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Non-Federal entities who apply for and receive Federal financial assistance awards are required to "establish safeguards to prohibit employees from using their positions for a purpose that constitutes or presents the appearance of personal or organizational conflict of interest, or personal gain." [2] Broadly, applicants (and recipients) need to address any relationship or matter which might put themselves, their employees, or their subrecipients in conflict with their responsibilities under the award and outside interests. During the application process, non-Federal entities must disclose in writing any potential conflicts of interest related to the funding opportunity.  If disclosed, the Federal agency or pass-through entity may elect to work with the applicant on a mitigation plan as part of the Federal awards terms and conditions. Successful applicants agree when accepting the Federal award or subaward to disclose to the Federal awarding agency any subsequent real or perceived conflicts of interest during its lifecycleperiod of performance. Failure to do so could result in termination of the award or subaward. 

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