Conflict of interest — purchasing

An employee with an undisclosed financial or personal interest in a vendor uses their position to benefit that vendor: steering awards, approving inflated or unneeded purchases, or avoiding competitive procurement.

Partly covered. The remaining analysis is planned.

Starter pack: Disbursement review, Procurement integrity

Red flags

In the data

• Vendor shares an address, phone, email, bank account, or TIN with an employee
• One buyer or approver accounts for most activity with a vendor
• Sole-source awards and awards just under bid thresholds
• Requester is also the approver, or approver acts above their limit

Behavioral

• Employee resists rotation of vendor responsibility
• Employee has social ties to the vendor's owners
• Conflict-of-interest disclosure not filed or incomplete

Internal controls

• No annual conflict-of-interest disclosure or no review of disclosures
• Vendor ownership not collected at setup
• Sole-source justifications not reviewed independently