Administrative Regulation Title:  Procurement Card Ethics

Regulation Number:  6.8.2

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EWC employees and trustees are subject to the laws and policies which impact all public employees. Employees are not to show favoritism to particular vendors or providers of services or share one vendor’s quotes with another. The acceptance of gifts and gratuities of value from outside interests such as vendors is illegal. When in doubt about the acceptance of gifts that may be considered customary, remember, the best guideline is DO NOT ACCEPT ANYTHING OF VALUE FROM A VENDOR.

Conflict of Interest

A conflict of interest occurs when an employee either:

  1. Has an existing or potential financial or other interest which impairs, or might appear to impair, the employee’s independent judgment in the discharge of responsibilities to the College or,
  2. May receive a material, financial or other benefit from knowledge or information confidential to the College.

Card Misuse and Sanctions Card

Misuse and failure to adhere to the requirements of the P-Card program has serious consequences. The cardholder understands that his/her improper use of the EWC procurement card may be cause for disciplinary action by the College, including termination, and that improper use of the procurement card may subject the cardholder to criminal prosecution. Misuse is broadly defined as using the card in violation of college policies and procedures as well as the P-Card program requirements.

Examples of misuse of the procurement card include, but are not limited to:

  1. Using the procurement card for personal purchases or for purchases that are not authorized by the College.
  2. Using the procurement card to purchase any goods or services that violate policies or procedures of the College, including those items listed as specific exclusions for the procurement card, or which violate any law or regulation to which the College must adhere.
  3. Splitting a transaction to circumvent the transaction limit authorized for the cardholder’s card.
  4. Using multiple cards to circumvent the transaction limit authorized for the cardholder’s card.
  5. Failing to provide required purchasing documentation in a timely manner.
  6. Failing to provide information about any specific purchase.
  7. Giving the cardholder’s P-card to another individual to use for a purchase. Occasionally, a person may be authorized to use another cardholder’s card.  The cardholder may make transactions on behalf of others in his/her college, department or division; however, the cardholder is responsible for the business validity of the use of his/her card.

Reporting Misuse of the Procurement Card

All P-Card program participants, including but not limited to the: president, vice-presidents, deans, directors, cardholders and budget managers are required to know and follow procurement card policies. Program participants also need to be aware of program misuses and consequences associated with these misuses. A department vice president, dean or director, budget manager and the Vice President of Administrative Services may review all transactions in order to identify possible misuse of the card. The review should be conducted each statement period and prior to submitting the final paperwork to the Business Office. By signing the P-card statement, the Budget Manager is acknowledging that all transactions were made appropriately and that no misuse has occurred. The Business Office shall notify the Budget Manager when it appears that misuse has occurred. Cardholders and Budget Managers are solely responsible for their own actions and cannot claim that they were ignorant of the rules or someone else in their department or the College insisted that they bend the rules. Prohibited purchases and card misuse are outlined throughout the procedures manual and reviewed during training sessions completed by all cardholders and support staff.

Consequences and Accountability

When it has been found that misuse may have occurred or that the requirements of the Procurement Card Manual are not being followed, the Budget Manager shall notify the Vice President of Administrative Services of such issues. The Vice President of Administrative Services will review the information to determine the best course of action in conjunction with the problems outlined below.

Frequent problems associated with the program processes may include, but are not limited to:

  1. Failure to provide a detailed receipt.
  2. Failure to enter an authorized and complete budget string.
  3. Failure to obtain written approval when purchasing for others.
  4. Failure to complete the month-end processes on time.
  5. Failure to ensure that the P-card statement and receipts match and contain only authorized purchases.

Consequences for misuse may include, but are not limited to:

  1. Written notification of misuse sent to department head and cardholder
  2. The Vice President of Finance and Administrative Services or the President reserves the right to suspend or cancel cards at any time.
  3. Termination of employment
  4. Criminal prosecution

 

Original Adoption Date: 10/10/19

Revision Date(s): 

Date reviewed, no change: