Conflict of Interest - Contract Management

Section: Case Management Agency (CMA)
Created: 02/25/2024
Revised:
Effective: 03/01/2024

Purpose

The purpose of this Weld County Case Management Agency (WCCMA) Conflict of Interest Policy is to ensure the highest standards of ethical conduct and integrity in fulfilling its contractual obligations. This policy aims to prevent actual or apparent conflicts of interest, promote transparency, and maintain the trust and confidence of the State and public in WCCMA's operations and decisions.

Policy

It is WCCMA's policy that all contractual engagements, operations, and interactions are conducted free from actual or apparent conflicts of interest to uphold the integrity and trust in its obligations under this Contract. This commitment extends to preventing any business activities, relationships, or practices that might directly or indirectly compromise the full performance of WCCMA's duties or the interests of the State.

Scope

WCCMA’s employees and/or Subcontractor’s employees, officers, or agents.

Contract Section(s)

SECTION 9: CONFLICT OF INTEREST

Policy Provisions

  1. Actual Conflicts of Interest: WCCMA shall avoid engaging in any transactions or maintaining any relationships that would conflict with its contractual duties. An actual conflict occurs if any benefit is offered or provided to a State employee, their immediate family, or partner by WCCMA's employees, officers, or agents in relation to the Contract’s management, oversight, or award.
  2. Apparent Conflicts of Interest: WCCMA acknowledges that, with respect to this Contract, even the appearance of a conflict of interest shall be harmful to the State’s interests. Absent the State’s prior written approval, WCCMA shall refrain from any practices, activities or relationships that reasonably appear to conflict with the full performance of WCCMA’s obligations under this Contract.
  3. Disclosure Requirements: If a conflict or the appearance of a conflict arises, or if WCCMA is uncertain whether a conflict or the appearance of a conflict has arisen, WCCMA shall submit to the State a disclosure statement setting forth the relevant details for the State’s consideration. Failure to promptly submit a disclosure statement or to follow the State’s direction regarding the actual or apparent conflict constitutes a breach of this Contract.
  4. State Ethical Standards Acknowledgment: WCCMA acknowledges that all State employees are subject to the ethical principles described in §24-18-105, C.R.S Contractor further acknowledges that State employees may be subject to the requirements of §24-18-105, C.R.S with regard to this Contract.

Monitoring and Enforcement Mechanisms:

  • WCCMA is responsible for the continuous monitoring of its activities to ensure adherence to this policy.
  • The State retains the authority to review and investigate any disclosed or suspected conflicts of interest, requiring full cooperation from Weld County.
  • Should a violation of this policy occur, WCCMA will be expected to take immediate corrective action as directed by the State, which may involve adjustments in practices, disciplinary measures, or cessation of conflicting relationships.
  • Records of all conflict disclosures and subsequent resolutions must be maintained by WCCMA for a period specified by the State or as required by law.

Policy Review

This policy will be updated as needed based on feedback and changes to contractual and regulatory requirements.