Finding Text
2025-004 - Absence of Written Standards of Conduct – Significant Deficiency Federal Agency: Environmental Protection Agency Federal Program: Climate Pollution Reduction Grants Assistance Listing Number: 66.046 Pass-through Entity: City of New Orleans Award Identification Number: K25-486, BRASS No. 7241 Criteria 2 CFR 200.318(c)(1) requires a non-Federal entity to maintain written standards of conduct covering conflicts of interest and governing the actions of employees engaged in the selection, award, and administration of contracts. Condition The Organization had not adopted written standards of conduct addressing conflicts of interest and employee conduct requirements applicable to federal awards. Cause Management had not formally developed and adopted standards of conduct meeting Uniform Guidance requirements. Effect Without written standards of conduct, the Organization may be unable to demonstrate compliance with federal conflict-of-interest and ethical conduct requirements. Recommendation Management should adopt written standards of conduct that address conflicts of interest and other ethical requirements applicable to federal awards and communicate those standards to employees, officers, and governing board members. Views of Responsible Official and Planned Corrective Actions Management agrees with the finding. The Organization will develop and adopt written standards of conduct addressing conflicts of interest and other ethical requirements applicable to federal awards and will communicate those standards to employees and Board members. Questioned Costs None.