Finding Text
The non-Federal entity must have and use documented procurement procedures consistent with State, local, and tribal laws and regulations and the standards identified in 2 CFR § 200.318 (c)(1) for the acquisition of property or services required under a Federal award or sub-award. During the audit period, it was noted that the District does not have a formal Conflict of Interest Policy in place. The absence of such a policy indicates a lack of formal procedures to identify, disclose, and manage potential conflicts of interest among employees, board members, and other stakeholders. The District has not yet developed or implemented a Conflict of Interest Policy, which may be due to oversight or a lack of awareness of the importance of such a policy in maintaining ethical standards and regulatory compliance. The absence of a Conflict of Interest Policy increases the risk of potential conflicts of interest going unreported and unmanaged. This could lead to decisions that are not made in the best interest of the District, potential legal or regulatory issues, and damage to the District's reputation.