Supplier Code of Conduct

University of Kansas (KU) recognizes that, in applying this code, suppliers must be mindful of their obligations under applicable laws, rules, and regulations, their respective contractual arrangements with KU and others, as well as University policies and procedures. If local laws, rules, or regulations applicable to a supplier or a supplier’s pre-existing contractual arrangements conflict with the expectations set forth in this code, suppliers are expected to work in good faith with KU to reach a mutually agreeable resolution that ensures compliance with the local law(s) or regulation(s) and, to the extent possible, the letter and spirit of this code.

In the event of conflict between the terms of a supplier’s contract with KU and the provisions of this code, the contract terms will prevail. This code does not constitute an employment contract or create an employment relationship between supplier’s employees and KU.

Governance and Ethical Business Practices

Suppliers are expected to conduct business with the highest ethical standards, uphold KU standards, and for each to develop policies and programs as appropriate to ensure that all supplier’s workers understand and adhere to these standards.

KU expects suppliers to develop programs and adopt and maintain policies and procedures so that conduct risk is monitored and governed. In particular, KU expects our suppliers to ensure policies and procedures effectively address the following topics:

1. Maintain Policies and Procedures to Ensure Business is Conducted Lawfully and With Integrity

• Suppliers must disclose any potential conflicts of interest prior to initiating a business relationship with KU or disclose a conflict as soon as a supplier becomes aware of a conflict.
• Suppliers must not directly or indirectly give, offer, or accept anything of value to improperly obtain or retain business or favored treatment, to improperly influence actions or to obtain an improper advantage for KU, itself, or any third party.  
• Suppliers must not directly or indirectly engage in, or facilitate the engagement by others in, the deliberate and fraudulent diversion of funds from a tax authority.
• Suppliers must not engage in illicit activities, including doing business with those engaged in illicit activities.

2. Maintain Policies and Procedures to Ensure Good Employee Working Conditions

• Suppliers are expected to provide their workers with open access to transparent and confidential processes to raise workplace concerns, resulting in swift and fair investigation, with a clear resolution and protection from retaliation.
• The University prohibits discrimination on the basis of race, color, ethnicity, religion, sex, national origin, age, ancestry, disability, status as a veteran, sexual orientation, marital status, parental status, gender identity, gender expression and genetic information in the University’s programs and activities. Suppliers are expected to have similar policies and practices.
• Suppliers must respect the rights of their workers in relation to freedom of association. Where the right of freedom of association and collective bargaining is restricted by law, the supplier will not hinder the development of alternative means for consulting with employees.
• Suppliers are expected to encourage that their subcontractors provide safe and healthy workplace conditions to prevent accidents, injuries, or exposure to health risks.

Compliance Assurance

This code sets forth our expectations for current and future suppliers. KU expects all new and existing suppliers to self-monitor their compliance with this code and make continuous improvement to their business as noted herein while conducting business with or on behalf of KU, and to self-report to the appropriate KU authority in a timely manner of any non-compliance. Reports can be made through KU’s Institutional Hotline.

KU reserves the right to monitor compliance with this code using a reasonable and risk-based approach and framework that is suitable for small and diverse-owned businesses as well as larger businesses with more mature compliance programs. This may include verification through self-assessment/questionnaires, on-site audits, and/or other means of due diligence. KU recognizes challenges that small and diverse-owned businesses may have to meet some of the expectations we have set forth. KU is committed to working with these businesses to achieve a reasonable level of compliance given their unique circumstances. If requested, suppliers are expected to provide written information, including, copies of policies and procedures and extracts of data regarding the supplier obligations under this code.

The failure or omission by KU to insist upon strict performance and compliance with any of the provisions of this code at any time shall in no way constitute a waiver of its rights.