GEORGIA WIC PROGRAM PROCEDURES MANUAL VM Employee Conflict of Interest Policy No. VM- 100.09 Effective Date: October 1, 2016

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Policy To ensure the integrity of the WIC Program, both of the Vendor Management oversight functions shall ensure that no undeclared conflict of interest or the appearance of a conflict of interest exists for any employees of the Office of Vendor Management (OVM) and the Department of Public Health (DPH) Office of the Inspector General (OIG). Both offices shall ensure that no conflict of interest exists between their personnel and authorized retailers. A conflict of interest will be deemed to exist when an employee of a vendor oversight function is also a worker, owner or has relatives who work at or own a WIC approved retailer/vendor.

WIC OVM and OIG employees shall not engage in any activities which creates a conflict of interest between the employees’ assigned functions and any other interests or obligations or those of immediate family members or business associates.

WIC OVM and OIG employees shall not engage in activities which violate federal or state laws, WIC Policies, or which, in any way, diminish the integrity, efficiency, or quality of the WIC Program. WIC OVM and OIG employees shall not perform their official duties in a manner that would result in preferential or discriminatory treatment to any vendor.

WIC OVM and OIG employees shall not, directly or indirectly, ask for, give, receive, or agree to receive any compensation, gift, reward, or gratuity for performing, omitting, or deferring the performance of any job related duties.

WIC OVM and OIG employees shall not abuse, misuse, or disclose confidential information in a manner that can result in a direct benefit to employee or immediate family member or business associate.

WIC OVM and OIG employees must refrain from directing or recommending that a WIC participant choose or stay away from a specific vendor/retailer to redeem benefits.

WIC OVM and OIG employees must refrain from knowingly making a decision intended to benefit or to disadvantage a specific authorized WIC vendor/retailer.

An owner or spouse of an owner of a WIC authorized vendor is prohibited from being concurrently employed by WIC.

Note: Failure to comply with the terms of this policy may result in the employee being subject to appropriate disciplinary or corrective action, including dismissal.

All conflicts of interest issues or complaints shall be reported directly to the DPH Office of Human Resources.

This policy does not intend to deny any employee opportunities available to all other citizens of the state to acquire private economic or other interests so long as this does not interfere with their WIC duties or disadvantage the WIC Program in any manner. Conflicts of interest are not necessarily unwarranted, unethical or illegal, nor are they always avoidable. Rather, it is the failure to disclose conflicts or potential conflicts to appropriate authorities; to comply with approved

GEORGIA WIC PROGRAM PROCEDURES MANUAL VM Employee Conflict of Interest Policy No. VM- 100.09 Effective Date: October 1, 2016

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conflict of interest polices; to continue to engage in a conflict after disapproval by appropriate authorities; or to further conduct oneself in a manner that unethically hurts, hinders, or disadvantages the WIC Program that must be avoided.

Purpose To define what may constitute a conflict of interest between the staff responsible for vendor management oversight and an authorized WIC vendor. To ensure staff safeguard the confidentiality of WIC vendor information.

Procedures I. The OVM shall establish a written conflict of interest policy. Through education and supervision of OVM and OIG staff, OVM will ensure that no conflict of interest exists between OVM and OIG staff and/or vendors (retailers). All federal regulations, state statutes and OVM policies that address the avoidance of a conflict of interest and the safeguarding of vendor information will be reviewed with each OVM and OIG staff within the 1st week of employment and every two (2) years thereafter. See WIC Vendor Management Employee Conflict of Interest Statement

II. All OVM and OIG staff members shall sign a COI statement upon employment and once every two (2) years to coincide with the state agencies Management Evaluation. The employee’s supervisor shall also sign and date the COI statement. A copy of the completed and signed statement for each staff member shall be maintained in the employee file in the Office of the State WIC Director.

III. Each DPH Employee signs a Confidentiality Agreement during New Employee Orientation. The agreement is comprehensive and safeguards the sensitive information about vendors or potential vendors and addresses the commitment to not show prejudice or favoritism toward vendors or potential vendors. Additionally, the signee agrees to not share information with any person or entity that may result in an unfair advantage for any vendor as it related to the Department of Public Health procurement activities.

IV. The signed agreement is maintained in the Office of Human Resources. The tenets of the Confidentiality Agreement will be reviewed at the time that the staff member signs a conflict of interest statement for clarity and understanding.

Authority 7 C.F.R. § 246.26 (e) 7 C.F.R. § 246.26 (f) 7 C.F.R. § 246.12 (r)

GEORGIA WIC PROGRAM PROCEDURES MANUAL VM Employee Conflict of Interest Policy No. VM- 100.09 Effective Date: October 1, 2016

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7 C.F.R. § 246.12 (t) O.C.G.A. § 12-3-572

Definitions/Supporting Information Policy Confidentiality of Retailer Information Policy Request for Confidential Retailer Information WIC Vendor Management Employee Conflict of Interest Statement Georgia Department of Public Health Confidentiality Agreement

Contact Information Georgia Department of Public Health Georgia WIC Program Office of Vendor Management 2 Peachtree Street, NW, 10th Floor Atlanta, Georgia 30303