Third Party Management

Contracts with third parties pose financial and reputational risk to the System. In particular, contracts create the opportunity for fraud unless adequate policies and internal controls are in place.

The System’s Comply with Anti-Bribery Laws Policy addresses potential fraud in business relationships with third parties, in particular the Foreign Corrupt Practices Act. In addition, the System’s policies on conflicts of interest and commitment help maintain objectivity and fairness in the System’s dealings with third parties. For additional information, see Policies and Procedures.

Before contracts are signed, the Purchasing Office at each university screens the contract against state and federal excluded party lists, and contracts with foreign parties are screened using Visual Compliance for possible export control issues. Responsibility for contract performance monitoring is decentralized, with units responsible for ensuring vendors satisfy contract performance requirements.