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Northern Arizona University
Purchasing Policy and Procedure

Anti-kickback Guidelines

POLICY:

In connection with any contract between the University and another party, no University employee shall receive from, or offer to the other party, or an employee of the other party, a kickback.

REPORTING

A University employee who becomes aware of a violation of this policy shall report such violation to a University vice president/provost. If the alleged violation concerns a vice president/provost, the violation should be reported to the University president.

DEFINITION:

KICKBACK

Any money, fee, commission, credit, gift, gratuity, thing of value, or compensation of any kind that is provided, directly or indirectly, to any prime contractor, prime contractor employee, subcontractor, or subcontractor employee for the purpose of improperly obtaining or rewarding favorable treatment in connection with a subcontract relating to a prime contract.