CDBG Entitlement FAQ

Are there disciplinary actions that must be taken if the code of conduct is violated in a CDBG project?

Date Published: May 2015

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All procurements made with CDBG funds must comply with the applicable federal requirements found in 24 CFR Part 85.36. CDBG grantees are required to adopt written procurement standards for CDBG projects as required by 24 CFR Part 85.36(b). Grantees must develop and maintain a written code of standards that helps prevent conflicts of interest in procurement. The written code of conduct must apply to all employees, officers, agents of the grantee, members of their immediate family and partners. To the extent permitted by State or local law or regulations, such standards of conduct will provide for penalties or sanctions, or other disciplinary actions for violations of such standards by grantees and subgrantee's officers, employees, or agents or by contractors or their agents. Any alleged violations of your code of conduct should be referred to your legal counsel for review and appropriate actions if violations have occurred. Your legal counsel would advise you on disciplinary actions that may be appropriate under state and local law such as removal from position, financial penalties, etc. If violations or infractions are substantial in nature, your legal counsel may refer the matter to appropriate officials for criminal investigation and possible prosecution. Some communities have boards of ethics that review matters, issue opinions and recommend actions.

Tags: CDBG Entitlement Program Procurement