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Ethics

Revolving Door Prohibition

The Ethics Act prohibits employees (or their spouse or immediate family member), including appointees, of Illinois State University from working for an outside vendor for one year after leaving university’s employment if he/she participated personally and substantially in decisions to award contracts to that vendor that exceeded $25,000.

The purpose of this prohibition is to prevent any quid-pro-quo act of awarding a contract in exchange for other employment.  The Act defines to impacted employee groups:

  • “C List” employees who by the nature of their duties may have the authority to participate personally and substantially in the award of State contracts/grants or in making regulatory /licensing decisions.
  • “H List” employees/appointees are senior level State employees who are fall under the Act by nature of their position and include the following:
    • Members of a board created by the Illinois constitution.
    • Persons whose appointment to office is subject to the advice and consent of the Senate;
    • The head of an administrative unit within the government of the State.
    • Chief procurement officers, State purchasing officers, and their designees whose duties are directly related to State procurement; and
    • Chiefs of Staff

The University Ethics Office maintains a listing, which is also provided to the State of Illinois, of those individuals associated with the University who are subject to the Revolving Door Prohibition.  University employees are notified annually by the University Ethics Office that they are on the list.

Requirements

  • C List and H List employees/appointees must acknowledge their receipt of the Revolving Door provisions annually.
  • C List employees/appointees must notify the Office of Executive Inspector General (OEIG) and complete necessary forms when they or an immediate family member living in their household are offered employment or compensation from a non-State employer so that the OEIG can determine if accepting the employment or compensation is prohibited by law. See the OEIG’s Frequently Asked Questions and Instructions and Forms for more information.
  • H List employees/appointees are strictly prohibited from Revolving Door employment.
  • Executive Order 15-09 expanded upon the Ethics Act Revolving Door Prohibition and added:
    • No employee, while employed by or serving as an appointee of a State Agency, shall negotiate for employment with any person or entity that is registered as a Lobbyist or Lobbying Entity and has identified that State Agency on it’s then-current Lobbying Entity registration filed with the Secretary of State.
    • No former State Employee, within one year after leaving his or her position with a State Agency, shall accept compensation from any person or entity for lobbying any State Agency.
  • The Illinois Procurement Code – Revolving Door Prohibition places a further two-year prohibition on chief procurement officers, State purchasing officers, or their designates whose principal duties are related to State procurement.

Violations of the Revolving Door Prohibitions may result in a fine of up to three times total compensation.

For additional questions, contact the University Ethics Officer.