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Page 3 3. The city will comply with all contractual requirements detailed in its duly executed grant agreements with awarding agencies. 4. The city will contract annually with an independent CPA firm for the purposes of conducting the city’s external financial audit. To the extent that the city has expended federal awards in excess of the applicable single audit limit (currently $750,000), the city will have a single audit performed in accordance with OMB UGG - Uniform Grant Guidance. 5. To ensure continuing compliance with all applicable accounting requirements, the city may, at its discretion, contract with a CPA firm to provide internal auditing and/or consulting services. 6. The Finance Director shall be responsible for the maintenance of all accounting and financial records (including journals, timesheets, bank statements, audit reports, and similar documents). Such records shall be retained as required by contractual or regulatory requirements. The city has adopted the state’s records retention schedule as its official guide for records storage, filing, and destruction. 7. The city and employees are required to comply with the city’s conflict of interest policy and report any potential conflicts of interest to their managers. No employee, officer or agent may participate in the selection, award or administration of a contract supported by a Federal award if he or she has a real or apparent conflict of interest. Such violations may result in appropriate discipline. See also the city policies on conflict of interest located in the city’s Personnel Policies and Procedures. 8. The city will request prior approval from federal agencies for program or budget changes. 9. Acquisitions for micro-purchases (below $10,000) may be awarded without soliciting bids if the city considers the price to be reasonable but applicable city purchasing procedures must be followed. Procurements for Small Purchases (less than $175,000 - Minn. Stat. § 471.345), in which case quotations must be obtained from an adequate number of sources. Procurements made by sealed bid should be made to the lowest responsible (not necessarily the lowest) bidder. Procurements made by competitive proposal must have standards to evaluate the selected recipient. Procurement made by non-competitive proposals (to one vendor) may be used only if one of the following applies a) the item is available from a single source, b) an emergency exists c) the federal agency expressly authorizes non-competitive proposals, or d) competition is seen as inadequate after solicitation to a number of vendors. 10. Other procurement procedures include: Contractors who develop or draft specifications for bids are precluded from bidding on them. The city must maintain oversight so that contractors perform work as bid. Multiple provisions must be included in contracts. The city must verify to http://www.sam.gov/ if contract is $30,000 or more to review if on the suspended and debarred list for federal grants. 11. Procedures for inventory of federal capital purchases will be maintained by the Finance Department, with the help of the Public Works Director, and all items will be tracked annually. 12. The Finance Director (or designee) or the City Administrator are required to certify expenditures. Purchasing and Procurement It is the policy of the city to ensure that all disbursements of city funds are properly reviewed and authorized, and consistent with sound financial management principles, and made in compliance with all applicable federal, state and local laws. In order to meet these objectives, all disbursements of city funds shall be subject to the following provisions, to the extent that they do not conflict with or contradict with any specific federal, state or local law or Council policies (the most specific or restrictive law, policy or procedure will be followed):