Code of Conduct for HUD Grant Programs

Code of Conduct policies must address the “Conducting Business in Accordance with Ethical Standards” requirements included in the Administrative, National & Departmental Policy Requirements and Terms for HUDs Financial Assistance.

  1. Code of Conduct for Procuring Property and Services. All Federal award recipients, except states, and all subrecipients under Federal awards must have a code of conduct (or written standards of conduct) for procurements that meets all requirements in 2 CFR 200.318(c). Before entering into an agreement with HUD, each applicant selected for an award (other than a state) must ensure an up-to-date copy of the organization’s code of conduct, dated and signed by the Executive Director, Chair, or equivalent official, of the governing body of the organization, is available in the Code of Conduct e-library.

    Applicants can check the Code of Conduct List to confirm HUD has received their Code of Conduct. HUD does not collect or review state codes of conduct for compliance with 2 CFR 200.318(c). Instead, each state must follow the same policies and procedures for procurements under Federal awards that the state uses for procurements from its non-Federal funds, as provided in 2 CFR 200.317.

B. Other Conflicts of Interest. All recipients and subrecipients must comply with the conflict-of-interest requirements in the applicable program regulations and grant agreements. If there are no program-specific regulations for the award, the following conflict-of-interest requirements apply:

i. Conflicts Subject to Procurement Regulations. In the procurement of property or services by recipients and subrecipients, the conflict-of-interest rules in 2 CFR 200.317 and 2 CFR 200.318(c) shall apply. In all cases not governed by 2 CFR 200.317 and 2 CFR 200.318(c), recipients and subrecipients must follow the requirements contained in the list of exceptions located in the Administrative, National & Departmental Policy Requirements and Terms for HUDs Financial Assistance.

ii. General prohibition. No person who is an employee, agent, consultant, officer, or elected or appointed official of the recipient or subrecipient and who exercises or has exercised any functions or responsibilities with respect to assisted activities, or who is in a position to participate in a decision making process or gain inside information with regard to such activities, may obtain a financial interest or benefit from the activity, or have a financial interest in any contract, subcontract, or agreement with respect thereto, or the proceeds thereunder, either for himself or herself or for those with whom he or she has immediate family or business ties, during his or her tenure or for one year thereafter. Immediate family ties include (whether by blood, marriage or adoption) the spouse, parent (including a stepparent), child (including a stepchild), brother, sister (including a stepbrother or stepsister), grandparent, grandchild, and in-laws of a covered person.

A list of exceptions can be found in the Administrative, National & Departmental Policy Requirements and Terms for HUDs Financial Assistance.

Codes of Conduct must:

  1. Include a cover letter on the company’s letterhead that provides the name and title of the responsible official, mailing address, business telephone number and email address;
  2. Prohibit real and apparent conflicts of interest that may arise among officers, employees or agents, or any member of his or her immediate family, his or her partner or an organization that employs any of the indicated parties;
  3. If applicable, the standards must also cover organizational conflicts of interest;
  4. Prohibit the solicitation and acceptance by employees, of gifts or gratuities in excess of minimum value; and
  5. Provide for administrative and disciplinary actions to be applied for violations of such standards.

Failure to provide a copy of the organizations Code of Conduct and/or notify HUD of potential conflicts of interest may prevent applicants from receiving HUD funds.

If your organization is not listed in the Code of Conduct e-library, please forward an electronic copy of the Code of Conduct statement to

The email should contain:

  1. Organization UEI#
  2. Organization Legal Business Name (from
  3. Complete mailing address
  4. Name, title, email and phone# for the person with executive authority.
  5. Electronic codes of conduct statement (searchable documents preferred)

The Code of Conduct e-library will be recorded in a single Microsoft Excel workbook displaying organizations with a compliant Code of Conduct policy submissions. The Code of Conduct e-library is updated at least quarterly.