Protected Bidding & Procurement Policy

1. Applicable Laws & Regulations

Peterpan Corp's procurement practices comply with:

2. Procurement Thresholds & Methods

All procurement follows tiered competitive requirements based on contract value:

Contract Value	Method Required	Documentation
Under $10,000	Micro-purchase — No competitive quotes required	Purchase order or receipt; price reasonableness determination
$10,000 - $49,999	Small purchase — Minimum 3 written quotes	Written quotes from qualified vendors; selection justification memo
$50,000 - $249,999	Sealed bids — Formal Invitation for Bids (IFB)	Public notice, sealed bid opening, award to lowest responsive/responsible bidder
$250,000+	Competitive proposals — Request for Proposals (RFP)	Evaluation committee, scoring criteria, board approval, public notice

3. Fair & Open Competition

Per 2 CFR 200.319, all procurement transactions must provide full and open competition. Peterpan Corp ensures:

• No organizational conflicts of interest — Board members, officers, employees, and their families are prohibited from participating in procurement decisions where they have a financial or personal interest
• No arbitrary barriers — Specifications are written to encourage maximum competition and are not tailored to favor a specific vendor
• No geographic preferences — Except where required by federal statute (e.g., Section 3 HUD economic opportunity provisions)
• Equal access — All qualified vendors, including minority-owned, women-owned, and veteran-owned businesses, receive equal consideration
• Public notice — All sealed bid and RFP solicitations are publicly advertised with adequate response time (minimum 14 calendar days for bids, 21 days for proposals)
• Documented evaluation — All bids/proposals are evaluated using pre-established, written criteria

4. Conflict of Interest Policy

Per 2 CFR 200.318(c)(1) and Kansas nonprofit governance requirements:

• No officer, director, employee, or agent of Peterpan Corp may participate in the selection, award, or administration of a contract if a real or apparent conflict of interest exists
• Conflicts include situations where the individual, their family member, or their business partner has a financial or other interest in the firm selected for award
• All board members and staff must complete annual conflict of interest disclosure forms
• Any identified conflict requires recusal from the procurement decision and documentation in meeting minutes
• Violations may result in removal from the board, termination of employment, and referral to appropriate authorities

5. Anti-Collusion & Bid Rigging Protections

All bidders are required to submit a Non-Collusion Affidavit certifying that their bid was prepared independently and without consultation with competitors. Suspected violations will be reported to the Kansas Attorney General's Office and, for federally funded projects, to the relevant federal Inspector General.

6. Minority, Women-Owned & Small Business Participation

In accordance with 2 CFR 200.321, Peterpan Corp takes affirmative steps to ensure that minority businesses, women's business enterprises, and labor surplus area firms are used when possible. These steps include placing qualified small and minority businesses on solicitation lists, soliciting these firms whenever they are potential sources, dividing total project requirements into smaller tasks where feasible, and using the services and assistance of the Small Business Administration and Kansas Department of Commerce Minority Business Development division.

7. Property Acquisition & Real Estate Transactions

Property acquisitions follow additional protections:

• Independent appraisals — All property acquisitions exceeding $25,000 require an independent, licensed appraisal
• Board approval — All real estate transactions require approval by the Board of Directors
• Title search — All acquisitions include a title search and title insurance
• Environmental review — For federally funded acquisitions, NEPA environmental review is completed per 24 CFR Part 58
• Uniform Relocation Act — Compliance with 49 CFR Part 24 when applicable
• Arm's length transactions — All transactions with related parties require additional scrutiny, independent valuation, and documented board approval with conflicted parties recused

8. Construction & Rehabilitation Projects

Construction and rehabilitation contracts include additional requirements:

• Performance and payment bonds required for contracts exceeding $250,000
• Prevailing wage compliance (Davis-Bacon) when required by federal funding sources
• Licensed and insured contractor verification
• Kansas contractor registration verification (K.S.A. 12-17,124)
• Change order procedures with written approval for changes exceeding 10% of contract value
• Retainage of 5-10% until satisfactory project completion
• Final inspection and punch list completion before final payment

9. Record Keeping & Transparency

Per 2 CFR 200.334 and Kansas public records requirements:

• All procurement records are retained for a minimum of 3 years after final payment (or longer if required by specific grant terms)
• Records include: solicitation documents, bid/proposal submissions, evaluation materials, selection justifications, contracts, change orders, and payment records
• Procurement records are available for audit by funding agencies, the Kansas Secretary of State, and the IRS
• Annual procurement activity is summarized in Peterpan Corp's Form 990 and annual report

10. Bid Protest & Grievance Procedures

Any bidder or proposer who believes the procurement process was conducted unfairly may file a formal protest:

1. Written protest must be submitted to Peterpan Corp's Director within 7 calendar days of the award announcement
2. The protest must include specific grounds for objection and supporting documentation
3. The Director will review the protest and issue a written decision within 14 calendar days
4. If unresolved, the protester may appeal to the Board of Directors at the next scheduled meeting
5. The Board's decision is final for internal purposes
6. For federally funded procurements, additional appeal rights may exist through the funding agency
7. Nothing in this procedure limits a bidder's right to seek judicial review in Dickinson County District Court or Shawnee County District Court

11. Debarment & Suspension Verification

Per 2 CFR 200.214 and Executive Order 12549, Peterpan Corp verifies that all contractors and subcontractors are not debarred, suspended, or otherwise excluded from participation in federal programs. Verification is conducted through the System for Award Management (SAM.gov) prior to contract award. Contracts include provisions requiring the contractor to notify Peterpan Corp immediately if they become debarred or suspended during the contract period.

12. Whistleblower Protection

Peterpan Corp protects individuals who report suspected procurement fraud, waste, or abuse in good faith. Reports may be made to the Director, the Board of Directors, or directly to the Kansas Attorney General's Office. Retaliation against whistleblowers is prohibited and will result in disciplinary action up to and including termination. Whistleblower protections are provided under the Kansas Whistleblower Act (K.S.A. 75-2973) and, for federally funded programs, 41 U.S.C. 4712.

13. Contact & Oversight

For questions about procurement, to request bid documents, or to report concerns: