What approach can be taken relative to disclosure data at institutions where purchases are decentralized and where the size of individual contracts is small?

The expectation of affiliate institutions is to make a good faith effort to gather disclosure data from the university’s vendors so that monitoring can take place.  The WRC recognizes that in the case of some vendors (for example, purchases made from local shops), it may not be practical to gather disclosure data.  The WRC recommends that universities implementing a code of conduct for the first time begin by focusing on the largest contracts and most significant vendors, particularly those which supply multiple universities, and to the extent feasible to work with other universities, through regional consortia or other groupings, to coordinate disclosure data gathering activities.