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Conflicts of Interest: GBEA

  • Personnel: G
Conflicts of Interest: GBEA

27J employees serve the mission of the district. No district employee shall engage in or have a financial interest, directly or indirectly, in any activity that conflicts or raises a reasonable question of conflict with his or her duties and responsibilities in the school system. Employees are expected to perform the duties of the position to which they are assigned and to observe rules of conduct and ethical principles established by state law and district policies and regulations.

It shall be understood that all confidential information an employee is privy to as a result of district employment shall be kept strictly confidential. In addition, employees shall not utilize information solely available to them through school sources to engage in any type of work outside of the school district. This includes information concerning potential customers, clients or employers.

An employee shall not sell any books, instructional supplies, musical instruments, equipment or other school supplies to any student or to the parents/guardians of a student who attends the school served by the employee unless prior approval has been obtained from the Superintendent.

Moreover, to avoid a conflict of interest, the district prohibits an employee from exercising supervisory, appointment, dismissal authority, or disciplinary action over a member of the employee's immediate family. For purposes of this policy, an employee's "immediate family" includes his or her spouse, partner in a civil union, children and parents. In addition, an employee may not audit, verify, receive or be entrusted with moneys received or handled by a member of the employee's immediate family. An employee shall not have access to the employer's confidential information concerning a member of the employee's immediate family, including payroll and personnel records.


Separate from state law and the Superintendent's policies concerning district employees' standards of conduct and conflict of interest, federal law imposes restrictions on the conduct of district employees whenever the transaction in question is supported by federal funds subject to the Uniform Grant Guidance (UGG).

Under the UGG, a district employee shall not participate in the selection, award or administration of a contract supported by a federal award if the employee has a conflict of interest as defined by the UGG.

A conflict of interest arises under the UGG when the employee, any member of his or her immediate family, his or her business partner, or an organization which employs or is about to employ any of the aforementioned parties has a substantial financial or other interest in or would obtain a substantial tangible personal benefit from a firm considered for a contract.

In addition, the UGG prohibits district employees from soliciting or accepting gratuities, favors, or anything of monetary value from contractors or parties to subcontracts that are federally funded, unless the gift is an unsolicited item of nominal value.

For purposes of this policy section only, "immediate family" means the employee's spouse, partner in a civil union, children and parents. In determining whether a financial or other interest is "substantial," or whether anything solicited or accepted for private benefit is of "nominal value," district employees shall follow the standards of conduct and corresponding definitions applicable to local government employees under state law.

These minimum federal requirements are not waivable in connection with any transaction or contract to which they apply.

An employee who violates the standards of conduct set forth in this policy's section may be subject to disciplinary action, in accordance with applicable law and Board policy.


Undue favoritism in the conferral of any District benefit, reward or privilege (for example, offers of employment, promotion, premium salary schedule placements, preferential overtime pay opportunities, salary increases, compensation bonuses, preferential job assignments, travel opportunities, etc.), is a conflict of interest with an employee's obligation to exercise fairness and professional judgment in the conduct of District business.

Undue favoritism based on race, religion, sex or other legally prohibited factors may also violate state and federal anti-discrimination laws and 27J policy.

Additionally, undue favoritism fosters lack of respect, distrust, and other employee morale problems which undermine professionalism and hinder fulfillment of the District's mission.

Undue favoritism constitutes misconduct justifying disciplinary action up to and including dismissal from employment.


Undue Favoritism – Generally: Undue Favoritism is the conferral of any District related benefit, privilege or reward based on factors other than individual merit and qualifications, and legitimate business considerations.

Undue favoritism Based on Legally Prohibited Criteria: Undue favoritism based on legally prohibited criteria is the unwarranted consideration of race, color, sex, sexual orientation, religion, national origin, age, gender identity, gender expression or disability in a decision or action which confers a District-related benefit, privilege or reward.


Undue Favoritism – Generally: In general, undue favoritism as defined in this policy occurs when a person who, by virtue of his or her position with the District, has authority to grant or deny District related benefits, but abandons professional and business judgment and confers those benefits on certain individuals because of some special relationship rather than on the basis of legitimate business considerations or District-related merit or qualifications. For example, a District manager who gives certain subordinate employees preferential job assignments, overtime opportunities, and more flexible leave and work schedules because those employees are personal friends with the manager, or also work for the manager in a non-District related business owned and operated by the manager would be in violation of this policy.


The District strongly believes that an environment where employees maintain clear boundaries between employee personal and business interactions is most effective for conducting business and maintaining positive employee morale. Although this policy does not prevent the development of all romantic relationships between coworkers, it does restrict such relationships between coworkers in a direct supervisor/subordinate relationship.

Though the romantic relationship between two consenting adults in these circumstances would normally be merely a private matter, the unequal status of the parties in the employment setting provides opportunities for one in a position of authority to favor or advance the other's Districtrelated interests. Even where such influence is not exercised, the appearance of favoritism may lead those not so advantaged to doubt the integrity of the normal processes available for advancement.

Accordingly, leaders/supervisors shall maintain professional boundaries/relationships and shall not engage in an intimate/romantic relationship with any employees with whom they exercise authority over. (A principal and assistant principal are presumed to have authority over all school staff.)

An employee who is currently in a romantic relationship with a District employee, but who is not in a supervisor-supervisee romantic relationship, shall not be hired, transferred, or promoted into a position that would create a supervisor-supervisee relationship except as authorized by the Chief Human Resouce Officer in writing.

In the event of a violation of this policy where a leader/supervisor and a subordinate become engaged in an intimate relationship, the leader/supervisor is required to immediately disclose the matter to the Chief Human Resources Officer so that the District can take appropriate action within the scope of the District's lawful authority to eliminate any conflict of interest.

Any 27J leader/supervisor who reasonably learns of conflicts of interests outlined in this policy including of a intimate/romantic relationship between another supervisor and subordinate shall immediately notify the Chief Human Resources Officer.