TANNEHILL

CONFLICTS OF INTEREST

In order to protect the public trust and maintain confidence in the fairness of public education, conflicts of interest or even the appearance of conflict must be avoided.  Therefore, it is the policy of the Tannehill Board of Education that school board members and school dis­trict personnel shall not engage in any activity that would create a conflict of interest.

Personal property acquired by the district is intended for use by employees of the district within the scope of their employment.  Use of school property, including, but not limited to, teaching materials, computer software and hard­ware, electronic equipment, and other equipment, outside of the scope of the employee’s employment is prohibited  Employees that utilize school district owned property for personal use or gain may be subject to disciplinary action which could include possible action to nonrenew or terminate employment. 

With regard to any Federal funding, the district will disclose in writing any potential conflicts of interest to the Federal awarding agency or pass-through entity in accordance with applicable federal awarding agency policies and procedures. 

No employee, officer, or agent must 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 a conflict of interest would arise when the employee, officer, or agent, any member of his or her immediately family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from a firm considered for a contract.  The officers, employees, and agents must neither solicit nor accept gratuities, favors, or anything of monetary value from contractors or parties to subcontracts.  Violation of these standards will result in disciplinary action which may include termination of employment. 

Contracts and Business Arrangements

   1.       Contracts with Board Members

              Oklahoma law prohibits a school board from entering into a contract in which a board member is directly or indirectly interested.  70 O.S. § 5-124. 

   2.       Disclosure of Other Contracts and Business Arrangements

              The board of education believes that certain business and contractual arrange­ments by employees, although not in violation of state law, create such a potential for conflict of interest that such contracts or relationships should be disclosed to the superintendent.  The following contracts or business relationships shall be disclosed in writing to the superintendent:

             A.   Any two or more district employees who together enter into any business relationship, including, but not limited to, a partnership, corporation, or lessor/lessee relationship.

             B.   Any employee who has a substantial interest, directly or indirectly, in any person or entity that is pro­viding services or sales of equipment or other goods or commodities to the district where such rela­tionship would result in a direct or indirect monetary benefit to the employee.

              Any violation of the foregoing reporting requirements will subject the employee or employees involved to possible disciplinary action which could include possible termination or nonrenewal of employment.

CONFLICTS OF INTEREST (Cont.)

   3.       Contracts or Employment Relationships between Employees

              District employees are not permitted to have other employees do personal errands or work for them during normal employment hours for personal gain.

              District employees who hire or use the services of other district employees for personal benefit during times other than normal employment hours should do so in such a manner as to avoid the appearance that the work or employment is being done as a condition of employment or is being done during normal employment hours. 

4.           Other Prohibited Activities

              In addition to the foregoing, the board of education prohibits any employee from receiving a monetary benefit as the result of any contract between a non-employee and the district.

Outside Activities of Full-time Employees

This portion of the policy applies to full-time employees.  A full-time employee shall be construed as any teacher, administrator, support employee, or other employee contracted as a full-time employee with the district and shall include all teachers and other employees who are engaged as full-time employees for only a portion of the year because of summer vacation or any other reason.  All full-time employees shall report any outside business activities or em­ploy­ment in writing to the superintendent.  The intent of this provision is not to prohibit such activities, but to allow the super­intendent to be fully aware of activities that may give rise to violations of other provisions of this policy. 

It is the express policy of the board of education that full-time employees devote their full efforts to their assigned activities during their normal business hours.

Legal Reference:         70 O.S. § 5-124

                                          2 C.F.R. § 200.112

                                          2 C.F.R. § 200.318