Conflict of Interest

Boss Watching As you perform your day-to-day duties, your co-workers and staff look to you for guidance. Performing your duties with integrity and in an ethical manner sets the tone for your department, your campus, and the district.

Cy-Fair ISD Strives to do things right – legally & ethically. Strives to avoid actual conflicts of interest and the appearance of conflicts of interest.

Avoid Headlines

Conflict of Interest Defined A situation that has the potential to undermine the objectivity of a person because of the possibility of a clash between the person’s self-interest and the person’s duties & responsibilities with the district. A situation that may impair or appear to impair an individual’s objectivity.

All Employees Avoid any conflict between their personal interests and the interest of the district in dealing with students, parents, vendors, customers, and all other organizations or individuals doing or seeking to do business with the district. Board Policy DBD (Local)

All Employees If an employee has an interest, obligation or relationship that in any way creates a potential conflict of interest with the proper discharge of assigned duties and responsibilities or with the best interest of the district, the employee should disclose this information in writing to his or her immediate supervisor. Board Policy DBD (Local)

Nonschool Employment If outside employment creates a potential conflict of interest with the duties of the employee or the district, the employee should disclose the situation in writing to his or her immediate supervisor.

Nonschool Employment An employee can not use district time or equipment for outside employment. An employee with outside employment may sell personal goods or services to other district employees. Employee receiving goods or services must not be in that employee’s chain of command whether as a staff or supervisor.

Private Tutoring & Private Service Provider Employee shall not privately tutor or provide private services (child care or respite care) to a student the employee teaches or serves for pay. Any private tutoring or private service for pay must be disclosed in writing to his or her immediate supervisor.

Gifts from Textbook Publishers Laws concerning textbook publishers and similar vendors are very strict. Gifts that can be accepted from a textbook publisher or similar vendor must relate to staff development, in-service, or teacher training; or instructional materials, such as maps or worksheets. No minimum dollar exceptions are allowed.

Example #1 An administrator’s spouse owns an office supply store. The administrator purchases office supplies from this store. The supplies cost more than the same supplies at the district’s distribution center or at another store and the quality is inferior. A conflict of interest exists.

Example #2 A principal purchases an educational product from a company owned by his or her parent. The product costs the same or less than that found through another company and the quality is good. A conflict of interest in appearance exists and should be avoided.

Example #3 For pay, a teacher provides child care during the school year to a student that she teaches. A conflict of interest exists.

Example #4 At a conference, a teacher attends a social event hosted by a textbook publisher. A violation of law occurs and the teacher commits a Class B misdemeanor offense. (Clarification concerning social events will be provided in the next few weeks.)

Employees with Primary Purchasing Responsibilities Annually employees with primary purchasing responsibilities need to complete a conflict of interest form. Employees with primary purchasing responsibilities are determined by position.

Conflict of Interest Forms Disclaimer – No conflict of interest exists. Disclosure – Possible conflict of interest exists. Product Disclosure Affidavit Disclosing Substantial Interest

Gifts from Vendors Gifts of less than $50 may be received from vendors or potential vendors. These gifts can not include cash or negotiable instruments. Gift cards may be accepted.

Trips To accept a trip paid for by a company, firm, or institution, prior written approval from the Superintendent must be received. Indicate the nature of the trip and why it should be accepted, the date of the trip, the party providing the trip, and its approximate value.

Conflict of Interest - Other Employees You may know if you have a conflict of interest, but you may not know if one of your staff has a conflict of interest. When an employee requests a purchase, ask whether they have an interest in the product being purchased or a relationship with the vendor.

YOU You are the best control in the district to help ensure that purchases are made in the best interest of the district. You make a difference!!!

Contacts Carol Oman, Internal Auditor carol.oman@cfisd.net 281-897-4111 Pat Stefan, Internal Auditor II patricia.stefan@cfisd.net 281-517-6537 Marney Collins Sims, General Counsel marney.sims@cfisd.net 281-807-8660

References Board Policy DBD (Legal) (www.cfisd.net – about cfisd – Policy Online) Board Policy DBD (Local) (www.cfisd.net – about cfisd – Policy Online) Administrative Regulation DBD-R & Exhibits (inside.cfisd.net – Policies)