CONFLICT OF INTEREST

Background

The District expects employees to act with the highest standards of integrity in discharging their employment duties. In order to maintain the public’s trust and confidence it is essential that employees acting on the District’s behalf avoid both the perception and any existence of conflict of interest. 

A conflict of interest arises when an employee’s private or financial interests compete with his or her professional duties to the District.  The District expects that its employees will not engage in activities where their actions or decisions are affected by personal gain, financial or otherwise or raise a reasonable question of conflict with their duties and responsibilities.

Procedures

1. Perceived conflict of interest
   1. A perceived conflict of interest exists when an employee’s private interests would appear to a reasonable person to conflict with their job duties, even though there may not actually be a conflict.
2. Potential conflict of interest
   1. A potential conflict of interest exists when an employee has private interests that, while no conflict has yet arisen, a conflict would arise were the employee to become involved in discharging workplace responsibilities in the future that could be influenced by the private interest.
   2. Employees are expected to request a determination from the Superintendent or Secretary-Treasurer before engaging in any activity that might reasonably raise questions about a possible conflict of interest.
3. Disclosure Process
   1. When an employee is aware they have a possible conflict of interest, they must disclose it, within 30 days, to the Secretary-Treasurer.
   2. Employees will outline:
      1. Specific duties that are relevant to the possible conflict;
      2. Specific private interests relevant to the possible conflict; and,
      3. Any interests of the District that you are aware of related to upholding public trust and confidence.
   3. When a possible conflict of interest has been reported, the Secretary-Treasurer will decide if the conflict exists and if it must be resolved or how it could be mitigated.
4. Duty to Report
   1. Employees will comply with all applicable laws and regulations and have a duty to report to the Secretary-Treasurer, in writing, any situation that they believe:
      1. Contravenes the law or District regulations.
      2. Misuses public funds.
5. General
   The following conduct by an employee will be considered to be a breach of conflict of interest:

    

   1. Receiving payment for privately providing services that are part of their responsibilities as an employee.
   2. Promoting at an employee’s school/site any services they privately offer to employees, students or parents.Any private services provided must not take place on District premises.
   3. Engaging in any activity outside regularly related employment duties, during working hours that promotes or involves an employee’s business interests or those of their immediate family.
   4. Utilizing District services, premises, materials and equipment for an employee’s business or their immediate family interests or other purpose which might compromise the interests of the District.
   5. Receiving personal gain, financial or otherwise for the sale of work or materials produced for the District as part of the employee’s normal duties for which the employee has been adequately compensated by the District.
   6. Demanding or accepting, directly or indirectly, a gift, favour, commission, benefit or services of any value where a personal benefit results, from any individual, organization, firm or corporation which might be interested in doing business with the District or may otherwise be interested in a benefit, gain, special consideration or favour from the District.
      1. It is recognized that hospitality and token promotional gifts or prizes of nominal value (less than $200) are an accepted courtesy in a business relationship.Recipients of such token gifts or hospitality are cautioned to ensure acceptance does not result in compromised objectivity.
      2. Gifts or prizes of other than nominal value are property of the District and must be disclosed to the Secretary-Treasurer to determine how they are best to be used to benefit the District.
   7. Giving preferential treatment, in the performance of duties, to an individual, corporation or organization, in which the employee or their immediate family has a financial interest.
   8. Selling or assisting in the sale of supplies or equipment within or to the District, and furnishing lists of students or parents to anyone selling such services or material.
   9. Making personal bids on the sale of District property or goods other than those disposed of at public auction.
   10. Representing themselves as being in a position to commit the District to the purchase of goods or services, except in accordance with relevant policies and procedures, and within the recognized authority of their position.
   11. Divulging confidential information that employees receive as a result of their employment with the District.Any information received must be kept confidential and is not to be divulged to anyone other than individuals authorized to receive such information.
   12. A business relationship between the District and an employee with external business interests.Exceptions may be made where no other source for the required product or service is available. In such cases, Secretary-Treasurer approval is required.
6. Employment Outside of the District
   1. Employees who are engaged in employment or who have business interests outside of their employment with the District must comply with the following guidelines:
      1. The outside employment or business interests must not interfere with performance of the employee’s duties to the District and must take place outside of the employee’s normal or scheduled working hours.
      2. The employee shall not use the District’s time or resources (including but not limited to photocopies, email, printers, vehicles, cellular phones, equipment and supplies) for the benefit of non-District employment or business interests.
      3. The employee shall not engage in any outside employment or business interest that is incompatible with the employee’s assigned duties.