Employee Conflict of Interest

Code Number: 401.1

Employees’ use of their position with the District for financial gain is considered a conflict of interest with their position as employees and may subject employees to disciplinary action.

Employees have access to information and a captive audience that could award the employee personal or financial gain. No employee may solicit other employees or students for personal or financial gain to the employee without the approval of the Superintendent or his/her designee. If the approval of the Superintendent or his/her designee is given, the employee must conduct the solicitations within the
conditions set by the Superintendent or his/her designee. Further, the Superintendent or his/her designee may, upon five days’ notice, require the employee to cease such solicitations as a condition of continued employment.

Employees will not act as an agent or dealer for the sale of textbooks or other school supplies, including sports apparel or equipment, on behalf of themselves or any companies doing business with the District. Employees will not participate for personal financial remuneration in outside activities wherein their position on staff is used to sell goods or services to students or to parents. Employees will not engage in outside work or activities where the source of information concerning the customer, client, or employer originates from information obtained because of the employee’s position in the District.

It will also be a conflict of interest for an employee to engage in any outside employment or activity which is in conflict with the employee’s official duties and responsibilities. Situations in which an unacceptable conflict of interest is deemed to exist will include, but not be limited to, any of the following:

  1. The outside employment or activity involves the use of the District’s time, facilities, equipment and supplies or the use of the District’s badge, uniform, business card, or other evidence of office to give the employee or the employee’s immediate family an advantage or pecuniary benefit that is not available to other similarly situated members or classes of members of the general public. For purposes of this section, a person is not “similarly situated” merely by being related to an employee who is employed by the District.
  2. The outside employment or activity involves the receipt of, the promise of, or acceptance of money or other consideration by the employee or a member of the employee’s immediate family from anyone other than the District for the performance of any act that the employee would be required or expected to perform as part of the employee’s regular duties or during the hours during which the employee performs service or work for the District.
  3. The outside employment or activity is subject to the official control, inspection, review, audit, or enforcement authority of the employee during the performance of the employee’s duties.

If the outside employment or activity is employment or activity in (1) or (2) above, the employee must cease the employment or activity. If the activity or employment falls under (3), then the employee must:

  • Cease the outside employment or activity; or,
  • Publicly disclose the existence of the conflict and refrain from taking any official action or performing any official duty that would detrimentally affect or create a benefit for the outside employment or activity. Official action or official duty includes, but is not limited to, participating in any vote, taking affirmative action to influence any vote, or providing any other official service or thing that is not available generally to members of the public in order to further the interests of the outside employment or activity.

When procurement is supported by the Federal Child Nutrition funds, employees will not participate in the selection, award, or administration of a contract if there is a real or apparent conflict of interest in the
contract. Contract, for purposes of this paragraph, includes a contract where the employee, the employee’s immediate family, partner, or non-school District employer of these individuals is a party to the contract.

It is the responsibility of each employee to be aware of and take the necessary action to eliminate a potential conflict of interest should it arise.


First Adoption:
2015-05-11
Revision Adoption:
January 27, 2020
Reviewed Dates:
December 16, 2019
Legal Reference:
2 C.F.R. 200.318
Iowa Code §§ 20.7; 68B; 279.8; 301.28
282 I.A.C §§ 25.3(6)f, 26.3(6)

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