• GBCAA: Conflict of Interest in Contracting and Purchasing

    Policy

    Board Members, the Chief Executive Officer (CEO), and all employees who make purchasing or contracting decisions on behalf of the District (collectively “Covered Persons”) shall perform their duties in a manner free from conflict of interest to assure the proper performance of school business as well as to earn and keep public confidence.

    Conflict of Interest Defined

    A “conflict of interest” is any transaction or relationship that presents or may present a conflict between the duties of the Covered Person to the District and his or her personal, business, or other interests.

    Conflict of Interest Disclosure

    A Covered Person who is employed by or under contract with a business enterprise with which the District is considering entering into a contract, or who knows that he or she has a family member with an ownership or employment interest in that business enterprise, should disclose the potential conflict or the appearance of a potential conflict of interest as soon as he or she learns that the district is considering such a contract. A Board Member shall not vote on any contract in which he or she has a potential conflict of interest.

    Every Covered Person shall also complete a disclosure form that identifies potential conflicts of interest that may arise from his or her personal and business dealings. The form shall be collected from all new Covered Persons and from existing Covered Persons on an annual basis.

    Board Members, the Chief Executive Officer, and the Chief Financial Officer shall file annual financial disclosure statements with the Ohio Ethics Commission as required by law.

    Substantial Conflict of Interest

    Although some potential conflicts of interest can be addressed by ensuring that the individual with a potential conflict does not participate in the decision making process, in other instances the conflict of interest may be so substantial that entering into a contract would create the appearance of impropriety.

    If a Covered Person has a substantial conflict of interest with regard to a proposed contract for services, supplies or equipment, the District shall not enter into that contract. A “substantial conflict of interest” means “a conflict of interest that is of such substance as to induce action on the part of the Covered Person to promote the contract for his or her own personal benefit.”

    History

    • Adopted: January 26, 2010
    • Amended: June 23, 2020

    Legal References