DJH Procurement of Staff Code of Conduct
PURCHASING AND CONTRACTING: PROCUREMENT STAFF CODE OF CONDUCT
Conflict of Interest
All employees of Regional School Unit 1 shall perform their duties in a manner free from conflict of interest to ensure that the school unit’s business transactions are made in compliance with applicable laws and regulations and in a manner that maintains public confidence in the schools. No employee, officer, or agent of the school unit shall participate in the selection, award, or administration of a contract supported by a federal award if they have a real or apparent conflict of interest.
A conflict of interest would arise when the employee or any member of their immediate family, their partner, or an organization that employs or is about to employ any of the parties has a financial or other interest in the firm selected for the award. For the purpose of this policy, “immediate family” is defined as spouse, sibling, parent, or child.
Conflict of Interest Disclosure
All employees with real or apparent conflicts of interest as defined above must disclose the conflict of interest to the Superintendent who will investigate the circumstances of the proposed transaction. The Superintendent will exercise due diligence in investigating the circumstances of the transaction and, if necessary, will make reasonable efforts to find alternatives to the proposed transaction or arrangement that would not give rise to a conflict of interest. If the Superintendent determines that the proposed transaction is in the best interest of Regional School Unit 1 and is fair and reasonable, they may proceed with the transaction. In the event that the Superintendent may have a conflict of interest, an ad hoc subcommittee of the Board will investigate and make a determination regarding the transaction.
Staff Gifts and Solicitations
Employees, officers, and agents of the school unit may neither solicit nor accept gratuities, favors or anything of monetary value from contractors or parties to subcontracts. Employees, officers, and agents of the school unit may accept unsolicited items of nominal value such as those that are generally distributed by a company or organization through its public relations program.
Violations
Employees of Regional School Unit 1 who violate this code of conduct may be subject to discipline, up to and including termination of employment, and, if appropriate, referral to law enforcement.
Legal Reference: 34 CFR Parts 74 and 80 (Education Department General Administrative Regulations (“EDGAR”)) (for federal awards made prior to 12/26/2014) 2 CFR § 200.318 (Uniform Administrative Requirements - General Procurement Standards) (for federal awards made on or after 12/26/14)
Cross Reference: BCB - Board Member Conflict of Interest DJ - Bidding/Purchasing Requirements DJ-R – Federal Procurement Manual KCD - Public Gifts to the Schools
Adopted: February 22, 2010 Revised: November 25, 2019; June 28, 2021; April 24, 2023
This is a required policy.