DJH: PURCHASING AND CONTRACTING: PROCUREMENT STAFF CODE OF CONDUCT

Conflict of Interest

All employees of Kittery School District 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 Kittery School District may participate in the selection, award or administration of a contract supported by a federal award if he/she has a real or apparent conflict of interest.

A conflict of interest would arise when the employee or any member of his/her immediate family, his/her partner, or an organization that employs or is about to employ any of these 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, brother, sister, parent, son or daughter. 

For the purpose of this policy, “immediate family” is defined as spouse, brother, sister, parent, son or daughter.

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 the Kittery School District and is fair and reasonable, he/she may proceed with the transaction.  In the event that the Superintendent may have a conflict of interest, an ad hoc subcommittee of the School Committee will investigate and make a determination regarding the transaction.

Gifts and Solicitations

Employees, officers and agents of the Kittery School District 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 the Kittery School District 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.

Adopted:                 July 21, 2011

Revised:                 January 15, 2019

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 12/26/2014)

Cross Reference:    DJ - Bidding/Purchasing Requirements

                                DJ-R – Federal Procurement Manual