Page 27 - The EDGE Spring 2020

Conflict of Interest - Does Your Staff Fully Understand?

CONTINUED FROM PAGE 25

So when does a conflict of interest actually exist?
• If an employee, board member, or relative has a
substantial interest in a commercial venture with whom the
school district does business.
• If an employee, board member, or relative is involved
in participating in the purchase of goods or services where
conflict exists. This includes voting, approving, developing,
introducing, administering, giving advice, recommending,
attending meetings, providing information, influencing decisions
or directing an employee to approve.

If either of the above scenarios exists, there is a conflict of
interest, and an employee or Governing Board member must
disclose as such.

Conducting a Risk Assessment

If your district hasn’t done a risk assessment recently regarding
potential fraud, it may be time to do so. Some questions to Protecting Your District
consider include: Does your district have a conflict of interest
policy? Are all employees aware of the conflict of interest
policy? Is the policy implemented consistently and responsibly? Here’s a little homework for you to get started.
Does management review the conflicts to consider whether they • Review your state laws to ensure your complete
are still valid? In addition to these questions, risk assessments understanding of the rules and consequences around
for personal interest, job function and vendor relations should conflict of interest.
be conducted.
• Review your district’s policy and procedures.
Best practices to help prevent fraud due to conflict of interest • Evaluate your district’s organizational risk, personal risk,
should be implemented. Employees should be required to fill job duty risk, and vendor relations risk.
out a conflict of interest form when hired, and those forms • Train all district employees to ensure they know what
should be renewed annually. Board members should be required constitutes a conflict of interest.
to fill out a conflict of interest form when elected, and those
forms, too, should be renewed annually. Timely and thoroughly • Go a step further to educate your vendors on conflict of
investigate allegations of inadequate disclosure of substantial interest policies and procedures.
interests and/or inappropriate participation when substantial • Learn where your district’s conflict of interest forms
interest may exist. are retained and how Purchasing becomes alerted when
conflicts are disclosed.
Trainings should be conducted annually to ensure district • Establish an alert in your purchasing system that allows
conflict of interest policies are communicated to employees your district to monitor vendors with a conflict.
and acknowledged as received and understood. In my district,
we have an online tool that contains the training for employees • Compare employee addresses with vendor addresses to
to review annually. It also tracks which employees have and see if any are the same.
haven’t completed the training and sends them reminders to • Conduct a vendor audit by reviewing ownership of
complete. businesses through state databases.
• Finally, educate, speak up, and encourage transparency.
Jill Barragan can be reached at: jbarrag@avondale.k12.az.us These measures will go a long way in helping you protect
your district against fraud due to conflicts of interest.

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