Clean Copy BHA Board Member Conflict of Interest

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Agenda Item

9. First Read: Board Policy BHA: Board Member Conflict of Interest

Summary: Presented by: Ms. Melanie V. Slaton, General Counsel, Hall Booth Smith, PC, Attorneys at Law
Request: It is requested that the Board of Education amend Board Policy BHA: Board Member Conflict of Interest.
Why: The Board Policy Review Committee met and conferred regarding Board Policy BHA: Board Member Conflict of Interest and determined the current language requires updates and recommended the proposed revisions.
Details: The purpose of the Board Policy Review Committee is to ensure the ongoing review, development, and refinement of Board policies governing the District. The Board Policy Review Committee has the goal of promoting transparency, accountability, and compliance with state, local, and federal laws while fostering a safe, equitable, and inclusive environment for all within the District. The Policy Review Committee determined the current language requires updates and recommends the proposed revisions.
Financial impact: No Financial Impact to the District
Contact: Ms. Melanie Slaton, General Counsel, Hall Booth Smith, PC. Attorneys at Law, 404.954.5000
Effective: Upon Board Approval
Status: Attorney Approval Not Required
                                                                                   Board Policy Manual
                                                                           DeKalb County School District

Board Policy BHA: Board Member Conflict of Interest                                        Status: ADOPTED

Original Adopted Date: 09/11/2000 | Last Revised Date: 11/01/2010 | Last Reviewed Date:
11/01/2010




Members of the DeKalb County Board of Educa on will adhere to these Conflict of Interest
provisions as set forth in state law.

    A. Financial Governance

            1. No Board member will use or a empt to use the member’s official posi on to secure
               unwarranted privileges, advantages, or employment for any member, for any Board
               member’s immediate family, for any business organiza on with which the Board
               member is associated, or for any others.

            2. No Board member, or any member of a Board member’s immediate family, or any
               business organiza on with which is the Board member associated will sell supplies or
               equipment used, consumed, or necessary in the opera on of the DeKalb County
               School District. Any member viola ng this paragraph will be guilty of a
               misdemeanor.

                     a. It will not cons tute a viola on of this paragraph for a Board member to
                        sell supplies or equipment used, consumed, or necessary in the opera on of
                        the DeKalb County School District if there are fewer than three sources for
                        such supplies or equipment within the county.

                     b. Any such purchase of $10,000.00 or more will be approved by a majority of
                        the Board members in an open public mee ng.

            3. No Board member will act in official capacity in any ma er in which any Board
               member, any member of a Board member’s immediate family, or any business
               organiza on in which a Board member is associated has a material financial interest,
               if such interest would reasonably be expected to impair the Board member’s
               objec vity or independence of judgment. Acts that comply with subparagraphs (a)
               and (b) of paragraph 2 above will not cons tute a viola on of this paragraph.

            4. No Board member or any member of a Board member’s immediate family may be an
               officer of or have any financial interest in any for-profit organiza on that sells or
               leases goods or services to the District except as provided in subparagraphs (a) and
               (b) of paragraph 2 above.

            5. No Board member will solicit or accept, or knowingly allow any member of his or her
               immediate family or any business organiza on in which he or she is associated to
               solicit or accept, any gi , favor, loan, poli cal contribu on, service, promise of future
               employment, or other thing of value based upon an understanding that the gi ,
               favor, loan, contribu on, service, promise, or other thing of value was given or
   offered for the purpose of influencing that Board member in the discharge of the
   Board member’s official du es.


       a. This paragraph will not apply to the solicita on or acceptance of campaign
          contribu ons by a Board member who has announced that he or she is they
          are a candidate for Board office if the Board member has no knowledge or
          reason to believe that the campaign contribu on, if accepted, was given with
          the intent to influence the Board member in the discharge of his or her
          official du es.

       b. For purposes of this paragraph, a gi , favor, loan, contribu on, service,
          promise, or other thing of value will not include the following items:

              1. Food or beverage consumed at a single meal or event;

              2. Legi mate salary, benefits, fees, commissions, or expenses associated
                 with a Board member’s nonpublic business, employment, trade, or
                 profession;

              3. An award, plaque, cer ficate, memento, or similar item given to a
                 Board member in recogni on of civic, charitable, poli cal,
                 professional, or public service;

              4. Food, beverages, and registra on at group events to which all Board
                 members are invited;

              5. Actual and reasonable expenses for food, beverages, travel, lodging,
                 and mee ng registra on which are provided to permit a Board
                 member to par cipate in or speak at the mee ng;

              6. A commercially reasonable loan made in the ordinary course of
                 business;

              7. Any gi with a value less than $100.00;

              8. Promo onal items generally distributed to the general public or to
                 Board members;

              9. A gi to a Board member from that Board member’s immediate
                 family; or

              10. Food, beverage, or expenses provided to Board members, members of
                  their immediate families, or others that are associated with normal
                  and customary business or social func ons or ac vi es.

6. No Board member will use, or knowingly allow to be used, the Board member’s
   official posi on or any informa on not generally available to the public which the
   Board member receives or acquires in the Board member’s capacity as a Board
   member for the purpose of securing financial gain for the Board member, any
   member of the Board member’s immediate family, or any business organiza on with
         which a Board member is associated.

      7. No Board member, any member of a Board member’s immediate family, or any
         business organiza on in which he or she is associated will represent any person or
         party other than the Board or the District in connec on with any ma er pending
         before the Board or in any proceeding involving the Board or the District.

      8. No Board member will be prohibited from reques ng informa on on behalf of a
         resident of the District if no fee, reward, or other thing of value is promised to, given
         to, or accepted by the Board member, any member of a Board member’s immediate
         family, or any business organiza on with which the Board member is associated in
         return therefor.

      9. No Board member will be deemed in conflict with the provisions of this policy if, by
         reason of the Board member’s par cipa on in any ma er required to be voted upon
         by the Board, no material or monetary gain accrues to him or her or any member of
         the Board member’s immediate family as a member of any profession, occupa on, or
         group to any greater extent than could reasonably be expected to accrue to any
         other member of that profession, occupa on, or group.

      10. This Board will not do business with any bank or financial ins tu on where a Board
          member or any member of the Board member’s immediate family is an employee,
          director, or officer, or where such Board member, any member of the Board
          member’s immediate family, or any business organiza on with which the Board
          member is associated, owns 30% or more of the capital stock in that ins tu on.

      11. No Board member, or any member of a Board member’s immediate family or any
          business organiza on with which the Board member is associated, may have a
          financial interest in school buses, bus equipment or supplies, provide services for
          buses owned by the Board, or sell gasoline to the Board for use in school buses
          owned by the Board.

      12. No Board member will accept a monetary fee or honorarium in excess of $101.00 for
          a speaking engagement or for par cipa on in a seminar, discussion panel, or other
          ac vity which directly relates to the Board member’s official du es or office as a
          Board member. Actual and reasonable expenses for food, beverages, travel, lodging,
          and registra on which are provided to enable the Board member’s par cipa on in
          such an ac vity will not be counted toward the monetary fee or honoraria limit.

B. Conduct As Board Member

      1. No Board member will disclose informa on or materials that are subject to the
         Board’s a orney-client privilege to anyone other than other Board members, the
         Board a orney, the Superintendent, or persons specifically designated by the
         Superintendent, unless such privilege has been waived by a majority vote of the
         whole Board. Each Board member acknowledges that individual Board members do
         not have the right or the power to waive the a orney-client privilege belonging to
         the Board.

      2. No Board member will vote on the employment or promo on of any member of the
         Board member’s immediate family. A public, recorded vote must be taken separately
         from all other personnel ma ers before a member of a Board member’s immediate
               family may be employed or promoted.

           3. No Board member may be employed in any posi on in the District.

           4. No Board member will hold another county office.

           5. No Board member will be employed by the State Department of Educa on or serve
              concurrently as a member of the State Board of Educa on.

           6. No Board member will serve on the governing body of a private elementary or
              secondary educa onal ins tu on.

   C. Disclosure of Conflic ng Interest Policy

       Whenever a Board member is required by this policy to refrain from vo ng on a ma er, the
       Board member will fully disclose the reason for not vo ng to the other Board members and
       the public.

   D. Enforcement of Board Member Conflict of Interest Policy

       This policy will be enforced in the manner set out in the Board Member Code of Ethics
       Policy, Descriptor Code BH, Paragraph L.                                                          Commented [MS1]: Committee member preferred to
                                                                                                         reference “Policy” rather than “Descriptor Code”.
   E. Board Eligibility
                                                                                                         Legal Recommendation: Leave as Descriptor code. The
                                                                                                         State Education Rules are listed pursuant to the National
       Each member of this Board understands and acknowledges that no person will be eligible for        School Boards Association (NSBA) codes.
       elec on as a member of this Board unless he or she:

           1. Has read and understands the Board Member Code of Ethics (Policy BH) and the
              provisions of this Board Member Conflict of Interest (Policy BHA), and has agreed to
              abide by them; and

           2. Has agreed to disclose annually compliance with the State Board of Educa on's
              training policy, code of ethics, and conflict of interest provisions for school board
              members.

      Before any person may qualify to run for office as a member of the DeKalb County Board of
      Educa on, they will file an affidavit with elec on officials, affirming that they meet all of the
      qualifica ons required by law, including the provisions stated in this policy. This requirement
      will apply only to Board members elected or appointed on or a er July 1, 2010.

   F. Defini on of Immediate Family

       As used in this policy, the term “member of immediate family” or “immediate family
       member” means a spouse, child, sibling, or parent or the spouse of a child, sibling, or parent.




Policy Reference Disclaimer:
 These references are not intended to be part of the policy itself, nor do they indicate the basis or authority
for the board to enact this policy. Instead, they are provided as addi onal resources for those interested in the
subject ma er of the policy.

Note: To access the policy references, CLICK HERE: State of Georgia Terms and Condi ons and close the
LexisNexis tab, which will return you to the policy. Click on the links below to be taken to each specific
code. You should only have to do this one me per session.




State                                          Descrip on
O.C.G.A. 20-02-0049                            Standards for local board of educa on members

O.C.G.A. 20-02-0051                            Elec on of LBOE members; persons ineligible to be
                                               member or superintendent; ineligibility for LBOE or
                                               other elec ve offices.

O.C.G.A. 20-02-0058.1                          "Immediate family" defined; employment of family
                                               members

O.C.G.A. 20-02-0063                            Prohibit certain conflicts of interest of board members

O.C.G.A. 20-02-0073                            Removal of board members upon poten al loss of
                                               accredita on; turnaround schools; prohibi on on use of
                                               public funds for li ga on expenses

O.C.G.A. 20-02-0505                            School board members prohibited from selling school
                                               supplies or equipment to county board

O.C.G.A. 20-02-0505.1                          Board transac ng business with bank or similar
                                               ins tu on in which member has interest

O.C.G.A. 20-02-1072                            Financial interest in transporta on services by board
                                               members/superintendent prohibited

O.C.G.A. 21-05-0001                            Ethics in Government Act - short tle

O.C.G.A. 21-05-0011                            Acceptance by public officers of monetary fees or
                                               honoraria

O.C.G.A. 21-05-0033                            Disposi on of contribu ons

O.C.G.A. 21-05-0034                            Campaign Disclosure Reports

O.C.G.A. 21-05-0041                            Maximum allowable contribu on by persons or
                                               partnerships
O.C.G.A. 21-05-0050   Filing by public officers; filing by candidates for public
                      office; filing by elected officials and members of the
                      General Assembly; electronic filing

O.C.G.A. 21-05-0070   Public Officials Conduct and Lobbyist Disclosure -
                      Defini ons

O.C.G.A. 45-02-0002   Person to hold only one county office; commissioned
                      officer not to be deputy for another

O.C.G.A. 45-05-0006   Public official inves gated by special commission upon
                      indictment; gubernatorial review if commission
                      recommends suspension; suspension; reinstatement;
                      replacement or temporary officer

Rule 160-4-9-.06      Charter Authorizers, Financing, Management, and
                      Governance Training

Rule 160-5-1-.36      Local School Board Governance