F24. Prevention of Conflict of Interest in Procurement

  •  Policy Code: F24

    First Reading:   May 15, 2018
    Second Reading:   June 5, 2018  
    Adopted:   June 5, 2018



    It is the policy of the Essex Westford School Board that all purchasing and contracting comply with state and federal laws. 

    No employee, officer, or agent of the Essex Westford School District may participate in the selection, award, or administration of a purchase or contract if that person has a real or apparent conflict of interest. Any employee, officer or agent with a real, perceived or apparent conflict of interest shall notify the superintendent of the conflict and not participate in the selection, award or administration of the purchase or contract at issue. The superintendent or his or her designee will develop written procedures to implement this policy.

    A conflict of interest arises if an employee, officer, agent, immediate family member, partner, or an organization which employs or is about to employ any of the parties indicated herein, has a direct or indirect financial or other interest in, or a tangible personal benefit from a vendor considered for a purchase or contract.

    An employee will not solicit or accept any favor, gratuity, or anything of monetary value from such vendors which exceeds a $100 value.

    In the event of a violation of this policy, the district or supervisory union may take disciplinary action against the employee, officer or agent according to district procedures and/or the collective bargaining agreement.

    Legal Reference(s):

    2 CFR 200.318 NOTE: This policy satisfies the federal regulatory requirement in 2 CFR 200.318. Alternatively, the district may fulfill this legal requirement by developing “written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts.”