Policy 210 - Conflict of Interest & Fiduciary Duty

I.    PURPOSE

The purpose of this policy is to uphold the integrity, impartiality, and public trust in the operations of the District.

II.    GENERAL STATEMENT OF POLICY

It establishes ethical standards for all District personnel and aims to prevent conflicts of interest, ensure transparency, and promote responsible stewardship of public resources.

III.    DEFINITIONS

  1. Conflict of Interest: A situation where personal, financial, or familial interests interfere with the impartial performance of official duties.
     
  2. District Personnel: For this policy District personnel apply to board members, employees, contractors, volunteers, agents, and any individuals under the supervision or control of the District.
     
  3. Close Relative: Includes spouse, parent, child, sibling, in-laws, step-relatives, domestic partners, or anyone residing in the same household.

IV.    GENERAL STANDARDS AND RESPONSIBILITIES

All District personnel shall:

  1. Act in the public interest and avoid any real or perceived conflicts.
     
  2. Not use their position for personal gain.
     
  3. Not disclose or use confidential information for personal benefit.
     
  4. Manage District assets with integrity and prudence.
     
  5. Avoid granting special treatment to any individual or entity.

V.    PROHIBITED CONDUCT

All District personnel shall not:

  1. Engage in transactions where they or close relatives have a financial interest.
     
  2. Accept gifts from individuals or entities with a financial interest in District decisions, except as allowed under Minn. Stat. §471.895.
     
  3. Use their position to influence decisions for personal or familial gain.
     
  4. Recommend specific providers of professional services; only neutral lists may be shared.
     
  5. Participate in political activities during work hours or using District resources.
     
  6. Engage in outside employment that interferes with District duties or uses District facilities.

VI.    NEPOTISM

  1. No employee shall be directly supervised or evaluated by a close relative.
     
  2. No preference shall be shown in hiring or employment decisions.
     
  3. If a familial relationship arises post-employment, the District may reassign one or both parties.
     
  4. Exceptions may be granted by the Superintendent if in the District’s best interest.

VII.    PURCHASING AUTHORITY AND VENDOR RELATIONSHIPS

  1. The Board, through the Executive Director of Finance and Operations or authorized agent, is responsible for the purchasing of all supplies, books, furniture, and equipment used by the District.
     
  2. All District purchases shall comply with Minn. Stat. 123B.20 and other applicable laws and regulations.

VIII.    DISCLOSURE REQUIREMENTS

District personnel must disclose any potential conflict of interest or financial interest in District-related transactions to the Superintendent or designee. Failure to disclose may result in disciplinary action.

IX.    REPORTING AND INVESTIGATION

  1. Suspected violations must be reported to the General Counsel/Executive Director of Human Resources or Superintendent.
     
  2. Reports made in good faith are protected from retaliation.
     
  3. The District will investigate all reports and may take disciplinary action, including termination if there has been a violation of this policy.

X.    DISCLOSURE TO THE MINNESOTA DEPARTMENT OF EDUCATION

  1. District personnel must disclose any conflict involving:
     
    1. Contracts, leases, or purchases from related parties;
       
    2. Financial or personal interests in District transactions;
       
    3. Relationships that may compromise impartiality.
       
  2. Written disclosures must include:
     
    1. Nature of the conflict;
       
    2. Parties involved;
       
    3. Affected transaction or decision;
       
    4. Mitigation steps taken.
       
  3. Disclosures must be submitted to the Superintendent and to MDE via the designated reporting channel (MDE.Inspector.General@state.mn.us).
     
  4. The District shall maintain records of all disclosures.
     
  5. Disclosures must be made prior to any affected transaction. If discovered after the fact, disclosure must occur immediately.
     
  6. Disclosures shall be documented in board minutes or other public records as appropriate.
     
  7. Failure to disclose may result in disciplinary action and/or contract termination. The Commissioner of Education may void contracts entered into without proper disclosure.

XI.    ANNUAL NOTIFICATION

The District shall annually notify all personnel of this policy.

Legal References:
Minn. Stat. 122A.40, Subd. 3 (Teacher hiring, dismissal)
Minn. Stat. 122B.195 (Board member’s right to employment)
Minn. Stat. 123B.20 (Dealing in School Supplies)
Minn. Stat. 471.87 (Public Officers; Interest in Contract; Penalty)
Minn. Stat. 471.895 (Certain Gifts by Interested Persons Prohibited)
Minn. Stat. 123B.20
Minn. Chapter 268B (Family and Medical Benefits)
 
Adopted: October 8, 1987
Revised: January 7, 1999
Adopted: February 4, 2004
Reviewed: November 20,2025
Approved: December 11, 2025