a commercial venture with whom
the school district does business.
“Substantial interest” means any
monetary or proprietary interest,
either direct or indirect. “Relative”
can be defined as the spouse, child,
child’s child, parent, grandparent,
brother, or sister of the whole or
half blood and their spouses and
the parent, brother, sister, or child
of a spouse.
2. If an employee, board member, or
relative participates 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.
Either of the above scenarios should
flag an alert for conflict of interest, and
the educated employee or governing
board member must disclose it as such.
Educating Employees
Implementing best practices and educating
employees can help prevent
fraud based on conflict of interest.
Require employees to fill out a conflict
of interest form when hired and
again annually; however, before any
forms are filled out, be certain
employees understand the terms and
the scope of concern applied to conflict
of interest. Require board
members to fill out a conflict of
interest form when they take office
and renew it annually. Again, be
certain that all persons involved
understand the definition of conflict
of interest. Thoroughly investigate
allegations of inadequate disclosure of
substantial interests and/or inappropriate
participation when substantial
interest may exist. Conduct annual
conflict of interest training for all
district employees and require
acknowledgment that they received
the training.
In Avondale Elementary School District,
we have an online tool that
provides the training for employees to
review annually. It also tracks which
employees have and have not completed
the training and sends
employees reminders about the
requirement to complete the training.
Educating employees to recognize
fraud in its various forms is the first
step in controlling the potential for
fraud within the district.
Protecting Your District
If your district hasn’t done a fraud risk
assessment recently, it may be time to do
so. Some questions to 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?
• Does management review the conflicts
to consider whether they are
still valid?
Risk assessments should be done
regarding personal interest, job
function, and vendor relations.
Here are some additional steps to get
you started:
• Review your state laws to ensure
you understand the rules of and
consequences around conflict of
interest.
• Review your district’s policy and
procedures.
• Evaluate your district’s organizational
risk, personal risk, job duty
risk, and vendor relations risk.
• Train all district employees to recognize
what constitutes a conflict of
interest.
• Educate your vendors on conflict of
interest policies and procedures.
• Establish an alert in your purchasing
system that allows your
district to monitor vendors who
may have a conflict.
• Compare employee addresses with
vendor addresses to ensure they are
not the same.
• Conduct a vendor audit by
reviewing ownership of businesses
through state databases.
It’s critical to educate employees and
colleagues, speak up, and encourage
transparency. Taking these measures
will go a long way in helping you
protect your district against fraud due
to conflicts of interest.
Election Results are In!
Please congratulate the new members of the Board of Directors
Tim Erickson,
President-Elect
Chrissy Hamiel,
Director
Jeff Mahoney,
Director
Sarah Viera,
Director
Want to learn more
about your new
board members?
Visit wasbo.com/
newboard
June 2020 • Taking Care of Business • WASBO.com 21