REVISED 1/2009 

Conflict of Interest Protocol

Policy for all School Employees
All school employees must avoid situations involving actual or potential conflict of interest. IEM Schools consider certain activities and situations to be a conflict of interest and therefore will not allocate school funding towards these nor allow these potential conflict of interest situations to occur. A brief description of each is listed below.  This is not an exhaustive list of all possible situations which would constitute conflicts of interest. The school administration reserves the right to add to or amend this list as it deems appropriate. Any relationship or action which creates an expectation of benefit or profit beyond an employee’s normal employment relationship with the School can impair an employee's ability to exercise good judgment on behalf of the School, and therefore creates an actual or potential conflict of interest. It is the School’s policy that all School employees must scrupulously avoid all such situations. We expect that the ESs authorizing expenditures from the school Instructional Funds will be responsible to see that none of these activities under their control are allowed.

Examples of conflict of interest could be (but are not limited to):

1. An ES may not solicit students for their “class list who are already enrolled with another ES. (This in no way limits a parent’s choice to request a new ES, or ESs to work together on transfers for the good of the students).
2. An ES who serves as ES for their own children or other children who reside in their household may not complete an AESS contract for them.
3. An ES or anyone in their immediate family may not become a “business vendor” for the school or otherwise receive payment for product sold to the school. An exception to this would be when the school bid process is used to secure the vendor. If selected, the employee must sign a Conflict of Interest Disclosure statement and submit it to the school Parent Council.
4. An ES may not order product for a student from a “business vendor” who is a relative of that student.
5. An ES who is also a school CP instructor may not be paid from the Instructional Funding account they control for their own children or other children who reside in their household.
6. A Classified CP Instructor (who is not also working in the capacity of a school ES) with relatives enrolled in their CP classes must have an equal number of enrolled school students as the number of relatives in order for the class to be approved and for the instructor to be paid for serving the relatives.
7. A “Service PO may not be created for a student to attend a course offered by a relative of the enrolled student.
8. An ES may not require any of the students on their “class list” to become AESS students, to enroll in the CP courses they instruct, or to participate in the service activities for which an ES receives payment. If an ES feels that a student would benefit from one of the above activities, and the parent disagrees, the ES can only require it of them if approved in writing by the ES's Advisor. (This does not limit a parent’s ability to choose to participate in any of these situations).
9. An ES may neither be nor be employed by nor have any financial or family interest in an approved “business vendor” at any time the ES is employed by an IEM school. However, an ES may teach courses or offer tutoring as a school employee through contract programs in addition to serving as an ES.
   

Policy for the Parent Council
The School Parent Council places great importance on making clear any existing or potential conflicts of interest.  All such conflicts of interest shall be declared by the member to the School Parent Council for consideration.  A School Parent Council member who believes another School Parent Council member has an undeclared conflict of interest should specify in writing the basis of this potential conflict.

Parent Council Procedures
1.     Members shall declare any conflicts of interest either at the start of the School Parent Council meeting concerned or when a relevant issue arises.  The nature of this conflict of interest should be entered into the meeting minutes.
2.    Where a conflict of interest or potential conflict of interest is identified and/or registered, the School Parent Council member concerned shall leave the room as soon as that item comes up for discussion. The concerned School Parent Council member shall not vote on that issue, nor initiate or take part in any School Parent Council discussion on that topic (either in the meeting or with other School Parent Council members before or after the School Parent Council meetings), unless expressly invited to do so by unanimous agreement by all other members present.
3.    If a person declares themselves to have existing or potential conflict of interest confidentiality will be respected. If a person alleges that another person has a conflict of interest, whether existing or potential, and if the School Parent Council cannot resolve this allegation to the satisfaction of both parties they will consult with Innovative Education Management as a mediator and legal advisor.

Examples of Parent Council conflict of interest could be (but are not limited to):

1. No ES, school employee, or any school employee's spouse or dependent may serve as a School Parent Council member.

2.    When a School Parent Council member or his/her immediate family or business interests stands to gain financially from any business dealings, programs or services of the organization.
3.    When a School Parent Council member him or herself offers a professional service to the organization.
4.    When a School Parent Council member stands to gain personally or professionally from any insider knowledge if that knowledge is used to personal advantage.
5.    Where a School Parent Council member or the ex/officio member of the School Parent Council has a role on the governing body of another organization and the activities of that other body may be in direct conflict or competition with the activities of SSCS.