GBEAA-E

EXHIBIT

STAFF CONFLICT OF INTEREST

CONFLICT OF INTEREST DISCLOSURE FORM

Districts are required to follow the School District Procurement Rules for all purchases of goods or services from district employees regardless of dollar amount. Arizona Revised Statutes § 38-503(C) prohibits public employees from providing their employers with any equipment, material, supplies, or services unless provided under an award or contract let after public competitive bidding. Accordingly, Arizona Attorney General Opinion I06-002 states that districts must follow the School District Procurement Rules, regardless of the expenditure amount, when purchasing goods or services from district employees. This applies to any purchase using district monies, including extracurricular activities fees, tax credit contributions, and monies held in trust by the District, such as student activities monies. Although the School District Procurement Rules exempt expenditures of student activities monies from the Rules, that exemption does not apply to purchases in which a District employee acts as a vendor. Following the guidelines for written quotes is not sufficient to comply with the requirements of A.R.S. § 38-503(C).

Similarly, districts are required to follow the School District Procurement Rules for all purchases of services from district board members regardless of dollar amount. A.R.S. § 38-503(C) prohibits governing board members from providing their district with any services, unless provided under an award or contract let after public competitive bidding, with exceptions. Arizona Attorney General Opinions I87-035 and I06-002, and A.R.S. §§ 15-213, 15-323, and 38-503.

A.R.S. § 38-503(A) requires that governing board members, officers, and employees make known any substantial interest they have in any contract, sale, purchase, or service, and refrain from voting upon or otherwise participating in any manner as an officer or employee in such contract, sale, or purchase. Any employee who has, or whose relative has, a substantial interest in any decision of the District shall make known this interest in the official records of the District, and shall refrain from participating in any manner as an employee in such a decision.

"Refrain from participating in any manner" means more than just refraining from making a final decision. It means participating in any way in the process leading up to a decision. An officer/employee with a conflict of interest must not make recommendations, give advice, or otherwise communicate in any manner with anyone involved in the decision-making process.

By signing this document, I hereby indicate:

1. That I am presently an officer/employee of the Tempe Union High School District No. 213;

2. That I shall refrain from participating in any manner in my capacity as an employee or officer of the Tempe Union High School District in such contract, sale, purchase, service to, or decision by the Governing Board in which I may have a substantial interest; and

EITHER (check one)

3. _____ That neither I, nor any relative of mine, have a substantial interest in any contract, sale, purchase, or service to or decision by the Tempe Union High School District No. 213 Governing Board. If a conflict of interest arises, it is my responsibility as an officer/employee of the Tempe Union High School District to complete a Conflict of Interest Disclosure Form with the Business Services Department immediately.

4. _____ That I (or my relative[s]: ( _______________________________) have a substantial interest in the contract, sale, purchase or service to or decision by the Tempe Union High District No. 213 Governing Board as described below.

Please identify the substantial interest (use additional pages as necessary):

______________________________________________________________

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Officer/Employee Name

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Signature

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School or Department

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Date

Revised September 6, 2019