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  • Section D: Fiscal Management


Conflict of Interest

A conflict of interest would arise when the employee, Director or agent—or any member of their immediate family, their (business) partner, or an organization that employs or is about to employ any of these parties—has a financial or other interest in or a tangible personal benefit from a firm selected for the award considered for a contract.  For the purpose of this policy, “immediate family” is defined as spouse, brother, sister, parent, son or daughter.  

All employees of RSU 21 shall perform their duties in a manner free from conflict of interest to ensure that the school unit’s business transactions are made in compliance with applicable laws and regulations and in a manner that maintains public confidence in the schools.

No employee, Director or agent of RSU 21 shall participate in the selection, award or administration of a contract supported by federal funds or in any other transaction in which RSU 21 is a party if they have a real or apparent conflict of interest in the transaction. 

Conflict of Interest Disclosure

All employees, officers or agents with real or apparent conflicts of interest as defined above must disclose the conflict of interest to the Superintendent who will investigate the circumstances of the proposed transaction.  The Superintendent will exercise due diligence in investigating the circumstances of the transaction and, if necessary, will make reasonable efforts to find alternatives to the proposed transaction or arrangement that would not give rise to a conflict of interest.  If the Superintendent determines that the proposed transaction is in the best interest of RSU 21 and is fair and reasonable (and any apparent conflict of interest can be managed appropriately), they may proceed with the transaction.  In the event that the Superintendent may have a conflict of interest, an ad hoc subcommittee of the Board will investigate and make a determination regarding the transaction.

Staff Gifts and Solicitations

RSU 21 employees, Director and agents are prohibited from soliciting or accepting gratuities, favors, money or anything of material monetary value from persons or entities doing business with, or desiring to do business with, the school unit RSU.  Employees, officers and agents of the RSU may accept unsolicited items of nominal value such as those that are generally distributed by a company or organization through its public relations program.


Employees of RSU 21 who violate this code of conduct may be subject to discipline, up to and including termination of employment and, if appropriate, referral to law enforcement. 

Legal Reference: 34 CFR Parts 74 and 80 (Education Department General Administrative Regulations (“EDGAR”)) (for federal awards made prior to 12/26/2014)

2 CFR § 200.318 (Uniform Administrative Requirements—General Procurement Standards) (for federal awards made on or after 12/26/2014) 

Cross Reference: BCB - Board Member Conflict of Interest

DJ - Bidding/Purchasing Requirements (this policy is recommended for removal)

DJ-R - Federal Procurement Manual

KCD - Revenue Enhancements/Gifts to Schools   

Adopted: 06/19/2017

Reviewed: 02/08/2021

Revised: 1/9/2023

  • Section D