Staff Conflict of Interest

Section G: Personnel

Policy Title: Staff Conflict of Interest
Policy Code: GBEAA

Print Version (In PDF)

Employee Must Notify District of any Conflict of Interest or Potential Conflict of Interest

Any employee who has, or whose relative has, a substantial interest in any decision of the District, including a decision to employ the relative or to engage in business with the relative, 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. To disclose this interest, the employee shall file GBEAA-E (in PDF) with the Governing Board office.

Vendor Relations

No employee of the District will accept a gift or benefit from any person, group, or entity doing, or desiring to do, business with the District as described in Policy DJ, Purchasing Ethics Policy.

Decision-makers must avoid accepting meals/gifts from any potential vendor.

Gifts in association with the procurement process shall be prohibited.

Any perception of improper influence in the procurement process shall be avoided.

District Purchases from Employees

The District must comply with competitive purchasing rules for any acquisition of goods or services from District employees regardless of the dollar amount. The District may acquire equipment, material, supplies, or services from its employees only under an award or contract let after public competitive bidding [A.R.S. 38-503; A.G.O. I06-002].

The requirement 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, when a District employee acts as the vendor.

Oral and written quotations do not satisfy the public competitive bidding requirements.

Purchasing for Personal Use

No employee may purchase goods or services for personal use in the name of Tucson Unified School District.

Forbidden Activities

No employee may sell goods or services for private gain to students or other employees on school premises.

Employees will not engage in any type of work where the source of information concerning customer, client, or employer originates from information obtained through the School District, except when permitted by state or federal law and the Governing Board.

Employees will not participate for financial remuneration in outside activities wherein their position on the staff is used to sell goods or services to students or their parents/guardians, except when permitted by the Governing Board.

District Exempt from Paying Employee Royalties

Employees who have patented or copyrighted any device, publication or other item will not receive royalties for use of such item in the District Schools.


No employee may use his/her position with the District to solicit, directly or indirectly, the purchase of supplies, services or equipment at special discounts for private use from any school district vendor.

It is understood that the Superintendent, or designee, may solicit or accept discounts for groups of employees.

Solicitation during working hours of employees either for contributions or membership drives must be approved by the Superintendent before made in the schools.

Employee Training and Acknowledgement of Understanding

The Governing Board may require annual employee training to ensure District conflict of interest policies are communicated to employees and acknowledged as received and understood. Each employee shall complete and sign the conflict of interest form, GBEAA-E (in PDF), as determined by the District.

The District will investigate allegations of inadequate disclosure of substantial interests and/or inappropriate participation when a substantial interest may exist.

Employment of Relatives

No person employed by the District may be supervised by or in the direct line of supervision of a relative or domestic partner including:

  • Father
  • Mother
  • Son
  • Daughter
  • Sister
  • Brother
  • Step children
  • Spouse or Domestic Partner
  • Father-in-law
  • Mother-in-law
  • Son-in-law
  • Daughter-in-law
  • Sister-in-law
  • Brother-in-law
  • Step parents
  • Former spouse

This policy will apply for summer, independent contracts, temporary, hourly or part-time work as well as for full-time employment.

A dependent of a Board member (a person more than half of whose support is obtained from a Board member) cannot be hired in the District except by consent of the Board.

The spouse of a Board member cannot be employed by the District.

Adopted: October 5, 2004
Revised: July 24, 2007
Revised: December 11, 2012
Revised: April 23, 2019

Legal Ref: A.R.S. 15-323 - Purchases from Governing Board Members
15-421 - Governing Board; Members; Qualifications
15-502 - Employment of School District Personnel
38-481 - Employment of Relatives; Violation; Classification
38-501 et seq. - Conflict of Interest of Officers and Employees
38-502 - Definitions

Attorney General Arizona Agency Handbook, Appendix 8.1, Conflict of Interest Disclosure Memorandum

Cross Ref:
BCB - Board Member Conflict of Interest Policy
BCB-E – Board Member Conflict of Interest Exhibit
DJ – Purchasing Ethics Policy
DJE—Purchasing Procedures Policy
DJE-R – Purchasing Procedures Regulation
GBP – Prohibited Personnel Practices Policy