HomeMy WebLinkAboutP 024 HR - Employee Conflict of Interest
POLICY P 024 HR
TITLE: EMPLOYEE CONFLICT OF INTEREST
Date Authorized: 15 May 1998
Last Revised: 20 May 2025 (Tier 1 Minor Housekeeping Edits)
Last Reviewed: 25 April 2024
COMMITMENT TO INDIGENOUS RIGHTS, HUMAN RIGHTS, AND EQUITY
The Board recognizes its responsibility to ensure that this policy and associated procedures promote
and protect Indigenous rights, human rights, and equity. The Board will strive to address and
eliminate racism and structural and systemic barriers for students, staff, and the community.
1.0 RATIONALE
To define guidelines and restrictions for employees with respect to conflicts of interest.
2.0 DEFINITIONS
Please refer to Appendix A for a list of definitions of terms used in this policy.
3.0 GUIDING PRINCIPLES
3.1 Employees of the OCDSB occupy positions of great public trust. They are expected to
conduct themselves and to perform their duties and responsibilities professionally,
ethically, honestly, efficiently, transparently, and impartially.
3.2 It is imperative that employees act and are seen to be acting in the best interests of the
organization and the public they serve, and do not compromise themselves or the
reputation of the OCDSB in the performance of their duties.
4.0 SPECIFIC DIRECTIVES
4.1 Employees are responsible for identifying and avoiding placing themselves in situations
where their Personal Interests, including financial interests, are actually or may be
perceived to be in conflict with the District’s interests or may adversely affect their ability
to carry out their professional duties on behalf of the District.
4.2 Without restricting the generality of this policy or any associated procedures, Conflicts of
Interest may include the following:
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a) participating in or influencing the outcome of the appointment, hiring, promotion,
supervision, or evaluation of a person or contractor with whom the employee has,
or has had, a Relationship, or directing or assigning the work of that person or
contractor;
b) providing direct services (e.g., teaching) to or evaluating a student with whom the
employee has a Relationship;
c) offering/promoting products for sale to the District, the Board, District employees,
students, and/or parents/guardians of students attending District schools;
d) using the District’s equipment, work time, resources, materials or facilities in any
form in the pursuit of outside employment, remuneration, or other personal gain;
e) offering private services to students for remuneration, where the business
relationship arises through their employment with the District;
f) acceptance of a gift from any person, group or entity if a reasonable person
might conclude that the gift could influence the employee in the performance of
their duties.
Disclosure of Conflict of Interest
4.3 Employees have an obligation to disclose when they are in an apparent, potential, or
actual Conflict of Interest as soon as becoming aware of its existence.
4.4 The District shall facilitate and administer a process for employees to disclose an
apparent, potential, or actual Conflict of Interest and for managing such disclosures.
4.5 The existence of apparent, potential, or actual Conflict of Interest does not necessarily
preclude involvement in the activity giving rise to the conflict. Such determination shall
be made by the Director of Education, or designate, in accordance with the established
process. The employee may be required to refrain from any involvement in the activity
until such time as a decision has been made.
Confidentiality
4.6 All personal information obtained under this policy shall be treated with confidentiality in
compliance with the Municipal Freedom of Information and Protection of Privacy Act
(MFIPPA).
No Reprisals
4.7 Reprisals against anyone disclosing another employee’s Conflict of Interest, including
an apparent, potential or actual conflict, as well as threats of reprisal, are prohibited.
Infractions
4.8 An employee who has acted in contravention of this policy may be subject to
appropriate disciplinary action, up to and including termination of employment, to be
imposed at the discretion of the Director or designate.
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4.9 The Director of Education is authorized to issue such procedures and guidelines to
facilitate the implementation of this policy.
5.0 APPENDICES
Appendix A: Policy Definitions
6.0 REFERENCE DOCUMENTS
The Municipal Freedom of Information and Protection of Privacy Act (MFIPPA)
The Education Act, 1998, § 217
Human Rights Code
Policy of the Ontario Teachers' Federation, Section III, Professional Ethics
OCDSB Policy P 052 SCO - Fundraising in Schools
OCDSB Policy P 069 FIN - Tendering, Purchasing and Acquisition of Supplies and Services
OCDSB Policy P 095 PLG - Decommissioning and Disposal of Surplus Board Property
OCDSB Policy P 146 HR - Equitable Recruitment, Hiring, and Promotion
OCDSB Procedure PR 502 FIN - Spending Authorization and Controls
OCDSB Procedure PR 558 FIN - Tendering, Purchasing and Acquisition of Supplies and
Services
OCDSB Procedure PR 625 HR - Corporate Code of Conduct for Business Relationships
OCDSB Procedure PR 700 HR - Equitable Recruitment and Hiring Procedure
OCDSB Procedure PR 710 HR - Employee Conflict of Interest
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APPENDIX A: POLICY DEFINITIONS
In this policy,
Board means the Board of Trustees.
Conflict of Interest means a potential, apparent or actual conflict where an Employee’s financial or
personal interest, whether direct or indirect, conflicts or appears to conflict with their responsibility to
the District. It includes situations in which financial or other personal considerations have the potential
to compromise or bias an employee’s professional judgment and objectivity. An apparent conflict of
interest is one in which a reasonable person would think that the employee’s judgment is likely to be
compromised.
District means the Ottawa-Carleton District School Board.
Employee means all persons who are currently engaged in active employment with the District,
regardless of employment status (e.g. full-time, part-time, regular, term, contract, occasional, casual),
but does not include Trustees.
Personal Interest means any financial or non-financial interest that an individual involved in
decision-making processes may have, which could potentially influence their judgment or actions to
the detriment of the organization’s best interests. Personal interests may include, but are not limited
to, financial gain, familial relationships, or other connections that might compromise objectivity.
Relationship means any relationship of the employee to persons of their immediate family whether
related by blood, adoption, marriage, or common-law relationship, any relationship of an intimate
and/or financial nature during the preceding five years, any student-supervisor relationship, or any
other past or present relationship that may give rise to a reasonable apprehension of bias.
Reasonable Apprehension of Bias is the legal standard for conflicts of interest which is raised when
a person who is informed of all the facts would reasonably conclude that there is an appearance of
bias on the part of the employee.
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