Policy BBFA 2 BOARD MEMBER CONFLICT OF INTEREST AND FINANCIAL DISCLOSURE

Policy BBFA-2: BOARD MEMBER CONFLICT OF INTEREST AND FINANCIAL DISCLOSURE Status: ADOPTED Original Adopted Date: 04/01/2015 | Last Revised Date: 09/09/2020 | Last Reviewed Date: 11/01/2023 All directors of the School District of Clayton Board of Educa"on shall adhere to the laws regarding conflict of interest and avoid situa"ons where their decisions or ac"ons in their capacity as board members conflict with the mission of the district. Purchases Involving Federal Funds In addi"on to the requirements of this policy, board members must follow the provisions of policy DJFA and related procedures and are also subject to the conflict of interest provisions of federal law. Definitions Business with Which a Board Member Is Associated – For the purposes of this policy: 1. A sole proprietorship owned by the board member, his or her spouse or any dependent children in the board member's custody;

2. A partnership or joint venture in which the board member or his or her spouse is a partner, other than as a limited partner of a limited partnership, and any corpora"on or limited partnership in which the board member is an officer or director or of which the board member or his or her spouse or dependent children in the board member's custody, whether singularly or collec"vely, own more than ten percent of the outstanding shares of any class of stock or partnership units; or

3. Any trust in which the board member is the trustee or se7lor or in which the board member or his or her spouse or dependent children in his or her custody, whether singularly or collec"vely, are beneficiaries or holders of a reversionary interest of ten percent or more of the corpus of the trust. Fourth Degree of Consanguinity or Affinity – Includes parents, grandparents, great-grandparents, great-great- grandparents, spouse, children, siblings, grandchildren, great-grandchildren, great-great-grandchildren, nieces, nephews, grand-nieces, grand-nephews, aunts, uncles, great-aunts, great-uncles, and first cousins by virtue of a blood relationship or marriage. Special Monetary Benefit – Being materially affected in a substan"ally different manner or degree than the manner or degree in which the public in general will be affected or, if the ma7er affects only a special class of persons, then affected in a substantially different manner or degree than the manner or degree in which such class will be affected. Substantial Interest – A substan"al interest exists when the board member or his or her spouse or dependent children in his or her custody, either singularly or collectively, directly or indirectly: 1. Own(s) ten percent or more of any business entity; or

2. Own(s) an interest having a value of $10,000 or more in any business entity; or

3. Receive(s) a salary, gratuity or other compensa"on or remunera"on of $5,000 or more from any individual, partnership, organization or association within any calendar year. Sale, Rental or Lease of Personal Property (Property Other Than Real Estate) No elected or appointed official of the district shall sell, rent or lease any personal property to the school district for considera"on in excess of five hundred dollars' value per transac"on or five thousand dollars' value per year to him or her, to his or her spouse, to a dependent child in his or her custody or to any business with which he or she is associated unless the transac"on is made pursuant to an award on a contract let or sale made aBer public no"ce and competitive bidding, provided that the bid or offer accepted is the lowest received. Sale, Rental or Lease of Real Property (Real Estate) No elected or appointed official of the district shall perform a service or sell, rent or lease any real property to the school district for considera"on in excess of five hundred dollars' value per transac"on or five thousand dollars' value Board Policy Manual Clayton

per year to him or her, to his or her spouse, to a dependent child in his or her custody or to any business with which he or she is associated unless the transac"on is made pursuant to an award on a contract let or sale made aBer public notice. Employment The district shall not employ board members for compensa"on even on a subs"tute or part-"me basis. The district will not accept applica"ons of employment from board members, consider board members for employment or decide to employ board members while they remain on the school board. Board members may provide services on a volunteer basis. Independent Contractor Services No elected or appointed official of the district shall perform service as an independent contractor for considera"on in excess of five hundred dollars' value per transac"on or five thousand dollars' value per year to him or her, to his or her spouse, to a dependent child in his or her custody or to any business with which he or she is associated unless the transac"on is made pursuant to an award on a contract let or sale made aBer public no"ce and compe""ve bidding, provided that the bid or offer accepted is the lowest received. Businesses That Employ Board Members A board member may par"cipate in discussions and vote on mo"ons for the district to do business with en""es that employ the board member as long as the business is not owned by the board member and the board member will not receive any financial benefit from the transac"on. The board member may need to submit a statement of interest as described below. Statement of Interest Before vo"ng, board members who have a substan"al personal or private interest in a decision before the board shall provide a wri7en report of the nature of the interest to the board secretary. The wri7en statement will be recorded in the minutes. Board members who have disclosed the interest in a financial interest statement filed or amended prior to the vote will be in compliance with this requirement. Self-Dealing 1. Board members may not act or refrain from acting by reason of any payment, offer to pay, promise to pay or receipt of anything of actual pecuniary value, whether received or not, to themselves or any third person. This includes a gift or campaign contribution made or received in relationship to or as a condition of the performance of an official act.

2. Board members shall not favorably act on any matter that is specifically designed to provide a special monetary benefit to them, their spouses or dependent children in their custody.

3. Board members will not use their decision-making authority for the purpose of obtaining a financial gain that materially enriches them, their spouses or dependent children in their custody by acting or refraining from acting for the purpose of coercing or extorting anything of actual pecuniary value.

4. Board members shall not offer, promote or advocate for a political appointment in exchange for anything of value to any political subdivision.

5. Board members will not accept gifts with a value in excess of $150 from a vendor who does or is attempting to do business with the district.

6. A board member will not attempt to directly or indirectly influence or vote on a decision when the board member knows the result of the decision may be the acceptance by the district of a service or the sale, rental or lease of property to the district and the board member, his or her spouse, dependent children in his or her custody or any business with which the board member is associated will benefit financially. If such a transaction is presented to the board, the board member will abstain and leave the room during any deliberation. Gifts and Gratuities

Board members and others who are subject to this policy are prohibited from accep"ng giBs or gratui"es in excess of the amount established by the board from any vendor, vendor's representa"ve or person who does or is a7emp"ng to do business with the district. GiBs and gratui"es include, but are not limited to, money, personal property, free meals, "ckets to events, travel expenditures and games of golf. Door prizes and other randomly awarded prizes, such as those awarded from raffles or other fundraising events, are not considered a gift or gratuity. Use of Confidential Information Board members shall not use or disclose confiden"al informa"on obtained in the course of or by reason of their official capaci"es in any manner with intent to result in financial gain for themselves, their spouses, dependent children in their custody, any business with which the board member is associated or any other person. Even when there is no financial gain involved, failure to keep informa"on confiden"al violates board ethics and board policy and could also violate state and federal law. Nepotism Board members shall not vote to employ or appoint any person who is related to them within the fourth degree by consanguinity or affinity. In the event that an individual is recommended for employment or appointment and the individual is related within the fourth degree to a board member, the related board member shall abstain from vo"ng and shall leave the room during considera"on of the ques"on and the vote, unless the mo"on is part of a consent agenda and there is no discussion, in which case, the member need not leave the room but will refrain from voting. For the purposes of this sec"on, to "employ" includes hiring persons to be employees of the district and approving independent contractors who provide services to the district. Financial Interest Statements The School District of Clayton Board of Educa"on hereby adopts a policy establishing and making public its own method of disclosing financial interests of board members, candidates and specified administrators, in accordance with law. Financial interest statements (also known as personal financial disclosure statements) as described below shall be filed with the Missouri Ethics Commission (MEC) and the School District of Clayton Board of Educa"on on or before May 1 for the preceding calendar year, unless the person filing is a board candidate. Candidates must file their reports within 14 days aBer the last day to file for office. The reports will be made available for public inspec"on and copying during normal business hours. This por"on of the policy dealing with the financial interest statement will be adopted in an open mee"ng at least once every other year by September 15. A cer"fied copy of this policy shall be sent to the MEC within ten days of adoption. Board Member Disclosure All school board members and candidates for school board will file the short-form version of the MEC's financial interest statement each year. This form is also known as the "Financial Disclosure Statement for Poli"cal Subdivisions." School board members and candidates will report the following transac"ons if they occurred during the previous calendar year. If no such transac"ons occurred, the board member or candidate will s"ll file, but will mark the items as not applicable. 1. Each transac"on in excess of $500 per year between the district and the individual or any person related within the first degree by consanguinity or affinity to the individual. The statement does not need to include compensa"on received as an employee or payment of any tax, fee or penalty due the district and other transfers for no considera"on to the district. The statement shall include the dates and iden""es of the par"es in the transaction. "First degree of consanguinity or affinity" includes parents, spouse or children by virtue of a blood rela"onship or marriage.

2. Each transac"on in excess of $500 between the district and any business en"ty in which the individual has a substan"al interest. The statement does not need to include any payment of tax, fee or penalty due the district or payment for providing u"lity service to the district and other transfers for no considera"on to the district. The statement shall include the dates and identities of the parties in the transactions.

Superintendent, Chief Purchasing Officer and General Counsel Disclosure The superintendent, chief purchasing officer and general counsel, if employed full-"me, will file the short-form version of the MEC's financial interest statement each year. This form is also known as the "Financial Disclosure Statement for Poli"cal Subdivisions." These employees will report the following transac"ons if they occurred during the previous calendar year. If no such transac"ons occurred, these employees will s"ll file, but will mark the items as not applicable. These employees will disclose in wri"ng the informa"on required in 1) and 2) above. In addi"on, these employees will disclose the following information for themselves, their spouses and dependent children in their custody: 1. The name and address of each employer from whom income of $1,000 or more was received during the year covered by the statement.

2. The name and address of each sole proprietorship the individual owned.

3. The name, address and general nature of business conducted by each general partnership or joint venture in which he or she was a partner or participant.

4. The name and address of each partner or copar"cipant in the partnership or joint venture unless the information is already filed with the secretary of state.

5. The name, address and general nature of business of any closely held corpora"on or limited partnership in which the individual owned ten percent or more of any class of the outstanding stock or limited partners' units.

6. The name of any publicly traded corpora"on or limited partnership that is listed on a regulated stock exchange or automated quota"on system in which the individual owned two percent or more of any class of outstanding stock, limited partnership units or other equity interests.

7. The names and addresses of each corpora"on for which the individual served in the capacity of director, officer or receiver.