M E M O R A N D U M. United Way Ethics Taskforce

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1 M E M O R A N D U M TO: FROM: United Way Ethics Taskforce Pepper Hamilton LLP DATE: October 23, 2012 RE: Overview of Existing Ethics Laws/Policies Applicable to School District Constituents This memo endeavors to summarize the existing legal landscape with respect to ethics-related statutes, regulations, and codes applicable to the various constituents of the Philadelphia School District. As a threshold matter, we note that in attempting to provide such a summary, we necessarily have made certain assumptions as to the definition of ethics and the identity of the District s constituents to whom the ethical obligations attach. If these assumptions were to be narrowed or broadened by the Taskforce, the overview of the applicable legal landscape would need to be changed accordingly. In addition, we recognize that all individuals and groups who have any contact or involvement with the District have an independent duty to abide by a wide variety of laws. We do not attempt here to identify every legal obligation of every District constituent; rather, we focus on the ethical obligations of District employees, governing board members and other individuals who function in some formal representative or decision-making capacity for the District. Section I identifies existing ethics laws, statutes, codes of conduct and other relevant resources. Section II outlines the categories of ethical issues that these ethics resources address. I. SOURCES CONSULTED A. Statutes/Laws Pennsylvania Public Official and Employee Ethics Act (65 Pa.C.S. 1101) State Adverse Interest Act (71 P.S et seq.) Pennsylvania Lobbying Disclosure Act (65 Pa.C.S. 13A01) Pennsylvania Open Meeting Law (Sunshine Act) (65 Pa.C.S. 701 et. seq.) Pennsylvania Right-to-Know Law (65 P.S ) Public School Code of 1949 (24 P.S , et seq.) (select provisions)

2 Professional Educator Discipline Act (24 P.S a et seq.) and its Definitions of Statutory Terms (22 Pa. Code 237.1) Pennsylvania Commonwealth Procurement Code (62 Pa.C.S. 101, et seq.) (specifically, 62 Pa.C.S. 521(e) and 512 (g)). 1 Public Employee Relations Act of 1970 (Act 195) (43 P.S. 1801) (conflict of interest provision) Pennsylvania Whistleblower Law (43 P.S et seq.) Philadelphia Ethics Law ( Standards of Conduct and Ethics ) (Philadelphia Code Chapter ) Philadelphia Campaign Finance Law (Philadelphia Code Chapter ) Philadelphia Lobbying Law (Philadelphia Code Chapter ) B. Codes of Conduct Governor s Code of Conduct (Executive Order No ) (May 16, 1984) Code of Professional Practice and Conduct for Educators (22 Pa. Code ) (issued by the Professional Standards and Practices Commission) School Reform Commission Governance Standards/Code of Conduct/Ethics (Oct. 5, 2011) School District of Philadelphia Employee Code of Ethics School District of Philadelphia Employee Handbook (December 2009) (Section 1.3, incorporating Employee Code of Ethics) School District of Philadelphia, Office of Procurement Services, Policies & Procedures Manual (May 2008) ( PSD Procurement Manual ) 2 1 We consulted the Pennsylvania Commonwealth Procurement Code for content, but the Office of General Counsel for the School District of Philadelphia advised that the District has taken the position that the Commonwealth Procurement Code does not apply to the District. This position was accepted by the Commonwealth Court. See U.S. Foodservice Inc. v. School District of Philadelphia, Case No. 664 M.D (Aug. 18, 2010), a copy of which is attached to this memo as Exhibit 1. 2 The Procurement Manual was provided by John Venti, Interim Director of Procurement Services for the School District of Philadelphia, and is currently under revision. In setting forth the relevant procedures and policies, the Manual cites Pennsylvania law, the Public School Code, and policies of both the School District of Philadelphia and the School Reform Commission. Notably, there are some differences between the base amounts cited in the Manual compared to the base amounts that appear in the underlying statutory provisions. These discrepancies may -2-

3 C. Memoranda of Understanding Educational Accountability Memorandum of Understanding between Philadelphia School District, the City of Philadelphia, and the Pennsylvania Department of Education (June 9, 2011) (effective through June 30, 2016) Memorandum of Understanding Concerning Governance Structure and Fiscal Working Group for the School District of Philadelphia and the School Reform Commission (October 4, 2011) (effective through June 30, 2012) II. MAJOR TOPICS/THEMES COVERED A. General Compliance with Laws/Regulations Professional educators must abide by the Public School Code of 1949 (24 P.S et seq.), other school laws of the Commonwealth, and the Public Employee Relations Act (43 P.S (a)(1), (2) and (4) and (b)(1), (2) and (4); see also 43 P.S regarding conflicts of interest). [22 Pa. Code 235.4(b)] Professional educators may not engage in conduct prohibited by the Teacher Certification Law (24 P.S ), the Public School Code of 1949, and the Public Official and Employee Ethics Law. 3 [22 Pa. Code 235.6] School District employees shall uphold all federal and state laws, the laws of other applicable government entities, and the policies, procedures, rules and regulations of the School District (including collective bargaining agreements). [PSD Code of Ethics at 9] Members of the SRC must comply with SRC policy and all applicable local, state and federal laws and regulations. [SRC Code of Conduct, 1(b)(5)] Members must also comply with the School District of Philadelphia Employee Code of Ethics. [SRC Code of Conduct, 2(b)(6)] The SRC, PSD, City of Philadelphia, and Pennsylvania Department of Education shall adhere to all applicable laws, including the Family Educational Rights and Privacy Act (20 U.S.C. 1232g), and the Health Insurance Portability and Accountability Act (Public Law ). The parties shall cooperate and coordinate in a reasonable manner with respect to their respective duties under the Right-to-Know Law. [June 2011 MOU, 10; be due to the fact that certain base amounts are subject to adjustment for changes in the Consumer Price Index, pursuant to 24 P.S Another potential reason is that, under 24 P.S , the SRC has the power to suspend the bidding requirements and provisions of 24 P.S But note that the Public Official and Employee Ethics Law specifically excludes teachers from its definition of public employee. See 65 Pa.C.S (stating that the term public employee shall not include individuals who are employed by this Commonwealth or any political subdivision thereof in teaching ). -3-

4 October 2011 MOU, 11] The parties shall also abide by all applicable federal, State and City laws and PSD policies prohibiting discrimination. [June 2011 MOU, 15; October 2011 MOU, 14] B. Avoiding Conflicts of Interest 1. Financial Disclosure/Statement of Financial Interest All State public officials must file an annual Statement of Financial Interest (in the form set forth in 65 Pa.C.S. 1105) with the Ethics Commission; all State public officials and public employees must file the statement with their department, agency, body or bureau; and any other public officials or employees must file the statement with the governing authority or political subdivision by which s/he is employed. [65 Pa.C.S. 1104(a)] (See 1104(b)-(c) for financial interest disclosures for candidates and nominees). The following officials and employees of the Commonwealth shall file a Statement of Financial Interest with the personnel office of their respective office or department: Governor; Lieutenant Governor; heads of agencies and departments, their respective deputy secretaries, all Commonwealth officials or employees at the level of division chief and above, and all attorneys, press secretaries, legislative liaisons, and executive and special assistants; chairpersons, executive directors, counsel, administrative secretaries, and members of compensated boards and commissions under the Governor s jurisdiction; and employees of all classes required to file under the State Ethics Act. [Gov. Code of Conduct Part II, 1] The required disclosures include real estate property interests, personal economic interests, business interests, gifts, employment (other than with the Commonwealth), and liabilities. [Gov. Code of Conduct Part II, 4] Certain City officers (enumerated in Philadelphia Code ) and all members of boards and commissions, whether compensated or not, shall file a Statement of Financial Interest for the preceding calendar year with the City Board of Ethics by May 1 of each year that s/he holds office, and of the year after s/he leaves office. [City Ethics Law, ] School District employees cannot engage or hold any interest, (financial or otherwise) in any business, transaction or professional entity that conflicts with the discharge of official duties, or reflects poorly on the district employee. [PSD Code of Ethics at 4] Further, all members of the SRC (or School Board), and employees at the level of Director and above, must file an annual Statement of Financial Interest with the Office of Human Resources. The Executive Director of Human Resources may also require any employee whose duties -4-

5 require discretion or judgment to file such a statement. [PSD Code of Ethics at 5] 2. Improper Influence Public officials/employees, or nominees or candidates for public office, cannot accept anything of monetary value, including gifts, loans, political contributions, rewards or promises of future employment, honoraria, or accept severance or contingent payments, upon assuming public office or employment (see exceptions). [65 Pa.C.S. 1103(b)-(e)] Public officials and employees are strictly prohibited from accepting an honorarium as that term is defined by the Ethics Act, 65 Pa.C.S. Sections 1102, 1103(d), and may not arrange for a charity to receive such an honorarium. See Richardson, State Ethics Commission Opinion (June 28, 1993); Crompton, State Ethics Commission Opinion (April 30, 2009). The Ethics Act controls in the event of a conflict with any other statute, ordinance, regulation or rule. [65 Pa.C.S ] No board of school directors can demand, request or accept, directly or indirectly, any gift or donation from any teacher or supervisor within its employ. [Public School Code, 24 P.S ] Public officials/employees cannot, in their official capacity, vote on a matter that would result in a conflict of interest. If a conflict exists, the official/employee must publicly announce and disclose the nature of his/her interest as a public record in a written memo filed with the person responsible for recording the minutes of the vote meeting. [65 Pa.C.S. 1103(j)] No State employee defined as an appointed officer or employee of a State agency 4 can (1) have an adverse interest in any contract with the State agency by which s/he is employed [71 P.S ]; (2) influence, or attempt to influence, the making of, or supervise or in any manner deal with, any contract in which s/he has an adverse interest [71 P.S ]; (3) become an employee of a State agency if 4 A state agency is a department, board, commission or other part of the executive branch of the Commonwealth that is created by a statute and performs or has for its purpose the performance of an essential government function. 71 P.S (8). At least one court has held that the School Reform Commission is not a state agency under the State Adverse Interest Act. See Comm. to Keep Our Pub. Schs. Pub. v. Schweiker, 803 A.2d 869, 874 (Pa. Commw. Ct. 2002) ( Because the School Reform Commission functions as a local school board, is funded by the local school district and is composed of primarily local residents who have the ability under the Act to control the actions taken by the Commission, we would conclude that the School Reform Commission is not a State agency under the Act.... ). -5-

6 s/he has an adverse interest in a contract with that agency, until the adverse interest has been wholly divested [71 P.S ]; or represent for remuneration any other person upon any matter pending before or involving any State agency, except in the performance of his/her duties as an employee [71 P.S ]. An adverse interest is defined as being a party to a contract as other than the Commonwealth or a State agency, or being a stockholder, partner, member, agent, representative or employee of such party. [71 P.S (4)] No State advisor or State consultant can have an adverse interest in a contract that s/he recommends to a State agency that s/he serves. [71 P.S ] A state advisor includes any person who performs professional or advisory service for a State agency, or serves as a member of an advisory board or similar entity, and who receives no compensation other than reimbursement of expenses. [71 P.S (7)] A state consultant includes an independent contractor who performs professional or advisory service for a State agency and who receives a fee, honorarium or similar compensation. [71 P.S (9)] No City officer or employee, or City Council member, shall assist another person by representing him/her directly or indirectly as his/her agent or attorney, whether or not for compensation, in any transaction involving the City (see exceptions). [City Ethics Law, ] No City officer or employee, or City Council member, shall solicit, accept or receive any gift, loan, gratuity, favor or service of substantial economic value that might reasonably be expected to influence one in his/her position in the discharge of his/her official duties, from any person, firm, corporation or other business or professional organization. The same prohibitions apply to any entity that makes such gifts, loans, etc. to City officers or employees, or Council members. [City Ethics Law, ] Any City officer or employee, or City Council member, who has a financial interest in any legislation (including ordinances and resolutions), award, lease, case, claim, decree or judgment, shall make public the nature and extent of such interest. Such person shall disqualify him/herself from any further official action regarding such legislation, award, lease, case, claim, decree or judgment. [City Ethics Law, ] No City officer or employee, or City Council member, shall directly or indirectly disclose or make available confidential information concerning the property, government or affairs of the City without proper legal authorization, for the purpose of advancing the financial interest of him/herself or others. [City Ethics Law, ] -6-

7 A professional educator may not accept gratuities, gifts or favors that might impair or appear to impair professional judgment; or exploit a professional relationship for personal gain or advantage. [22 Pa. Code 235.9] SRC members may not seek or hold position as any other public official in the Commonwealth, or as an officer of a political party, while serving in the SRC. [Public School Code, 24 P.S (6)] While elected or appointed, a school director cannot be employed in any capacity by the school district in which s/he is appointed, or receive any pay for services rendered to the district. (Exceptions apply for positions of attorney, solicitor or secretary for the board). After resigning, one who has served as a school director may be elected to the position of teacher by the board of which s/he was a member by vote, and is entitled to receive pay for services as a teacher. [Public School Code, 24 P.S (a)] It is unlawful for anyone to offer bribes to any school director, including: giving any sum of money or other valuable thing, or making any promise of any office or appointment of any kind, to influence or secure the voting for, or the appointment of, him/herself, or any other person, as a teacher, executive director or assistant executive director of an intermediate unit, district superintendent, assistant superintendent, tax collector, attendance officer, or to any other position connected with the public schools of this Commonwealth, or for the purpose of having his/her salary increased while holding any appointment under the provisions of this act. [Public School Code, 24 P.S ]. Any school director who accepts a bribe will also be penalized. [Public School Code, 24 P.S ] No employee, appointee or official in the Executive Branch of the Commonwealth shall engage in any business transactions or private arrangements for profit that are based upon his/her official position or authority. This includes representing or acting as an agent for any private interest (whether or not for compensation) in any transaction in which the State has a direct and substantial interest; participating in the negotiation of or decision to award contracts, settle claims or charges in any contracts, make loans, grant subsidies, fix rates, or issue permits, certificates, guarantees or other things of value, with or for any entity in which s/he has a financial or personal interest; and holding any pecuniary interest (including shares or securities) in certain regulated gaming entities. [Gov. Code of Conduct Part I, 1-2] -7-

8 No employee, appointee or official in the Executive Branch of the Commonwealth shall solicit or accept gifts, gratuities, favors, entertainment, loans, or any other thing of monetary value from a person who has potential or existing financial relations with the Commonwealth, conducts activities regulated by the Commonwealth, is engaged in court proceedings before or against the Commonwealth, or has interests that would be substantially affected by the employee s official duty. [Gov. Code of Conduct Part I, 3; see same section for exceptions] No employee, appointee or official in the Executive Branch of the Commonwealth shall use or disclose confidential information obtained as a result of service or employment with the Commonwealth for his or her own personal gain or for the gain of others. [Gov. Code of Conduct Part I, 4] No employee, appointee or official in the Executive Branch of the Commonwealth shall use Commonwealth equipment, supplies or properties for his/her own private gain, or for other than officiallydesignated purposes. [Gov. Code of Conduct Part I, 5] No employee, appointee or official in the Executive Branch of the Commonwealth shall accept private employment or render services for a private interest, unless such activities are approved in advance by the Head of the Agency to which the affected person is assigned. Even then, supplementary employment must not conflict with his/her official duties. Those appointed to serve part-time on boards and commissions can pursue their usual occupations, but cannot perform services or receive compensation from persons or institutions that they regulate. [Gov. Code of Conduct Part I, 6] No employee, appointee or official in the Executive Branch of the Commonwealth shall accept honoraria or speaking fees, or compensation for consultation that draws upon ideas or data derived from his/her official duties. Such persons can, however, arrange for honoraria to be paid to designated non-profit, charitable organizations. Individuals appointed to Boards and Commissions may accept honoraria, except from groups that are regulated by the Board or Commission on which they serve. [Gov. Code of Conduct Part I, 7] No employee, appointee or official in the Executive Branch of the Commonwealth shall engage in any political activity (campaigning, fundraising, canvassing, poll watching) during his/her specified working hours if the Secretary of Administration determines that it conflicts or interferes with his/her official duties. Nor can s/he coerce another person in government service to contribute time, money or -8-

9 services to a political candidate or campaign. [Gov. Code of Conduct Part I, 8] School District employees cannot vote on any expenditure that would result in a direct financial benefit to an immediate family member. [PSD Code of Ethics at 6] School District employees cannot misuse funds, facilities, property, school personnel, time or other public assets, or their authority, to attain personal or private gain. School District employees also cannot receive honoraria; privately tutor any student(s) in their own schools; engage in advertising on school property or on school time (whether personal or political); participate in the process of approving materials that the district may purchase if s/he has worked on the materials; engage in a referral service for any services or products; accept any outside income that poses a conflict of interest; solicit benefits in a manner that suggests improper influence; or accept gifts or other benefits from those with whom the district does business (see exceptions). [PSD Code of Ethics at 4-5] 3. Procurement/Contracting The Office of Procurement Services is committed to ensuring that our business practices are carried out with the highest degree of professional ethics, integrity and competency. We are committed to providing superior customer service; implementing and utilizing best procurement practices; building solid business partner relationships; utilizing latest technological advancements; providing continuing education opportunities to our professional staff; networking with other procurement professionals; and continued advocacy of small business development by increasing the number of minority-owned and woman-owned businesses who bid on School District of Philadelphia contracts. [PSD Procurement Manual at 1] Prohibited procurement activities include changing bid or contract specifications without providing notice to all bidders, and engaging in private negotiations between the School District and potential bidders. [PSD Procurement Manual at 7-8] Solicitations of up to $5000 require one verbal price quote from a vendor; solicitations of $5001 to $10,000 require three verbal quotes via a phone bid; solicitations of $10,001 to $24,999 require a minimum of three written quotes via a Request for Quotation; and solicitations of $25,000 and above require solicitation via the Advertised Bid process. The Purchasing Department advertises and mails notification of the bid postings, and will open, analyze and submit resolutions for recommended contract awards to the SRC. -9-

10 [PSD Procurement Manual at 10] (citing Public School Code, 24 P.S (a)-(b)) The Request for Proposal ( RFP ) process is used for solicitations of transactions of $100,000 and above, or when the School District deems it appropriate or in its interest to obtain proposals from vendors on the scope of work or specifications. [PSD Procurement Manual at 10] (citing Public School Code, 24 P.S (a)-(b)) Contracts for materials, supplies, and equipment to be furnished, sold or leased to the District (unless exempt by statute) having an aggregate value of more than $25,000 are subject to the Advertised Bid or public competitive bid process. [PSD Procurement Manual at 10] (citing Public School Code, 24 P.S (a)-(b)) Contracts for professional services with an aggregate value of more than $25,000 (standard contracts) must be submitted by a school or program office in resolution form to the SRC for consideration. Upon SRC approval, the school or program office must submit the Agreement for Services, the SRC resolution authorizing the contract, the contractor s budget and description of work to the Office of General Counsel for review and necessary signatures. Contracts for professional services having an aggregate value of $15,000 5 and under (limited contracts) must be submitted, evaluated and approved by the Limited Contract Review Committee. [See PSD Procurement Manual at 10-11] All contracts for work to be done (unless exempt by statute) having a value of more than $4,000 shall also be subject to the competitive quote or bid process, except where such work is valued at less than $5,000 and performed by District employees. [PSD Procurement Manual at 11] (citing Public School Code, 24 P.S (b) & (c)) Pursuant to its authority under section 696(i)(3) of the Public School Code, 24 P.S (i)(3), the SRC has the power to suspend the bidding requirements and provisions of section of the Public School Code. [PSD Procurement Manual at 11] (citing Public School Code, 24 P.S (i)(3), (a)) No person shall act as an agent for school books or school supplies, in any district in which s/he is engaged or employed as a superintendent, teacher, or employee of the school district in any capacity, or in which 5 The Procurement Manual states that limited contracts are those with an aggregate value of up to $25,000, but the limited contract program currently applies to contracts of up to $15,000. This amount has been authorized by an SRC resolution delegating contracting authority to the Committee. -10-

11 s/he was thus employed during the preceding school year. [PSD Public School Code, 24 P.S ] School boards shall not draw, cause to be drawn or accept a specification for any item to be purchased by the school district that would limit the purchase of the item to the firm, corporation, partnership or other business entity of which a school director is an officer, agent or employee and exclude all other persons who could submit quotations or bid on an equivalent item. 24 P.S (b). Under certain circumstances, school boards may contract for goods or services with a business with which a school director is associated, pursuant to 65 Pa. Ch. 11 (related to ethics standards and financial disclosure). [Public School Code, 24 P.S (c)] It is unlawful for a school director, officer, superintendent, supervising principal, or teacher to ask for or accept money or any other valuable thing for his/her vote, recommendation or influence, in order to secure the recommendation, adoption, rejection, or purchase of any school books, school furniture, or other school supplies, from any person, firm, association, or corporation, or any agent or representative thereof, either directly or indirectly. [Public School Code, 24 P.S ] Bids shall be evaluated based on the requirements in the invitation to bid, which may include criteria to determine acceptability such as inspection, testing, quality, workmanship, delivery, and suitability for a particular purpose. Those criteria that will affect the bid price and be considered in evaluation for an award shall be objectively measurable, such as discounts, transportation costs, and total or life cycle costs. [PSD Procurement Manual at 14] (citing Pennsylvania Commonwealth Procurement Code, 62 Pa.C.S. 521(e)) 6 Contracts awarded during the public competitive bid process shall be let to the lowest responsible and responsive bidder upon resolution of the SRC, unless the SRC chooses to reject all bids. [PSD Procurement Manual at 14] (citing Public School Code, 24 P.S (a) & (b) and Pennsylvania Commonwealth Procurement Code, 62 Pa.C.S. 512(g)) 7 6 Although cited in the School District s Procurement Manual, the Commonwealth Procurement Code does not apply to the School District of Philadelphia. See explanation in footnote 1. When we last spoke with John Venti, Interim Director of the School District s Office of Procurement Services (on June 14, 2012), he stated that he had started the process of removing from the School District s procurement manual any references to the Commonwealth Procurement Code. 7 Id. -11-

12 Public officials/employees, their spouses or children, or any business in which the person/spouse/child is associated, cannot enter into a contract valued at $500 or more with the governmental body with which the public official/employee is associated, unless the contract has been awarded through an open and public process. 8 The same restriction applies to entering subcontracts valued at $500 or more with any person who has been awarded a contract with the governmental body with which the public official or public employee is associated. If the contract is awarded to a business with which the public official/employee, or their spouses or children are associated, the official/employee cannot have any supervisory responsibility for the contract. [65 Pa.C.S. 1103(f)] School District employees cannot recommend, vote or otherwise participate in the decision to make any contract valued at $1,000 or more between the School District and any business or entity in which the employee has a personal or financial conflict of interest. [PSD Code of Ethics at 4] A financial conflict of interest is deemed to exist if the decision has a material financial effect on: the employee s immediate family distinguishable from its effect on the public generally; any business entity in which the employee or a member of the employee s immediate family has a direct or indirect investment worth $1,000 or more, or in which the employee or a member of the employee s family is a director, officer, partner, trustee, employee, or holds any position of management; any real property in which the employee or a member of the employee s immediate family has a direct or indirect interest worth $1,000 or more; or any source of income for the employee or a member of the employee s immediate family of $1,000 or more. [PSD Code of Ethics at 4] School District employees who have access to confidential information about contracts, construction or procurement must maintain confidentiality; no misrepresentations or fraud; no acceptance of gifts or kick-backs; no contemporaneous employment with the School District and any contractor contracting with the District. [PSD Code of Ethics at 7-8] 4. Restrictions on Former Public Officials/Employees Former public officials/employees may not represent a person (with promised or actual compensation) on any matter before the governmental body that s/he was associated with for a period of one year after leaving that governmental body. [65 Pa.C.S. 1103(g)] 8 The Pennsylvania Supreme Court has held that Section 1103(f) of the State ethics act does not mandate a competitive bidding process. See Kistler v. State Ethics Commission, 22 A.3d 223, (Pa. 2011). -12-

13 Former executive-level State employees may not work for or represent a business or corporation that s/he actively participated with while working for the State, for a period of two years after terminating employment with the State. [65 Pa.C.S. 1103(i)] Former members of City Council and City officers or employees who have served for compensation may not assist at any time subsequent to City service or employment any person, with or without compensation, in any transaction involving the City in which s/he at any time participated during City service or employment. [City Ethics Law, ] Former School District employees are restricted from providing the following services for a period of 12 months after leaving the District: lobbying; contracting (or subcontracting) with the District in an area of service in which the former employee held a position of substantial responsibility, or on a contract that the former employee helped to develop. [PSD Code of Ethics at 6] Former School District employees responsible for procurement cannot accept employment with any bidder, offer, or contractor with whom the employee dealt in an official capacity, for a period of one year after terminating employment with the District (unless the employee first provides written notification to the Chief of Procurement of the School District). [PSD Code of Ethics at 8] C. Personnel Issues/Interpersonal Relationships A professional educator may not discriminate on the basis of race, national or ethnic origin, culture, religion, sex or sexual orientation, marital status, age, political belief, socioeconomic status, disability or vocational interest against any student or fellow professional. [22 Pa. Code 235.8] A professional educator may not deny or impede a colleague in the exercise or enjoyment of a professional privilege or right in being an educator; intentionally distort evaluations of colleagues; sexually harass fellow employees; or use coercion or special treatment to influence professional decisions of colleagues. [22 Pa. Code ] A professional educator may not sexually harass or engage in sexual relationships with students. [22 Pa. Code ] A board of school directors cannot employ any teacher who is related to any member of the board as a father, mother, brother, sister, husband, wife, son, daughter, stepson, stepdaughter, grandchild, nephew, niece, first cousin, sister in-law, brother-in-law, uncle or aunt, unless such teacher receives the affirmative votes of a majority of all members of the board other than the -13-

14 member related to the applicant, who shall not vote. [Public School Code, 24 P.S ] Under the Professional Educator Discipline Act, the Professional Standards and Practices Committee may discipline any Commonwealth teacher, educational specialist or administrator, or charter school staff member, who is found guilty upon hearings before the commission of, among other things, immorality, intemperance, cruelty or negligence. [24 P.S (a)(11)]. For purposes of this provision: o Immorality is defined as conduct which offends the morals of the Commonwealth and is a bad example to the youth whose ideals a professional educator or charter school staff member has a duty to foster and elevate [22 Pa. Code 237.3]; o Intemperance is defined as a loss of self-control or self-restraint, which may result from excessive conduct [22 Pa. Code 237.5]; o Cruelty is defined as intentional, malicious and unnecessary infliction of physical or psychological pain upon living creatures, particularly human beings [22 Pa. Code 237.7]; o Negligence is defined as continuing or persistent action or omission in violation of a duty [22 Pa. Code 237.8(a)]. In turn, a duty may be established by: law; promulgated school rules, policies or procedures; express direction from superiors; or duties of professional responsibilities, including those prescribed in the Code of Professional Practice and Conduct for Educators. [22 Pa. Code 237.8(b)]. No person who is a member of the same local, State, national or international organization as the employee organization with which the public employer is bargaining, or who has an interest in the outcome of such bargaining which interest is in conflict with the interest of the public employer, shall participate on behalf of the public employer in the collective bargaining processes, with the proviso that such person may, where entitled, vote on the ratification of an agreement. [Public Employee Relations Act of 1970 (Act 195), 43 P.S (conflict of interest provision)] School District employees cannot engage in any conduct with students that might be seen as improper. Dating relationships between employees and students are strictly prohibited. [PSD Code of Ethics at 8-9] School District employees must conduct themselves with integrity and honesty; avoid any form of falsification, misrepresentation, deception or cheating; be fair in all official actions affecting students and co-workers; treat employees, students and parents with respect; be candid and give accurate, -14-

15 timely information to superiors; maintain confidentiality of District and student information; and must not engage in intimidation, discrimination, or harassment (related to race, ethnicity, religion, national origin, sexual orientation, age, sex, or disability). [PSD Code of Ethics at 2] In the School District, immediate family members may work at the same facility or program, but not in superior-subordinate positions. Hiring, appointment, or transfer of an employee that creates such situations is prohibited. [PSD Code of Ethics at 6] School District employees cannot discuss or negotiate possible future employment with anyone (other than a government agency) that might benefit from any official action the employee might take while still employed by the District. [PSD Code of Ethics at 6] D. Duty to Report Misconduct School District employees shall report any unethical, illegal or dangerous conduct to any supervisor with whom the employee feels comfortable, or to the Director of Human Resources. Supervisors who receive such reports must report the matters to the Director of Human Resources. The obligation to report misconduct arises when the School District employee has personal knowledge that another employee s conduct constitutes (a) a violation of law or the PSD Code of Ethics; (b) gross mismanagement; (c) a significant waste of funds; (d) an abuse of authority; (e) a substantial and specific danger to public health or safety; or (f) other conduct that could injure the reputation of the District or subject it to liability. [PSD Code of Ethics at 9] E. Prohibitions on Retaliation Public officials/employees cannot discharge, threaten or demote any official or employee for filing a complaint with the Ethics Commission, or for providing information or testifying before the Commission. [65 Pa.C.S. 1108(j)] A professional educator may not threaten, coerce or discriminate against a colleague who in good faith reports to a governing agency actual or suspected violations of law, agency regulations or standards. [22 Pa (5)] No employer may discharge, threaten or otherwise discriminate or retaliate against an employee regarding the employee s compensation, terms, conditions, location or privileges of employment because the employee or a person acting on behalf of the employee makes a good faith report or is about to report, verbally or in writing, to the employer or appropriate authority an instance of wrongdoing or waste. [Pennsylvania Whistleblower Law, 43 P.S. 1423(a)] Nor can an employer take such action if an employee is requested by an appropriate authority to participate in an investigation, hearing or -15-

16 inquiry held by an appropriate authority or in a court action. [43 P.S. 1423(b)] (The Whistleblower Law defines employer as a person supervising one or more employees, a superior of that supervisor, or an agent of a public body.) School District employees cannot use or threaten to use official authority to prevent another employee from reporting alleged ethical violations, or to punish or harass an employee who has made a good faith complaint. [PSD Code of Ethics at 9] F. Transparency to the Public Under the Sunshine Act, certain rules apply to meetings of public agencies. 9 The must hold open meetings; each member s vote must be publicly cast and, for roll call votes, recorded; create meeting minutes; give public notice of the first regular meeting of each year; allow reasonable public participation; and allow members of the public to record the meetings. [65 Pa.C.S , 709, 711] The Sunshine Act does not apply to agency executive sessions, conferences, and working sessions by boards of auditors. [Id ] Agencies cannot construe a meeting as an executive session as subterfuge to exclude the public. [Id. 708(c)] Under the Right-to-Know Law, all Commonwealth, local, legislative and judicial agencies must provide public records upon written request from a member of the public. [65 P.S ] G. Lobbying Both the Commonwealth of Pennsylvania and the City of Philadelphia have lobbying laws, enforced by the State Ethics Commission and the Philadelphia Board of Ethics, respectively. The two laws are substantially similar. Both laws define lobbying as an effort to influence legislative or administrative action, including via direct or indirect communication, incurring office expenses, and providing any gift, hospitality, transportation or lodging to a State or City official or employee for the purpose of advancing the interest of the lobbyist or principal. [See 65 P.a.C.S. 13A03; Phila. Code (18)] Both laws also define a principal as an individual, association, corporation or any other entity that engages in lobbying on its own behalf, either directly or through a lobbying firm or lobbyist. [See 65 P.a.C.S. 13A03; Phila. Code (23)] 9 The Sunshine Act defines an agency to include: the bodies and all committees of the General Assembly; the executive branch of the State; all boards, councils, authorities or commissions of the State or any political subdivision; State, municipal, township or school authorities, boards, governing bodies, and commissions; and boards of trustees for State-aided and State-owned colleges and universities. [65 Pa.C.S. 703, Agency ] -16-

17 The Philadelphia lobbying law applies to anyone dealing with the Philadelphia School District and any board or other instrumentality thereof. [Phila. Code (3)(c)] The following requirements apply to lobbying activities under both the Pennsylvania and Philadelphia lobbying laws. Any notable differences are explained below. Registration: A lobbyist, lobbying firm or a principal must register with the Department of State of the Commonwealth (under the Pennsylvania law) or the Philadelphia Board of Ethics (under the Phila. law) within 10 days of acting in any capacity as a lobbyist, lobbying firm or principal. Pennsylvania law requires registration every two years, while Phila. law requires registration annually. [65 P.a.C.S. 13A04(a); Phila. Code (1); see 65 P.a.C.S. 13A04(b)-(c) and Phila. Code (2)-(3) for required information] Any change in information must be amended in the registration within 14 days after the change occurs. [65 P.a.C.S. 13A04(d); Phila. Code (4)] Reporting: A registered principal must, under oath or affirmation, file quarterly expense reports with the Department of State of the Commonwealth (under the Pennsylvania law) or the Philadelphia Board of Ethics (under the Phila. law) no more than 30 days after the last day of the quarter. [65 P.a.C.S. 13A05(a)-(b); Phila. Code (1); see 65 P.a.C.S. 13A05(b) and Phila. Code (2) for content of expense reports] An expense report is required when total expenses exceed $2,500 for the registered principal in a reporting period. If less, a statement to that effect shall be filed. [See 65 P.a.C.S. 13A05(d); Phila. Code (7)] Registrants must retain all documents reasonably necessary to substantiate the reports for four years from the date of filing of the subject report. [See 65 P.a.C.S. 13A05(c); Phila. Code (6)] Exemptions: There are numerous persons and activities exempt from the registration and reporting requirements, including elected and appointed State/City/political subdivision officials acting in their official capacity. [See 65 P.a.C.S. 13A06; Phila. Code ] Prohibited activities A lobbyist may not: o Serve as an officer who must be included in a registration statement under the Pennsylvania Election Code for a candidate s political committee or political action committee, if the candidate is seeking a Statewide or City office or the office of Senator or Representative in the General Assembly. [See 65 P.a.C.S. 13A07(a); Phila. Code (2)] o Charge a fee or receive economic consideration based on a contract that any part of the fee or consideration will be converted into a contribution to a candidate for public office or a political committee -17-

18 subject to reporting under the Pennsylvania Election Code. [See 65 P.a.C.S. 13A07 (b); Phila. Code (3)] o Knowingly make a false, forged, counterfeit or fictitious communication to a State/City official or employee to influence legislative or administrative action. [See 65 P.a.C.S. 13A07(c); Phila. Code (4)] o Lobby on behalf of a principal on any subject matter that is directly adverse to another principal currently or previously represented by the lobbyist, or the lobbyist s own interests. [See 65 P.a.C.S. 13A07(d)(1), Phila. Code (5)(a); see 65 P.a.C.S. 13A07(d)(2) and Phila. Code (5)(b) for exceptions] o Receive compensation contingent in whole or in part on the occurrence, nonoccurrence or amendment of legislative or administrative action (other than procurement). This restriction does not apply to vendors. [See 65 P.a.C.S. 13A07(e); Phila. Code (7)] Unlawful activities: A lobbyist or principal may not: o Instigate legislation for the purpose of obtaining employment to lobby in opposition to that legislation; o Knowingly counsel a person to violate the Lobbying Disclosure law or any other federal or state statute; o Engage or counsel another to engage in fraudulent conduct; o Attempt to influence a State/City official or employee on legislative or administrative action through a loan, or by the promise of financial support or the financing of an opponent at a future election; o Refuse to disclose the identity of a principal on whose behalf the lobbyist or principal is lobbying; o Commit a criminal offense arising from lobbying; o Influence or attempt to influence a State/City official or employee by coercion, bribery or threat of economic sanction; o Extort or unlawfully retaliate against a State/City official or employee by reason of their position or vote on an administrative or legislative action; -18-

19 H. Campaign Finance o Engage in conduct which brings the practice of lobbying of the legislative or executive branches of State or City government into disrepute. [See 65 P.a.C.S. 13A07(f); Phila. Code (8)] Philadelphia s Campaign Finance law is enforced by the Philadelphia Board of Ethics and applies to candidates for City elective offices. Among other things, the law sets limits on political contributions to candidates [Phila. Code ] and campaign expenditures for various elective positions [Id (2)], and requires candidates and political committees to disclose campaign finance information to the Philadelphia Ethics Board [Id ]. I. Entities Created Under the Memoranda of Understanding (MOU) That May Be Subject to Ethics Obligations Executive Advisors: The Department of Education and the City of Philadelphia each designated one full-time individual called an Executive Advisor (EA) to work inside the PSD and advise/support the administration through the interim leadership period. The EAs were situated at the Acting Superintendent s level and provided advice, input and recommendations to the Acting Superintendent. EAs could not cause the PSD to incur any additional expense or diminish the Acting Superintendent s authority. EAs participated in all PSD cabinet, senior staff, and major management meetings, and SRC meetings. EAs had access to all PSD information, including documentation described in the Educational Accountability MOU of June 2011, unless it would have been inappropriate to share the information with the EA (such as due to an actual or potential conflict of interest). EAs were responsible for their own compliance with all applicable ethics rules and legal requirements. [October 2011 MOU, 2(d)] Working Group: The SRC appointed knowledgeable individuals to a Financial, Operations and Systems Working Group (the Working Group ) to advise the parties and the EAs about the PSD s financial systems, contracting systems, personnel controls, general administrative organization, and any other areas at the SRC s request. The Working Group was not responsible for implementing any recommendations or changes. Working Group members were not compensated. [October 2011 MOU, 3-4] Working Group members signed a Conflict of Interest Memorandum, and a Confidentiality and Nondisclosure Agreement. -19-

20 EXHIBIT 1

21

22

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