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Adams 12 reports compliance on staff ethics, purchasing and high‑value property rules; will expand annual certification

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Summary

Adams 12 Five Star Schools told the board it complied with internal policies on staff ethics and purchasing during the July 2023–June 2024 monitoring period, identified three unbudgeted purchases above $500,000 that were approved, and said it will require more employees to sign annual conflict‑of‑interest certifications beginning July 2025.

Adams 12 Five Star Schools officials told the board Thursday that the district complied with internal policies governing staff ethics, conflict of interest and high‑value property transactions for the July 1, 2023–June 30, 2024 monitoring period, and outlined steps to broaden required annual certifications and to consider an anonymous ethics hotline.

Brenda McGee, director of supply chain management for Adams 12 Five Star Schools, said Policy 41.30 — the staff ethics/conflict‑of‑interest/nepotism policy — requires an annual notice and return certification from employees in specified classes and that Human Resources currently sends those notices. "We are required as employees to sign those and send those back that we understand the nepotism policy, the conflict of interest," McGee said. She said some classified and regular certified staff who handle purchases (office managers, bookkeepers, teachers who make purchases) are not yet required to sign the 41.30 certification but that HR plans to add that requirement for classified and certified staff beginning July 2025.

The district also reviewed purchasing policy thresholds. Molly Brandt, chief operating officer for Adams 12, summarized Policy 33.20 and related guidance used by the district for purchase authority and competitive thresholds: delegated staff may make purchases under $10,000; purchases between $10,000 and $100,000 generally require an informal bid and at least two quotes; purchases exceeding $100,000 require a minimum of three written or electronic proposals. Brandt said the district encourages contracts and procurement review by purchasing for protection against problematic contract language but noted some school‑level staff occasionally sign agreements before procurement review.

On the district's monitoring standard for property acquisition and disposition (described in the report as the guidance that requires board approval for acquisitions larger than $500,000 when not already budgeted, part of a bond or part of a mill levy override), Brandt said the district identified three decision information reports during the monitoring period that met that threshold and had been approved by the board: a cybersecurity vendor contract on Aug. 16, 2023 to reduce unstructured data risk; a replacement of the Northland High School track in December 2023 (reported as part of bond funding and also reviewed by the district's Long Range Planning Advisory Committee, LRPAC); and construction work at Thunder Vista on June 5, 2024 to repair broken pipes. Brandt described the review process used to identify those items: cross‑checking board agendas, finance reports of purchases over $500,000, and direct confirmations with chiefs and department leaders.

Board members asked about earlier instances where procurement practice did not strictly follow policy and whether the district had monitored those incidents for trends. McGee said she had not performed a follow‑up audit of those specific instances but that staff are "becoming more aware and asking more questions and working more closely with the purchasing department." When asked about an anonymous ethics hotline, a board member who identified himself as Mike said, "I'm a big fan of the ethics outlines" and described how a low‑cost anonymous reporting system can provide early signals for management. Brandt and McGee said they would look into that suggestion and follow up.

The officials said they did not identify any property dispositions during the monitoring period that would trigger the district's disposal rules. Brandt noted the district is monitoring potential land work tied to phasing and transition for the planned Thornton High School campus; if acquisitions or dispositions occur in the next monitoring period, they will be reported in next year's monitoring documentation.

No formal board motions or votes were recorded during this portion of the meeting; the presentation concluded after board questions and staff follow‑up commitments.

The district provided the monitoring documentation to board members via a shared drive and said it will update the annual certification process and report back on potential anonymous reporting options and any procedural training or audits that staff recommend.