The Upper Dublin School District Policy Committee on Dec. 10 agreed in principle to consolidate separate conflict-of-interest policies for employees and board members into a single operations policy and to forward the draft to the legislative meeting and legal review.
The chair (unnamed in the transcript) introduced the change as part of a broader effort to align district policy numbers with Pennsylvania School Boards Association guidance. Speaker 2 told the committee the proposal would “repeal 360, repeal 007, and create the new 827,” combining provisions that previously lived in separate sections to reduce duplication and administrative work.
Committee members said consolidation would make maintenance easier but urged clear signposting in the new policy so readers can quickly determine which sections apply to board members, employees or contractors. John Held, a returning committee member, urged retaining a narrow exception that permits a board member otherwise required to abstain to vote when necessary to break a tie; the chair and other members said that provision appeared intended to remain and should be explicitly ported into the consolidated text.
Several members flagged technical points for legal review: whether the policy should include language about “perceived” conflicts (some members favored reporting perceptions rather than defining conduct by another’s perception), how to treat honoraria paid to family members, and where to place a savings clause that clarifies the policy supplements state ethics law and the school code. As Speaker 3 summarized on perceived conflicts: “Somebody's perception is their perception… defining somebody’s behavior based on how somebody else perceives it is really difficult to do,” and the committee agreed reporting perceptions is appropriate while making prohibitions about conduct narrowly framed.
The committee also asked staff to list statutory references in the policy’s authority section (for example, the school code, Pennsylvania Department of Education standards, and the Sunshine Act) rather than burying them in corrective-action language. Miss Kitten and other staff committed to preserve definitions (such as “associated”) from prior policies.
After discussion and line-by-line checks, committee members indicated consensus to move the consolidated conflict-of-interest policy forward for legal review and consideration at the legislative meeting; no roll-call vote was recorded during the committee meeting.
The next step is legal review to ensure statutory language and reporting requirements are properly cited and to finalize any cross-references or AR (administrative regulation) language before the legislative board considers adoption.