Conflict of Interest Policy for Investigations

Reynolds School District is committed to ensuring that all investigations, including those related to personnel, civil rights, and Title IX matters, are conducted in a manner that is free from bias and conflicts of interest. By following this policy, the District aims to uphold the integrity of its investigative processes and maintain a fair and equitable environment for all students, staff, and families.

Purpose

The purpose of this policy is to ensure that all investigations conducted within Reynolds School District, including but not limited to personnel investigations, civil rights complaints, and Title IX matters, are fair, impartial, and free from conflicts of interest. This policy provides clear procedures for handling conflicts of interest when they arise, ensuring that parties to an investigation are treated equitably and that investigations are conducted without bias.

Scope

This policy applies to all District employees involved in conducting the investigations, including administrators, principals, assistant principals, directors, and managers.

General Principles

  • Investigators must remain impartial and objective at all times. 
  • Any individual who has a conflict of interest due to bias, relationships with a party involved, or any other factor must recuse themselves from overseeing or participating in the investigation. 

Definitions

Conflict of Interest: A situation in which a person’s personal interests or relationships with any party involved in the investigation may compromise their objectivity, impartiality, or ability to carry out a fair investigation. This may include, but is not limited to, personal relationships, familial connections, or financial interests that could affect the perception or outcome of the investigation.

Procedure for Handling Conflicts of Interest 

1. Recusal of Principal 

If the principal or lead investigator in a personnel or Title IX investigation identifies or is informed of a conflict of interest due to bias, relationship to a party involved in the complaint (student, staff, parent, or advisor), or any other factor that may impair impartiality, the individual must recuse themselves from the investigation.

2. Escalation Process

  • If the principal is conflicted out of the investigation, the investigation will be referred to an Assistant Principal.
  • If the Assistant Principal is conflicted out or unavailable, the investigation will be escalated to the Director of Schools.
  • If the Director of Schools is conflicted out, the investigation will be transferred to the Manager of Civil Rights and Title IX or the Executive Director of Human Resources, depending on the nature of the complaint.

3. Special Considerations

  • If the complaint involves the Manager of Civil Rights and Title IX, or if the Manager has a conflict of interest or bias, the Executive Director of Human Resources or their designee will assume responsibility for conducting the investigation or will assign an external, independent investigator to handle the case.
  • If the complaint involves the Executive Director of Human Resources or Superintendent, or if either of these individuals is conflicted out, an outside investigator will be appointed to conduct the investigation. This ensures that impartiality and fairness are maintained throughout the investigation process.
  • If the complaint involves a superior but otherwise would fall within the scope of the investigator’s duties, the investigation will be elevated to a higher level (i.e. an assistant principal will not be tasked with investigating a principal).
  • If a specific case is deemed by the Superintendent, Executive Director of Human Resources, or the Manager of Civil Rights and Title IX to be complex or require special attention, then the investigation can be elevated to a higher-level administrator or external investigator.

4. Appointment of Outside Investigators

  • In cases where internal personnel are unable to handle the investigation due to conflicts of interest, the District will appoint a qualified external investigator. The external investigator will be selected based on their expertise in civil rights, Title IX, or personnel investigations, as applicable to the nature of the complaint.
  • The external investigator will report directly to the Manager of Civil Rights and Title IX, Executive Director of Human Resources, Superintendent, or Board of Education, depending on the specific circumstances of the case.

5. Notification and Documentation

  • If the investigation has already been initiated, all parties involved in the investigation will be notified promptly of any changes in the investigation process, including recusal and referral to another administrator or external investigator.
  • The District will maintain thorough documentation of the conflict of interest and the steps taken to ensure a fair and impartial investigation.
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