{
  "code": "DBD",
  "title": "Employment Requirements and Restrictions: Conflict of Interest",
  "description": "This policy addresses conflicts of interest related to the employment of District administrators. It defines who qualifies as an administrator and sets rules around administrators receiving financial benefits from businesses or educational entities that have dealings with the District. The policy also outlines a Board-approval process for certain financial arrangements and establishes disclosure requirements and penalties for violations.",
  "policy_connect_url": "https://policyconnect.org/policy/conroe-isd/DBD",
  "last_action_date": "2026-05-12",
  "last_action_result": "adopted",
  "timeline_local": [
    {
      "date": "2026-05-12",
      "school_year": "2025-2026",
      "action": "adopted",
      "result": "adopted",
      "summary": "This update to Conroe ISD's DBD (Local) policy adds a new \"Administrator Financial Benefit\" section that defines \"administrator,\" prohibits administrators from receiving financial benefits for personal services to certain business entities or other districts, and establishes a Board-approval process with public disclosure requirements and a $10,000 civil penalty for violations. The date issued field is also updated to reflect the new version.",
      "changes_added": [
        "Administrator Financial Benefit [section heading]",
        "Definition [subsection heading under Administrator Financial Benefit]",
        "For this section, an administrator means a person who has significant administrative duties relating to the operation of the District, including the operation of a campus, program, or other subdivision of the District.",
        "The definition of administrator does not include: 1. An employee whose employment contract responsibilities primarily include the in-classroom instruction of students; or 2. A Board member.",
        "Financial Benefit [subsection heading under Administrator Financial Benefit]",
        "Except as provided by this Board policy, an administrator may not receive any financial benefit for the performance of personal services for: 1. Any business entity that conducts or solicits business with the District; 2. An education business that provides services regarding the curriculum or administration of any school district; or 3. Another school district, open-enrollment charter school, or regional education service center.",
        "An administrator, other than a Board member, superintendent, or assistant superintendent, may receive a financial benefit for the performance of personal services for items (2) or (3) above only if: 1. A written contract describing the services to be performed by the administrator is provided to the Board; and 2. The Board votes to approve the contract after determining that: a. The contract will not harm the District; b. The arrangement does not present a conflict of interest; and c. The services to be performed will be performed entirely on the administrator's personal time.",
        "A contract provided to the Board under these conditions shall be subject to public disclosure.",
        "An administrator who violates these terms may be liable to the state for a civil penalty in the amount of $10,000 for each violation.",
        "The District shall adopt procedures to implement this policy."
      ],
      "changes_removed": [
        "2016-01-26 [strikethrough in DATE ISSUED line]",
        "1 [strikethrough in UPDATE line]"
      ],
      "meeting_notes_url": "https://cisd-meetings.boardmonitor.app/meeting.html?id=2026-05-12_regular",
      "confidence": "high",
      "source_redline": "DBD_LOCAL.pdf",
      "notes": "The cover page title reads \"Consider on Second Read and Final Adoption,\" indicating this is a second reading proceeding to adoption. All red-underlined text (the entire new Administrator Financial Benefit section) was clearly distinguishable. The only red strikethrough text visible was the original date \"2016-01-26\" and update number \"1\" in the footer, indicating a version/date update. The legislative basis pages (pp. 5–6) reference House Bill 3372 / Texas Education Code §11.006 as the origin of the changes.",
      "compliance_assessment": {
        "classification": "Required by Law",
        "elements": [
          {
            "element": "Definition of Administrator",
            "classification": "Required by Law",
            "statutory_basis": "TEC § 11.006 as enacted by H.B. 3372 (89th Leg., R.S., 2025)",
            "supporting_quote": "The term does not include: (1) an employee whose employment contract responsibilities primarily include the in-classroom instruction of students",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None — definition mirrors statutory language"
          },
          {
            "element": "Exclusion from Administrator Definition — in-classroom instruction employees",
            "classification": "Required by Law",
            "statutory_basis": "TEC § 11.006 as enacted by H.B. 3372 (89th Leg., R.S., 2025)",
            "supporting_quote": "The term does not include: (1) an employee whose employment contract responsibilities primarily include the in-classroom instruction of students",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None — exclusion mirrors statutory language"
          },
          {
            "element": "Exclusion from Administrator Definition — Board members",
            "classification": "Required by Law",
            "statutory_basis": "TEC § 11.006 as enacted by H.B. 3372 (89th Leg., R.S., 2025)",
            "supporting_quote": "The term does not include: ... (2) a member of the board of trustees.",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None — exclusion mirrors statutory language"
          },
          {
            "element": "Prohibition on financial benefit for services to business entities conducting or soliciting business with the District",
            "classification": "Required by Law",
            "statutory_basis": "TEC § 11.006 as enacted by H.B. 3372 (89th Leg., R.S., 2025)",
            "supporting_quote": "An administrator may not receive any financial benefit for the performance of personal services for: (1) any business entity that conducts or solicits business with the school district that employs the administrator",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None — prohibition mirrors statutory requirement"
          },
          {
            "element": "Prohibition on financial benefit for services to education businesses regarding curriculum or administration",
            "classification": "Required by Law",
            "statutory_basis": "TEC § 11.006 as enacted by H.B. 3372 (89th Leg., R.S., 2025)",
            "supporting_quote": "except as provided by Subsection (c), an education business that provides services regarding the curriculum or administration of any school district",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None — prohibition mirrors statutory requirement"
          },
          {
            "element": "Prohibition on financial benefit for services to other school districts, open-enrollment charter schools, or regional education service centers",
            "classification": "Required by Law",
            "statutory_basis": "TEC § 11.006 as enacted by H.B. 3372 (89th Leg., R.S., 2025)",
            "supporting_quote": "except as provided by Subsection (c), another school district, open-enrollment charter school, or regional education service center",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None — prohibition mirrors statutory requirement"
          },
          {
            "element": "Board approval exception: written contract requirement",
            "classification": "Required by Law",
            "statutory_basis": "TEC § 11.006 as enacted by H.B. 3372 (89th Leg., R.S., 2025)",
            "supporting_quote": "a written contract describing the services to be performed by the administrator is provided to the board of trustees of the administrator's employing district",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None — requirement mirrors statutory mandate"
          },
          {
            "element": "Board approval exception: board vote requirement",
            "classification": "Required by Law",
            "statutory_basis": "TEC § 11.006 as enacted by H.B. 3372 (89th Leg., R.S., 2025)",
            "supporting_quote": "the board of trustees for the administrator's employing district votes to approve the contract",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None — requirement mirrors statutory mandate"
          },
          {
            "element": "Board approval exception: no-harm-to-district determination",
            "classification": "Required by Law",
            "statutory_basis": "TEC § 11.006 as enacted by H.B. 3372 (89th Leg., R.S., 2025)",
            "supporting_quote": "the contract will not harm the district",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None — determination mirrors statutory requirement"
          },
          {
            "element": "Board approval exception: no-conflict-of-interest determination",
            "classification": "Required by Law",
            "statutory_basis": "TEC § 11.006 as enacted by H.B. 3372 (89th Leg., R.S., 2025)",
            "supporting_quote": "the arrangement does not present a conflict of interest",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None — determination mirrors statutory requirement"
          },
          {
            "element": "Board approval exception: services performed entirely on personal time",
            "classification": "Required by Law",
            "statutory_basis": "TEC § 11.006 as enacted by H.B. 3372 (89th Leg., R.S., 2025)",
            "supporting_quote": "the services to be performed by the administrator will be performed entirely on the administrator's personal time",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None — requirement mirrors statutory mandate"
          },
          {
            "element": "Exception unavailable to superintendent and assistant superintendent",
            "classification": "Required by Law",
            "statutory_basis": "TEC § 11.006 as enacted by H.B. 3372 (89th Leg., R.S., 2025)",
            "supporting_quote": "An administrator, other than a member of a board of managers, superintendent, or assistant superintendent, may receive a financial benefit under Subsection (b)(2) or (3) if",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None — statutory exclusion applied directly; policy substitutes 'Board member' for 'member of a board of managers,' which is functionally equivalent in a trustee-governed district"
          },
          {
            "element": "Public disclosure of contracts provided to the Board",
            "classification": "Required by Law",
            "statutory_basis": "TEC § 11.006 as enacted by H.B. 3372 (89th Leg., R.S., 2025)",
            "supporting_quote": "A contract provided to a board of trustees under Subsection (c) is subject to disclosure under Chapter 552, Government Code.",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None — disclosure obligation is statutorily mandated"
          },
          {
            "element": "$10,000 civil penalty per violation",
            "classification": "Required by Law",
            "statutory_basis": "TEC § 11.006 as enacted by H.B. 3372 (89th Leg., R.S., 2025)",
            "supporting_quote": "An administrator who violates this section is liable to the state for a civil penalty in the amount of $10,000 for each violation.",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None — penalty amount and structure are statutorily prescribed"
          },
          {
            "element": "District shall adopt procedures to implement this policy",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "The statute analysis contains no verbatim quote requiring the district to adopt implementing procedures; this is a locally chosen administrative mechanism to operationalize the statutory requirements"
          }
        ]
      },
      "compliance_summary": [
        "Administrator Definition: H.B. 3372 (2025) added a new section to Texas Education Code § 11.006 that defines who counts as an 'administrator' for purposes of this rule. The policy copies that definition directly, including clarifications that classroom teachers and school board members are not covered.",
        "Financial Benefit Prohibition: Under TEC § 11.006 as updated by H.B. 3372, administrators are prohibited from receiving personal payments for services provided to businesses that work with the district, education-related companies, or other school districts and charter schools. This policy reflects that statutory prohibition.",
        "Board Approval Exception: State law allows an administrator to receive outside pay in limited cases if the school board approves a written contract, determines there is no harm to the district and no conflict of interest, and confirms the work is done entirely on the administrator's personal time. This policy includes each of those conditions as required by TEC § 11.006.",
        "Superintendent Exclusion: TEC § 11.006 does not allow the board approval exception to apply to superintendents or assistant superintendents, meaning those positions may not receive outside financial benefits under any circumstances. This policy applies that same restriction.",
        "Civil Penalty: H.B. 3372 set a civil penalty of $10,000 per violation for administrators who receive prohibited financial benefits. This policy states that penalty amount, which comes directly from TEC § 11.006.",
        "Implementing Procedures: The policy directs the district to create internal procedures for carrying out these new rules. This step was not required by state law and reflects a local decision to help put the policy into practice."
      ]
    },
    {
      "date": "2026-04-21",
      "school_year": "2025-2026",
      "action": "first_reading",
      "result": "first_reading",
      "summary": "This update to Board Policy DBD (Local) adds a new \"Administrator Financial Benefit\" section that defines who qualifies as an administrator, prohibits administrators from receiving financial benefits for personal services rendered to businesses dealing with the District or other educational entities, and establishes a Board-approval process with public disclosure requirements and a $10,000 civil penalty for violations. The changes are driven by Texas House Bill 3372 (Education Code §11.006).",
      "changes_added": [
        "Administrator Financial Benefit — section heading (new section)",
        "Definition — subsection heading",
        "For this section, an administrator means a person who has significant administrative duties relating to the operation of the District, including the operation of a campus, program, or other subdivision of the District.",
        "The definition of administrator does not include: 1. A school district employee whose employment contract responsibilities primarily include the in-classroom instruction of students; or 2. A Board of Trustees member.",
        "Financial Benefit — subsection heading",
        "Except as provided by this policy, an administrator may not receive any financial benefit for the performance of personal services for: 1. Any business entity that conducts or solicits business with the District; 2. An education business that provides services regarding the curriculum or administration of any school district; or 3. Another school district, open-enrollment charter school, or regional education service center.",
        "An administrator, other than a member of a Board of Trustees, superintendent, or assistant superintendent, may receive a financial benefit for the performance of personal services for (2) or (3) only if: 1. A written contract describing the services to be performed by the administrator is provided to the Board; and 2. The Board votes to approve the contract after determining that: a. The contract will not harm the District; b. The arrangement does not present a conflict of interest; and c. The services to be performed will be performed entirely on the administrator's personal time.",
        "A contract provided to a Board under these conditions shall be subject to public disclosure.",
        "An administrator who violates these terms may be liable to the state for a civil penalty in the amount of $10,000 for each violation.",
        "The District shall adopt procedures to implement this policy.",
        "UPDATE: 1 (version bump in footer)"
      ],
      "changes_removed": [
        "2016-01-26 (struck through in DATE ISSUED footer, indicating a date update)"
      ],
      "meeting_notes_url": "https://cisd-meetings.boardmonitor.app/meeting.html?id=2026-04-21_regular",
      "confidence": "high",
      "source_redline": "DBD_LOCAL.pdf",
      "notes": "The cover page title reads \"Consider and Adopt Revisions to Board Policy DBD (Local)\" with no \"First Reading\" qualifier, so action is recorded as 'adopted'. All red-underlined text in the Administrator Financial Benefit section (pages 3–4) constitutes entirely new language; no pre-existing policy text was removed other than the original issue date in the footer. The TEE (Texans for Excellence in Education) comparison pages (5–6) show the corresponding statutory language from HB 3372 / Education Code §11.006 as context but are not part of the policy text itself.",
      "compliance_assessment": {
        "classification": "Required by Law",
        "elements": [
          {
            "element": "Administrator Definition (including exclusions for classroom instructors and board members)",
            "classification": "Required by Law",
            "statutory_basis": "TEC §11.006 as enacted by H.B. 3372 (89th Leg., R.S.)",
            "supporting_quote": "an administrator may not receive any financial benefit for the performance of personal services for: (1) any business entity that conducts or solicits business with the school district",
            "verification_method": "adapted statute text",
            "litigation_status": "None identified",
            "local_additions": "Policy excludes 'A Board of Trustees member' from the administrator definition. The statute excludes 'a trustee of a school district.' Functionally equivalent but not verbatim."
          },
          {
            "element": "Prohibition on financial benefits from business entities conducting or soliciting business with the District",
            "classification": "Required by Law",
            "statutory_basis": "TEC §11.006(b)(1) as enacted by H.B. 3372 (89th Leg., R.S.)",
            "supporting_quote": "an administrator may not receive any financial benefit for the performance of personal services for: (1) any business entity that conducts or solicits business with the school district",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None"
          },
          {
            "element": "Prohibition on financial benefits from education businesses providing curriculum or administration services",
            "classification": "Required by Law",
            "statutory_basis": "TEC §11.006(b)(2) as enacted by H.B. 3372 (89th Leg., R.S.)",
            "supporting_quote": "an administrator may not receive any financial benefit for the performance of personal services for: (2) an education business that provides services regarding the curriculum or administration of any school district",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None"
          },
          {
            "element": "Prohibition on financial benefits from other school districts, charter schools, or ESCs",
            "classification": "Required by Law",
            "statutory_basis": "TEC §11.006(b)(3) as enacted by H.B. 3372 (89th Leg., R.S.)",
            "supporting_quote": "an administrator may not receive any financial benefit for the performance of personal services for: (3) another school district, open-enrollment charter school, or regional education service center",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None"
          },
          {
            "element": "Absolute prohibition for superintendents and assistant superintendents (no board-approval exception available)",
            "classification": "Required by Law",
            "statutory_basis": "TEC §11.006(b)-(c) as enacted by H.B. 3372 (89th Leg., R.S.)",
            "supporting_quote": "An administrator, other than a member of a board of managers, superintendent, or assistant superintendent, may receive a financial benefit for the performance of personal services for a purpose described by Subsection (b)(2) or (3) only if",
            "verification_method": "adapted statute text",
            "litigation_status": "None identified",
            "local_additions": "Policy uses 'Board of Trustees' where the statute says 'board of managers.' A board of managers is a state-appointed conservatorship body; CISD has an elected board of trustees. The substitution is locally appropriate but not verbatim statutory language."
          },
          {
            "element": "Written contract requirement as prerequisite for board approval of financial benefit",
            "classification": "Required by Law",
            "statutory_basis": "TEC §11.006(c) as enacted by H.B. 3372 (89th Leg., R.S.)",
            "supporting_quote": "a written contract describing the services to be performed by the administrator is provided to the board",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None"
          },
          {
            "element": "Board vote with three-part determination (no harm to district, no conflict of interest, personal time only)",
            "classification": "Required by Law",
            "statutory_basis": "TEC §11.006(c) as enacted by H.B. 3372 (89th Leg., R.S.)",
            "supporting_quote": "the board votes to approve the contract after determining that: the contract will not harm the school district; the arrangement does not present a conflict of interest; the services to be performed will be performed entirely on the administrator's personal time",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None"
          },
          {
            "element": "Public disclosure of contracts submitted for board approval",
            "classification": "Required by Law",
            "statutory_basis": "TEC §11.006(c) as enacted by H.B. 3372 (89th Leg., R.S.)",
            "supporting_quote": "A contract provided to the board under Subsection (c) is subject to public disclosure.",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None"
          },
          {
            "element": "$10,000 civil penalty per violation for administrators who violate the section",
            "classification": "Required by Law",
            "statutory_basis": "TEC §11.006 as enacted by H.B. 3372 (89th Leg., R.S.)",
            "supporting_quote": "An administrator who violates this section is liable to the state for a civil penalty in the amount of $10,000 for each violation.",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "None — policy restates the statutory penalty without enhancement"
          },
          {
            "element": "District obligation to adopt implementation procedures",
            "classification": "Mixed",
            "statutory_basis": "TEC §11.006 as enacted by H.B. 3372 (89th Leg., R.S.)",
            "supporting_quote": "None — no verbatim statutory quote in the statute analysis directly mandates that the district adopt implementing procedures",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "The directive that 'the District shall adopt procedures to implement this policy' is not supported by a verbatim quote in the statute analysis provided; the specific procedural content the district will adopt is locally discretionary. Classified Mixed because the overall compliance framework is statutorily required but the procedural implementation mandate in the policy text lacks a supporting verbatim statutory quote and reflects local board choice."
          }
        ]
      },
      "compliance_summary": [
        "Administrator Definition: Texas House Bill 3372 (H.B. 3372) required school districts to define which employees count as 'administrators' under a new financial ethics rule. The definition in this policy follows state law exactly, and does not include classroom teachers or school board members.",
        "Financial Benefit Prohibitions: H.B. 3372, codified as Texas Education Code §11.006, prohibits administrators from receiving personal payments or other financial benefits from companies doing business with the district, education service providers, or other school districts and charter schools. This policy restates those three categories of prohibited relationships directly from the statute.",
        "Superintendent-Level Restrictions: Under TEC §11.006, superintendents and assistant superintendents face a stricter standard than other administrators — there is no approval process available to them, meaning they may not receive these types of financial benefits under any circumstances.",
        "Board Approval Process: For administrators other than superintendents and assistant superintendents, TEC §11.006 allows the school board to approve outside financial arrangements if certain conditions are met — a written contract must exist, the board must confirm there is no harm to the district, no conflict of interest, and that the work is done on personal time, and the contract must be made available to the public.",
        "$10,000 Civil Penalty: State law sets a civil penalty of $10,000 per violation for administrators who break these rules. This policy restates that penalty amount directly from TEC §11.006 without adding to it.",
        "Implementation Procedures: The policy directs the district to create internal procedures for carrying out this new rule. While the overall compliance framework comes from H.B. 3372, the specific procedures the district will develop are a local decision made by the school board."
      ]
    }
  ],
  "timeline_legal": []
}