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Mel Gravely

Importance of a Code of Conduct for Your Board, Policy Council, & Tribal Council

According to Sec 642(c) of the Head Start Act, all Head Start designees are required to have a formal structure for program governance, including the formation of a governing body and policy council. The section goes into detail about the responsibilities of the board and policy council, including the composition of each group and who should be a member. It also goes into detail about conflicts of interest for both entities, careful to define the types of prohibited conflicts of interest.

The Act goes on further to describe that the policies and procedures regarding conflicts of interest must be formalized in writing by the governing body:

(X) establishing, adopting, and periodically updating written standards of conduct that establish standards and formal procedures for disclosing, addressing, and resolving–
(aa) any conflict of interest, and any appearance of a conflict of interest, by members of the governing body, officers and employees of the Head Start agency, and consultants and agents who provide services or furnish goods to the Head Start agency;

The Board of Directors for a Head Start agency is the primary fiduciary custodian of the agency’s federal dollars. Policy Council has a secondary role in advising the Board in how funds should be spent. As such, it is imperative that both the Board and Policy Council conduct themselves in a manner that acts in the interest of the agency and the children and families it serves.

This not only includes avoiding conflicts of interest, but also dictates the board’s use of confidential information, accepting gratuities or gifts, and conducting themselves in a respectful manner when representing the agency, both in meetings and out in the public.

Remember, not everyone who is invited to serve on a board has ever served on one before, which is particularly true with policy council. They may not be familiar with the standards and rules. That’s why it’s important that expectations be set early and in writing for new board members during the welcome process. Each member should receive a copy of your agency’s Code of Conduct as soon as possible after they join the board or policy council.

ECLKC has put together a sample Code of Conduct document that you can use in your program. As the sample shows, the Code of Conduct document for new board members should includes several key elements.

  • Identify the Policy – A short paragraph identifying the overall expectations for Board and Policy Council conduct.
  • Set out the Procedures – Describe the procedures for amending the Code of Conduct, notifying members, and reprimanding or removing members.
  • Explain the Code of Conduct – Give examples of conduct that is expected, from maintaining confidentiality to following operating procedures set out in the bylaws.

A well-functioning board or policy council means a well-functioning program. By setting the expectations for board members early, you can potentially avoid future problems down the road.

Is your board and policy council trained on codes of conduct? How about the Duties of Care, Loyalty, and Obedience? Contact The Gravely Group for more information on Board Training and take your program to the next level!


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