Employee Standard of Conduct Policy Number and Last Update
(01.02.03/02-2008)

Policy

The highest standards of conduct among public-service employees are essential to uphold the public trust and fulfill the obligation to the clients. Processes of the Head Start Agency are to be conducted with transparency and accountability.

Procedures

The requirement to comply with these standards of conduct is a condition of employment or participation in the Migrant and Seasonal Head Start Agency. Employees or officers who fail to comply with these standards may be subject to disciplinary action up to and including dismissal.

Confidentiality

Employees and officers must exercise the strictest confidentiality regarding information pertaining to a procurement process. Examples include useful information about bids and proposals, plans to evaluate responses and results of evaluations. Caution and discretion in handling confidential information extends to disclosure made inside and outside the agency, and continues to apply after the relationship ceases.

Confidential information that employees or officers receive through the procurement process must not be used by an employee or officer for the purpose of furthering any private interest, or as a means of making personal gain.

Prohibited Political Activities

No officer or employee shall intentionally perform any prohibited political activity during any compensated time, or use any property or resources of the Head Start Agency in connection with any prohibited political activity.

Gift Ban

No officer or employee, and no spouse of or immediate family member shall intentionally solicit or accept any gift, gratuity or favor from any person or entity who is seeking official action by the agency, does business or seeks to do business with the agency, or receives Head Start services from the Agency.

Conflict of Interest

No officer or employee shall, in the performance of official duties, give preferential treatment to an individual, corporation, or organization, in which the employee, officer, or a relative or friend of the employee or officer has an interest.

No employee or officer shall allow a contractor to participate in the development of a request for proposals and subsequently submit a proposal to the solicitation.

No officer shall receive compensation for serving on the Board of Directors or for providing services to the Head Start Agency. No officer nor member of his immediate family shall be employed nor compensated by the Head Start Agency. The Agency shall not employ or compensate any immediate family member of an employee or officer who can influence hiring and termination decisions. Immediate family means spouse, son, daughter, son-in-law, daughter-in-law, father, mother, or grandchild.

No officer or employees shall use agency property or the employee's position, office, or affiliation to pursue personal interests.

Reports of Wrongdoing

All employees and officers of the Agency have a duty to report possible wrongdoing or suspected violations of applicable Federal and Stare laws and regulations. The Agency will not retaliate or discriminate against any employee or officer who makes a good-faith report of a suspected violation regarding the observed conduct or actions by another person. It will be a violation of this program to make a report of a suspected violation that is knowingly false.

Reports of suspected violations should be made to the Illinois OIG hotline at (800) 368-1463 or the U.S. Department of Health and Human Services ACF Fraud Alert hotline at (888) 289-8442.The call will not be traced, and the caller need not give his or her name.

Audits and Investigations

If an employee or officer is contacted by a government investigator or auditor, the employee or officer shall fully and appropriately cooperate.

It is the policy of the Agency to courteously receive and investigate complaints concerning its processes, employees, or officers.

Complaint

A person desiring to make a complaint which alleges one or more of the following: an infraction of rules, regulations, or policies, or an illegal act, may contact any Agency employee or officer, or any employee of the Illinois Department of Human Services Migrant and Seasonal Head Start and will be furnished the name and address of the Chairperson of the Board of Directors of the Agency, the Chief of the IDHS Office of Child Care, and the ACF Migrant & Seasonal Branch Grants Officer.

Persons complaining orally or by e-mail will be requested to submit their complaint in writing with their signature affixed. A person refusing to make a written complaint or who makes an anonymous complaint does not necessarily prevent an investigation from being initiated on the facts provided, but does cause the mater to be more difficult to process to an effective conclusion.

Upon receipt of a complaint, the Chairperson of the Board will send a notification, in Spanish and English, to the President of the Policy Committee and the IDHS Migrant Head Start Director of the nature of the complaint. The Chairperson of the Board will also notify the complainant that his or her complaint is to be investigated and that he or she will be given time on the agenda of the Board of Directors' meeting to discuss in detail the allegations made. A copy of the complaint shall be sent to the subject by certified mail with return receipt within three (3) days.

Investigation

A combined meeting of the Board of Directors and the Policy Committee will hear the complaint. All member will decide whether the matter can be resolved immediately, and if so, what actions to take. Or, if necessary, they will appoint a joint committee to investigate the complaint within fourteen (14) days.

The committee investigation shall include:

  • Contacting the complainant (when at all possible) to fully discuss the complaint;
  • Contacting the accused employee or party to fully discuss the allegations;
  • Contacting all witnesses as necessary or available;
  • Obtaining all known relevant legal evidence or other documents to support or refute the allegations;
  • Submission of a report to the Board of Directors, Policy Committee, the complainant, the subject, and IDHS Migrant & Seasonal Head Start program at the final conclusion of the investigation.

At the conclusion of the investigation, the Committee shall either: (1) Dismiss the complaint; or (2) Find a violation of the Standards of Conduct of the Agency. The Board of Directors and Policy Committee shall determine the discipline to the alleged violator and any redress to the complainant, IDHS, or U.S. Department of Health and Human Services, that is appropriate.

If an existing real or apparent conflict of interest id discovered, the Board and Policy Committee shall take action to correct it within ten (10) days. If a conflict of interest is found to have occurred in the past, the Board will take appropriate action, if any, and impose discipline against an employee or officer. The Board may seek legal counsel as necessary.

For other breaches of the Standards of Conduct, the Board and Policy Committee will take such action as they see fit, up to and including dismissal or an officer or employee. If a formal complaint is sustained against an employee, the employee has the right to appeal that decision and/or the discipline imposed, through the staff grievance procedure of the Agency.

Findings of alleged violations of criminal codes by officers or employees of the agency shall be referred to the State's Attorney.

A full report of the complaint and resolution shall be submitted to Policy Committee and the IDHS Migrant & Seasonal Head Start office within five (5) days of the conclusion of the investigation.

WHISTLE-BLOWER PROTECTION

Protected Activity

If a person wishes to report an unethical action by a State of Illinois or Head Start employee, please call the Office of the Inspector General hotline at (866) 814-1113. They do accept anonymous reports.

An officer, administrator, or supervisor shall not take any retaliatory action against an employee because the employee does any of the following:

Discloses or threatens to disclose to a supervisor or public body, an activity, policy, or practice of any officer, administrator, or employee that the employee believes is in violation of a law, rule, or regulation; or

Provides information to or testifies before any public body conducting an investigation, hearing, or inquiry into any violation of law, rule, or regulation by any officer, administrator, or employee.