Q&A: Creating a Code of Ethics & Sample

The October 2017 issue of SN focuses solely on ethics—workplace ethics, no less. The topic is such an important one and so oft misunderstood that, not only did we dedicate an entire issue to the subject and a 19-page main feature to its study, but we have also provided you with these bonus extras. In the pages of the highly instructive main feature, titled “Got Ethics in the Workplace?” Toni Vega Aiken, SNA senior program manager; Christina Uticone, SN contributing editor; and Patricia Fitzgerald, SN editor suggest writing and keeping an on-staff Code of Ethics. First, read the below Q&A between SN and Stephanie Bruce, director of nutrition services, Palm Springs (Calif.) Unified School District. Bruce’s interview will take your through the ins and outs of writing an all-important, all-encompassing Code.

Then, click to read the actual PSUSD Nutrition Service Code of Conduct in its final form to elicit ideas and plans for your own Codes.

SN Magazine: How did you go about writing the Code of Ethics?

Stephanie Bruce: Writing the Code of Ethics was definitely a collaborative effort. The county I work in (Riverside County) has a diverse and amazing group of directors that get together on a quarterly basis and bounce ideas off of each other constantly. Our own mental health support group! When we all had to develop a strong Code of Ethics, we started by bringing what was in current board policy. Many of us discovered that the Code of Ethics in other districts only covered the Board Members and Cabinet-level positions. We reached out to even more districts and used several examples and looked to the requirements from USDA and drafted Codes together. I then took what I had and brought it to my staff where we then discussed all aspects and then edited the document to fit our environment. The process was a great moment to educate and train my staff on what ethics is and how we can change our practices and behaviors at all levels.

SN Magazine: Why did you go about writing the Code of Ethics?

SB: Part of it was this whole spotlight on procurement, and the fact that we weren’t doing everything we were supposed to be doing. It was necessary, for us, to be able to have a relationship with our vendors that was professional. For a long time, things have been done with a wink-and-a-nod, and while I think we’ve gone through our due diligence and gone through the proper steps, I don’t think we were doing it well enough.

Here in California, our Department of Education was coming down hard on steps and things to have in place, and one was a Code of Ethics. My last review year was the 2015-16 school year, and we all had to have one in place by January 1, 2015.

SN Magazine: Who worked on this with you—who was on your ethics“team”?

SB: Myself and a former foodservice director, Harold Sullins; he was the director at Hemet Unified. He is a dynamo! If something was coming down the pike, he was always the first one to get something written and put together. He was the first person I reached out to and said, “Help!” because I didn’t even know where to start. He showed me a couple of things he had done, and we took them to our Riverside County directors meeting. We took it upon ourselves to put together these meetings for networking and to help solve issues, because we’re all in the same boat. We asked, “what is everyone doing?” and it kind of started the conversation. We all started adding things to our documents. What I sent you (the linked Code above) is what Harold had started, and then I added to it and Bob Quanstrom—he’s a director at Val Verde Unified—he added some things, and some of it we took from our own board policies. The majority we took directly from the Code of Federal Regulations (CFR), the guidance we got from USDA.

SN Magazine: Can you describe the writing process?

SB: We had a little skeleton of things, things we needed to put in it. Then we just bounced ideas off of each other. Under the Code of Conduct, that first bullet point, reads: “No employee, director, or agent, of the Palm Springs Unified School District Nutrition Service Department shall participate in the selection, award, or administration of a bid or contract supported by federal funds if the conflict of interest is real or inherent to a reasonable person.” That was something we never really had in writing in any of our documents, so we would take these little statements, right out of the CFR, and had a discussion. “What does that mean?” “How does that look?” And we all shined mirrors on ourselves, and looked at each other and laughed. Just going to lunch can look like a conflict of interest. Accepting a gift at a conference. All sorts of things, and our heads were spinning—everything we’re doing is unethical! Some of us decided we were going to put together this Code of Conduct and live by it and others were like, “I have enough to do.” It’s the right thing to do, but the reality is that our jobs are getting so complicated. I was just happy to get mine done! The beauty of our group is that we are a support system. It’s been helpful.

SN Magazine: Did you encounter any unusual or unexpected results?

SB: We had a district here in Southern California, where I live—a big district with a longtime director who did a wonderful job. We receive rebates in the form of gift cards from vendors, and none of us really thought that was bad—but we all realize why it is—and over the years having collected all of these gift cards she decided to do an end-of-year celebration to show appreciation for her staff, and she did a lottery for the gift cards. That turned into a federal investigation into misappropriation of funds. She had a disgruntled employee who filed a complaint, so she had a full audit and then she had federal investigators come out and audit all the books. She was at the end of her career and getting ready to retire—she was going to retire that next year, but because of everything that happened her boss and the board said, “You can’t retire in the middle of this, it’s going to look like you’re running from the problem” so she ended up having to work another four years while going through the process.

When a director thought she was doing something nice for her employees, it turned out not-so-great—those items should have been used to put the benefit back into the program. The employee that complained was one of many who didn’t get a gift card and that started the complaint; it ended up with a civil rights complaint going through USDA. That was an unexpected consequence of all of this, because it happened right around the time that we all had to write these Codes of Ethics.

SN Magazine: Can you talk about some of the systemic changes that resulted from writing a Code of Ethics?

SB: Once we got the document together, I worked with my management team and used it as a way to train all of them not just on proper ethics, but proper etiquette and professionalism; how to conduct ourselves, not just when we’re at a school site but when we’re in meetings with vendors, when we’re out at conferences.

One change we made was that before, vendors could bring in whatever they wanted, bring everything, offer the world to us, and it was taking up a lot of our time. We now do four vendor days a year. Vendors can schedule the time—vendors get the same amount of time as everyone else, so no one can say I’m favoring any one vendor—and we tell them what we’re looking for, and they bring us what they think we’re looking for or new items. I invite several districts, so we have six or seven districts here which helps that we’re all kind of on the same page, and hearing the same thing.

Also, how we handle things at conferences. One of the hardest things for my staff to hear was that if they entered a raffle or contest at a conference that the district paid for you to attend, then whatever you win goes back to the district not to you. That was a difficult thing for them to hear. It was hard in the beginning but as we’ve worked through it, they’re all grateful to have that to rely on when they don’t want to be put in a situation that could be misconstrued as inappropriate. It’s actually helped protect them.

SN Magazine: What advice do you have for school nutrition professionals based on your experience writing a Code of Ethics?

SB: Find out what your current board policy is, and I would take the section on the CFR that talks about the Code of Conduct portion, and I would also look at what your state requires, because all three might be different.

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