Title
Approval of Update to Code of Ethics
Office of the General Counsel
end
description
Brief Description:
(Approval of update to Code of Ethics) Recommends approval of the updated Code of Ethics and adoption of the State’s annual gift limit of $630, retroactively applying it as of January 1, 2026.
end
Recommendation
Action Proposed:
1. Approve update to Code of Ethics.
2. Adopt and retroactively apply State’s gift limit ($630), beginning January 1, 2026.
end
Body
Background:
The Ethics Policy Statement and Code of Ethics, established under Board Rule 1900, was initially adopted by the Board of Education in September 1998. It was subsequently revised in December 2000, and again in February 2003.
Expected Outcomes:
As the District advances its mission to ensure students are Ready for the World, it is essential to foster trust among stakeholders and the broader public by providing clear, accessible information that supports informed, engaged, and responsible decision-making at all levels. Accountability requires that all LAUSD officials and partners understand and adhere to the legal requirements and ethical standards governing the nation’s second-largest school district.
The updated Code of Ethics will offer clearer guidance to LAUSD officials regarding standards of conduct related to gifts, conflicts of interest and disqualification, and outside employment. This enhanced clarity is intended to strengthen compliance and promote consistent ethical practices across the District.
Board Options and Consequences:
A “Yes” vote will immediately put into effect the updated Code of Ethics and change the District’s gift limit for all LAUSD Officials to the State’s gift limit of $630 with a biannual increase of $40. It will also retroactively apply the State’s gift limit beginning January 1, 2026.
A “No” vote would leave the current Code of Ethics in place and the District’s gift limit would remain at $100 for the 2026 calendar year and going forward.
Policy Implications:
Approval of the Code of Ethics would also require updates to the following policy documents referencing the District’s gift limit of $100:
• Bulletin 5661.0 <https://my.lausd.net/laserfiche/DocView.aspx?repo=eLibrary&id=145226> - LAUSD Ethics Guide for Holiday and Social Events, Office of the General Counsel, December 5, 2011.
• Reference Guide 055300 <https://my.lausd.net/laserfiche/DocView.aspx?repo=eLibrary&id=150775> - Tax Implications on Employee Receipt of Gift Cards, Tickets, and Other Fringe Benefits, Controller, August 27, 2018.
Budget Impact:
Not applicable.
Student Impact:
Not applicable.
Equity Impact:
Not applicable.
Issues and Analysis:
The proposed update to the Code of Ethics reflects the need to align the Los Angeles Unified School District’s ethical standards with current state guidance and best practices in public governance. Since the last revision in 2003, there have been significant developments in state ethics laws and expectations regarding transparency, accountability, and the acceptance of gifts by public officials.
A key component of this update is the adoption of the State of California’s annual gift limit of $630. Aligning with the state-established threshold promotes consistency between District policy and statewide regulations, reducing ambiguity and ensuring compliance with applicable legal standards. This alignment also supports clearer guidance for reporting and disclosure obligations.
The retroactive application of the $630 gift limit to January 1, 2026, ensures that the District’s policy remains current with the state’s annually adjusted limits and avoids any gap between state requirements and local policy. This approach reinforces the District’s commitment to ethical conduct and minimizes the risk of inadvertent non-compliance.
Additional updates to the Code of Ethics clarify expectations regarding conflicts of interest, acceptance of gifts, and standards of conduct. These revisions are intended to strengthen public trust, enhance transparency in decision-making, and provide Board Members with more explicit guidance in navigating ethical considerations in their official roles.
Overall, the proposed revisions modernize the Code of Ethics, ensure consistency with state law, and reaffirm the Board’s commitment to integrity, accountability, and public service.
The following summarizes the major updates to the Code of Ethics:
• Title
The title has been revised from “Employee Code of Ethics” to “Code of Ethics” to reflect its applicability to all LAUSD Officials.
• Preamble
Revised to incorporate the District’s Ready for the World mission.
• Section 1. Application and Enforceability
Clarifies that the Code of Ethics applies to all LAUSD personnel and Board of Education Members, collectively referred to as “LAUSD Officials,” in alignment with Board Rule 106.(F.).
• Sections 2, 3 and 4
No changes.
• Section 5. Building Workplace Excellence
Includes the following elements: setting the example; fostering an environment of trust, respect, and non-discrimination; providing honest, accurate, and timely information; and identifying problems while contributing to solutions.
• Section 6. Business Integrity
Includes the following elements: objectivity; Cone of Silence; confidentiality in contracting; relationships with contractors or partners; and lobbying disclosure.
• Section 7. Conflicting Interests
Includes the following elements: conflicts of interest; financial conflicts of interest; appearance of impropriety; disclosure and disqualification; and improper influence. This section clarifies that LAUSD Officials are responsible for disclosing potential conflicts and recusing themselves from District decision-making until guidance is provided by the Ethics Office.
• Section 8. Employment Concerns
Includes the following elements: outside employment or activities; LAUSD affiliation; post-LAUSD employment; and upholding LAUSD interests.
• Section 9. Gifts and Travel
Includes the following elements: adherence to gift limits and restrictions on gifts from contractors. The Ethics Office proposes increasing the District’s gift limit from $100 to the State’s current limit of $630, which is adjusted biennially by $40. The District would adopt these periodic increases accordingly. The Ethics Office also recommends applying the State’s gift limit retroactively to gifts received during the 2026 calendar year. This adjustment reflects inflationary considerations. Additionally, this section codifies the Procurement Services Division’s zero-tolerance policy on gifts from District vendors and extends it to LAUSD Officials involved in contracting processes under the Cone of Silence.
• Section 10. Proper Use of Resources
Includes the following elements: use of public resources; appropriate use of LAUSD time; use of public position; and confidentiality.
• Section 11. Reporting Responsibilities and Waivers
Includes the following elements: relationships with students; reporting improper conduct; prohibition of retaliation; and waivers.
Attachments:
Attachment A: Code of Ethics
Submitted:
04/21/26
RESPECTFULLY SUBMITTED, APPROVED & PRESENTED BY:
______________________________ _____________________________
ANDRES E. CHAIT DENEEN COX
Acting Superintendent Deputy General Counsel
Ethics and Compliance Monitoring Legal
Services
REVIEWED BY:
______________________________
DEVORA NAVERA REED
General Counsel
___ Approved as to form.
REVIEWED BY:
______________________________
KURT E. JOHN
Deputy Chief Financial Officer
___ Approved as to budget impact statement.