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2017-1292
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Last modified
7/12/2021 10:21:39 AM
Creation date
1/22/2018 1:15:13 PM
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2017-1292
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Opinion Item
Opinion Type
Advisory Opinion
Docket Number
2017-1292
Requesting Party
Emmy O'Dwyer
Decision Date
1/19/2018
Caption
Advisory opinion that the Code of Governmental Ethics would prohibit an Educational Program Consultant with the Early Childhood Division of the Louisiana Department of Education from providing fee-based trainings to early childhood teachers and directors, since the Early Childhood Divisions of the Department of Education regulates early childcare centers. Addiitonally, she would be prohibited from providing strategic planning guidance to early childhood programs at private school based centers because they are licensed by the Early Childhood Division of the Department of Education. However, she would not be prohibited by the W.K. Kellogg Foundation to develop curriculum for the next class of fellows, since the Foundation has no contractual, business, or financial relationship with, and are not regulated by, her agency.
Ethics Subject Matters
Outside Employment
Public Employee - Definition
Prohibited Sources
Payment from Third Parties
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The Board concluded, and instructed me to inform you, that since your agency, the Early Child- <br /> hood Division of LDE,regulates early childcare centers,including private centers,you would be <br /> prohibited from receiving compensation from those centers for training services. <br /> 2. STRATEGIC PLANNING GUIDANCE TO EARLY CHILDHOOD PROGRAMS <br /> You have provided strategic planning guidance to early childhood programs at primarily private <br /> school based centers. These services have included developing a budget for a new program or <br /> implementing a new vision. These private schools are licensed by the Early Childhood Division <br /> of LDE. <br /> The Board concluded, and instructed me to inform you, that Section 1111C(2)(d) (above) would <br /> prohibit you from receiving compensation from private childhood centers for strategic guidance <br /> services, as those centers are regulated by your agency <br /> 3. W.K.KELLOGG FOUNDATION <br /> You recently completed a three year fellowship program with the W.K. Kellogg Foundation. You <br /> have been asked by the W.K. Kellogg Foundation and the Kellogg Foundation Leadership Asso- <br /> ciation to develop curriculum for the next class of fellows. The Leadership Association would <br /> compensate you for your work developing the curriculum. All work would be performed outside <br /> of your normal LDE working hours. You stated that neither the W.K. Kellogg Foundation, nor <br /> the Leadership Association, has a contractual, business, or financial relationship with, or are reg- <br /> ulated by,the Early Childhood Division of LDE. <br /> The Board conduded, and instructed me to inform you, that you would not be prohibited from <br /> receiving compensation from the W.K. Kellogg Foundation or the Leadership Association, as <br /> they have no contractual, business, or financial relationship with, and are not regulated by, your <br /> agency,and all work would be performed outside of your normal working hours with LDE. <br /> This advisory opinion is based solely on the facts as set forth herein. Changes to the facts as pre- <br /> sented may result in a different application of the provisions of the Code of Governmental Eth- <br /> ics. The Board issues no opinion as to past conduct or as to laws other than the Code of Gov- <br /> ernmental Ethics, the Campaign Finance Disdosure Act, the Lobbyist Disclosure Act, and con- <br /> flict of interest provisions in the gaming laws. If you have any questions, please contact me at <br /> (800)842-6630 or(225)219-5600. <br /> Sincerely, <br /> LOUISIANA BOARD OF ETHICS <br /> David M. Bordelon <br /> For the Board <br />
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