Dot Woodfin, the Board President and CEO of The Galloway School engaged in a Q & A session answering questions related to the Houston ISD ethics investigation that found her to have very real conflicts of interest involving the sale of MindOH! character education software to HISD schools while she was an employee of the HISD and also owning a significant stake in the company selling MindOH! software. TGS Watch provides some of Ms. Woodfin's statements.
Dot Woodfin Admits Ethical Violation
Ms. Woodfin outright agrees that she violated a conflict of interest provision in a state statute. Ms. Woodfin seems to be under the impression that her ignorance of the ethical standard means that there was no violation of the standard.
Q: Do you agree that [HISD's] finding that there is a conflict of interest in violation of the statement government code was wrong ...
Ms. Woodfin: Had I had knowledge of the protocol of this policy, I would agree ...
Q: Which protocol are you talking about? Standard Practice Memorandum 4168?
Ms. Woodfin: The one that you're speaking of here, which I -- if a person owns 10 percent or more of the voting stock or shares of a business entity, prior to this, I had no knowledge of that.
This ethical violation relates to Ms. Woodfin's 12% ownership in a company named MindOH! LLC. While Ms. Woodfin was an HISD employee, this company earned nearly $200,000 in revenue from the school district. HISD investigators determined that this was a conflict of interest. We are shocked to see Ms. Woodfin suggest that her ignorance of this ethical standard is a mitigating factor.
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Dot Woodfin Fails to Comply with Houston Independent School District Standards
Below are several examples of HISD standards that Ms. Woodfin failed to comply with:
HISD Standard:
"If an administrative employee of HISD or a member of his or her immediate family is an officer, agent, or a member of or owns a substantial legal or beneficial interest in any corporation, firm, partnership or other business entity doing business with HISD or its affiliate organizations, he or she shall file a sworn statement with the HISD Board of Education Secretary disclosing such interest."
Ms. Woodfin admits she never filed the required statement:
Q: Did you ever file a sworn statement with the HISD Board of Education Secretary disclosing your interest in MindOH!?
Ms. Woodfin: No.
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HISD Standard:
"It is strongly suggested for the protection of the administrator that any administrator having any interest, regardless of how small, seek written clarification concerning possible conflicts of interest."
Again, Ms. Woodfin admits that she didn't seek the recommended clarification of this HISD Standard:
Q: Is it true that you never sought written clarification concerning your possible conflict of interest between your involvement in MindOH! and your position at HISD?
Ms. Woodfin: Yes.
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HISD Standard:
"It is recommended that any administrative employee in doubt about a potential conflict of this nature [transactions with other entities in which the employee has a position or interest] seek written clarification concerning any transaction or potential transaction which might create a conflict of interest."
You get the idea. Ms. Woodfin admits she didn't bother to get this clarification either:
Q: It's true that you never sought written clarification concerning any transaction or potential transaction with MindOH! with respect to whether it might create a conflict of interest?
Ms. Woodfin: Yes.
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Ms. Woodfin Doesn't Understand Accountability Systems
Long after Ms. Woodfin was in the eye of the metaphorical ethical storm that culminated in an unflattering article in the Houston Chronicle, Ms. Woodfin still did not understand the ethical standards HISD accused her of violating. This lack of knowledge suggests to TGS Watch that Ms. Woodfin had little interest in learning about the ethical standards.
Ms. Woodfin: I don't understand these [HISD ethics] circulars, the Accountability System, the Texas Local Government Code, Section 16 of the Special Act of 1923 because I do not know what those state.
TGS Watch believes that the Houston Independent School District is a professional organization. We've got to believe that HISD offers ethics training to its employees. Regardless, most ethical standards are common sense. We can't imagine that anyone could fail to see the MindOH! transaction as ethically dubious.
1 A good employee will know when s/he is approaching the boundaries of unethical conduct and will seek clarification and advice. Ms. Woodfin seems to have a strange lack of curiosity about the ethical standards she was subject to.
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TGS Watch is utterly amazed that not only did Ms. Woodfin fail to provide required disclosures and other clarifications, she seems to have no interest at all in ethical standards. We can only hope that things have changed at The Galloway School and that there aren't any related-party transactions between the school and Board Members / Administrative Staff. What are the chances that Ms. Woodfin even bothered to learn the Conflict of Interest policy at TGS?
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1 Ms. Woodfin's role in the MindOH! scandal at HISD reminds TGS Watch of the
corrupt acts of Andrew Fastow leading up to the collapse of Enron. Mr. Fastow was an employee of Enron Corp. and the General Partner of LJM2, Co-Investment LP. Fortunately, under Superintendent Abe Saavedra, HISD was far more sensitive to corruption in 2004-2005 than Enron was in 2001.