Press Release  Former Greater New Bedford Voc-Tech Guidance Director Heather Larkin Pays $10,000 Civil Penalty for Violating Conflict of Interest Law

Boston, MA — Dr. Heather Larkin, former Director of Guidance and Pupil Personnel Services at Greater New Bedford Regional Vocational Technical High School (GNBVT), has paid a $10,000 civil penalty for violating the conflict of interest law by contracting with her friend and business partner to provide services to the school, using the school’s resources to promote her private business event, and through other actions. Larkin signed a Disposition Agreement in which she admitted the violations and waived her right to a hearing.

In 2021, Larkin developed a friendship with a professional mental performance coach for athletes, referred to in the Disposition Agreement as “the Consultant.”  In January 2022, as Guidance Director, Larkin drafted and signed a $10,000 contract for the Consultant to provide a mental performance coaching program to GNBVT student-athletes from January through June 2022, then approved payments to the Consultant. As Guidance Director, Larkin participated in selecting students to attend the Consultant’s program, including Larkin’s son.

In March 2022, Larkin founded a private business, All In Consulting and Mental Performance Coaching, LLC. The following month, Larkin and the Consultant formed a business partnership to share costs and anticipated profits from a mental performance summit they planned to co-host in August 2022. At Larkin’s request, GNBVT’s Athletic Director sent an email promoting the summit to a listserv of approximately 500 student-athletes and/or parents. Larkin posted photos of GNBVT student-athletes in their school uniforms on the All In Instagram account promoting the summit. She also posted flyers promoting the summit on the official GNBVT Guidance Department Instagram account, which she managed.

After forming the private business partnership with the Consultant to co-host the summit, Larkin, as GNBVT Guidance Director, drafted and signed a new contract to renew the mental performance coaching consultant’s services with the school. The new contract doubled the Consultant’s fee to $20,000.

Larkin was placed on leave from GNBVT on June 15, 2022. Larkin and the Consultant co-hosted the mental performance summit on August 3, 2022, for which they did not charge the previously planned entrance fee and from which they did not earn a profit. Larkin resigned from GNBVT in June 2023.

The conflict of interest law prohibits municipal employees from participating officially in matters in which they, their immediate families, or business partners have a financial interest. Larkin violated this prohibition by, as GNBVT Guidance Director, contracting with and approving payments to her business partner, the Consultant.

The conflict of interest law also prohibits public employees from using or attempting to use their official positions to obtain valuable privileges or benefits for themselves or others that are not properly available to them. Larkin violated this prohibition by using her GNBVT Guidance Director position to promote her private business event through the use of the school’s student-athlete listserv, the GNBVT Guidance Department Instagram account, and images of GNBVT student-athletes in their school uniforms.

Additionally, the conflict of interest law prohibits public employees from acting in a manner that would cause a reasonable person to conclude that they can be unduly influenced by anyone or are likely to act with favoritism toward anyone in their official actions. Larkin violated this prohibition by participating as GNBVT Guidance Director in contracting with her personal friend, the Consultant, and by participating in her son’s selection to participate in the Consultant’s program. Larkin did not disclose her personal connections to either matter to the Superintendent before participating.

The Commission encourages public employees to contact the Commission’s Legal Division at 617-371-9500 for free advice if they have any questions regarding how the conflict of interest law may apply to them.

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