HomeMy WebLinkAboutItem 6.3 Conflict O fInterest
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CITY OF DUBLIN
AGENDA STATEMENT
CITY COUNCIL MEETING DATE: October 3, 1994
ordinance Amending city's Conflict of Interest
Code
Report by Elizabeth Silver, City Attorney
EXHIBITS ATTACHED: ~haPter 2.24 of Dublin Municipal Code
_(Uraft Ordinance
RECOMMENDATIONM1:> Open Public Hearing
2) Receive Staff Report
'\ 3) Receive Public Testimony
4) Close Public Hearing
5) Deliberate
6) Waive Reading and ADOPT Ordinance
SUBJECT:
FINANCIAL STATEMENT:
None
DESCRIPTION:
Every local government agency is required by the Political Reform Act
to review its Conflict of Interest Code biennially to determine if it
is accurate and up-to-date or alternatively, whether the Code must be
amended.
Since the time of the last amendment to the city's code in June of
1992, a reorganization of the city Manager's Office and Administrative
Services Department has occurred, thereby changing/eliminating certain
job titles. In accordance with clarification from FPPC, the city
Manager and city Attorney positions are being deleted from the city's
Code as these positions are required to file by state Law. Thus, the
city Manager and City Attorney positions would be deleted from the
designated positions list in the city's Code and section 2.24.030
would be amended to delete "Category 1" in the draft Ordinance.
The new position of Economic Development Manager is being added to the
city's Code and the position is being designated as a Category 2
filer.
Additionally, in March of 1994, the Fair Political Practices
Commission adopted Regulation 18720 which applies to those who
exercise responsibility for the management of public investments. For
DUblin, this would be the Administrative Services Director/Assistant
city Manager. While this position is required to file a Form 721, it
is filed with the city Clerk rather than with FPPC.
This is the second reading of a draft Ordinance which was introduced
at the September 12, 1994 city council meeting. Since its
introduction, minor housekeeping type items have also been
incorporated into the amended ordinance. These changes are non-
substantive in nature and therefore do not require reintroduction of
the ordinance.
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Staff recommends that the city council conduct a public hearing, waive
the reading and ADOPT the amended Ordinance.
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ITEM NO. -". 7
COPIES TO:
CITY CLERK
FILE ~
II.
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Chapter 2.24
CONFLICT OF INTEREST
CODE
Sections:
2.24.010
2.24.020
2.24.030
2.24.040
2.24.050
2.24.060
Purpose.
Designated positions.
Disclosure statements.
Place of filing.
Time of filing.
Contents of disclosure
statements.
Acquisition or disposal
during reporting period.
Disqualification.
Manner of
disqualification.
Copies of regulations on
file.
2.24.070
2.24.080
2.24.090
2.24.100
2.24.010 Purpose.
Pursuant to the provisions of Government
Code Sections 87300, et seq., the City Man~
ager of the city, on behalf of Ihe adl1linistra~
tive staff of the city and all consultants,
hereby adopts the following conflict of
interest code. Nothing contained herein is
intended to modify or abridge the provi~
sions of tlle Political Reform Act of 1974
(Government Code Section 81000, et seq.).
The provisions of tllis code are additional to
Government Code Section 87100 and other
laws pertaining to conflicts of interest,
including but not limited to Government
Code Section 1090, et seq. TIle provisions
of the Political Reform Act of 1974 and
administrative regulations promulgated
under authority of said Act by the Fair
Political Practices Commission shall govern
over any inconsistent provisions of this
code. Except as otherwise indicated, tlle
definitions of said Act and regulations
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2.24.010
adopted pursuant thereto are incorporated
herein and this code shall be interpreted in
a manner consistent therewith. (Ord. 18 ~ I,
1982)
2.24.020 Designated positions.
The positions listed below are designated
positions. Officers and employees holding
tllOse positions are designated employees
and, for purposes of the Political Reform
Act of 1974, are deemed to make, or partic-
ipate in the making of decisions which may
foreseeably have a material effect on a fi-
nancial interest.
Designated Positions
City Manager
City Attorney
Assistant City Manager
Planning Director
Public Works Directorl
City Engineer
Administrative Servicesl
Finance Director
Recreation Director
ConsuItants*
Disclosure Category
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2
2
3,4
2
2
2
2
(. Those consuhants which the City Manager determines
are not "consulla.nts" pursuant to the Fair Political Prac-
tices Commission Regulations are not required to file
economic interest sla.lements.)
(Ord. 8~92 ~ 1; Ord. 5-83 ~ 1; Ord. 18 ~ 2,
1982)
2.24.030 Disclosure statements.
Designated positions shall be assigned to
one or more disclosure categories set forth
in tilis section.. TIle disclosure categories
shall be specifically described as set forth
in this section. Each employee or officer
holding a designated position shall file
statements disclosing that employee's or
officer's interests in investments, real prop-
erty, income and positions of management
designated as reportable under the category
to which the employee's or officer's posi-
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(Dublin 8-92)
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2.24.030
tion is assigned at the time, place and in the
manner as hereinafter provided.
A. Disclosure Category 1. No additional
disclosure requirements are imposed by this
Conflict of Interest Code by virtue of Sec-
tions 87200 and 87302(b) of Ule Govern~
ment Code. Notwithstanding tile foregoing,
the provisions of Section 2.24.080 of Ulis
code relating to disqualification are applica-
ble.
B. Disclosure Category 2. Investment in
business entities which are located within,
or do business, plan to business, or have
done business during the preceding two-year
period within the city of Dublin. Interests in
real property located in whole or in part
within the city of Dublin. Sources of in-
come as defined by the Political Reform
Act of 1974, as amended. Business posi-
tions with business entities not otherwise
reported as investments, interest in real
property or sources of income, which are
located within, plan to do business, do
(Dublin 8-92)
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business or have done business during the
preceding two years within the city of Dub-
lin.
C. Disclosure Category 3. Investments
in and business positions held in business
entities, and sources of income which:
1. Have interests in real property locat~
ed in whole or in part within the city of
Dublin;
2. Do business, plan La do business, or
have done business during the preceding
two-year period within the city of Dublin
and which engage in architectural. plaruting.
engineering, construction. building, real
estate development or a related field.
(Business positions need only be reported
if the business entity has not otherwise been
reported as an investment, source of income
or interest in real property.)
D. Disclosure Category 4. Interests in
real property which are located in whole or
in part within the city of Dublin. (Ord. 8~92
~ 2; Ord. 18 ~ 3, 1982)
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2.24.040 Place of filing.
All disclosure statements required by
this code shall be filed with the City
Clerk. (Ord. 18 ~ 4, 1982)
2.24.050 Time of filing.
A. An official or employee holding a
designated position shall submit an ini-
tial statement within thirty (30) days after
the effective date of this code. The initial
statement shall disclose reportable
investments and interests in real prop~
erty.
B. Officers and employees who are .
appointed, promoted or transferred to
designated positions shall file an initial
statement disclosing reportable invest-
ments, interests in real property and posi-
tions of management within thirty (30)
days after the effective date of such
appointment, promotion or transfer to a
designated position.
C. Officers and employees holding
designated positions shall file an annual
statement no later than April 1st of the
next succeeding year. Such annual state~
ments shall cover the period of the pre-
ceding calendar year. The annual
statement shaH disclose such reportable
investments, interests in real property,
sources ofincome, and positions of man-
agement as may be applicable.
D. An employee or officer holding a
designated position who leaves such des-
ignated position voluntarily or involun-
tarily shall file, within thirty (30) days
thereof, a leaving office statement. Such
statement shall disclose reportable
investments, interests in real property,
income and positions of management
held or received at any time during the
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2.24.040
period since the closing date of the pre-
viously fIled annual statement. (Ord. 18 ~
5, 1982)
2.24.060 Contents of disclosure
statements.
Disclosure statements shall be made
on the forms supplied by the City Clerk
and shall contain the fOllowing informa-
tion:
A. Contents of Investment and/or
Real Property Reports. When an invest-
ment, or an interest in real property is
required to be reported under the provi-
sions of this code, the report shaH con-
tain:
1. A statement of the nature of the
investment or interest in real property;
2. The name of the business entity in
which each investment is held, and a gen-
eral description of the business activity in
which the business entity is engaged;
3. The address or other precise loca-
tion of the real property;
4. A statement whether the fair mar-
ket value of the investment or the interest
in real property exceeds one thousand
dollars ($1,000) but does not exceed ten
thousand dollars ($10,000), whether it
exceeds ten thousand dollars but does
not exceed one hundred thousand dollars
($100,000), or whether it exceeds one
hundred thousand dollars ($100,000);
5. For purposes of disclosure under
this code, "interest in real property" does
not include the principal residence of the
filer.
B. Contents of income reports:
1. When personal income or a source
of personal income is required to be
reported, this statement shall contain:
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2.24.060
a. The name and address of each
source of income aggregating two hun-
dred fifty dollars ($250) or more in value
if the income was a gift, and a general
description of the business activity, if
any, of each source,
b. A statement whether the aggregate
value of income from each source, or in
the case of a loan, the highest amount
owed to each source, was at least two
hundred fifty dollars ($250), but did not
exceed one thousand dollars ($1,000),
whether it was in excess of one thousand
dollars ($1,000), or whether it was greater
than ten thousand dollars ($10,000),
c. A description of the consideration,
ifany, for which the income was received
by the filer,
d. In the case of a gift, the amount and
date on which the gift was received,
e. In the case of a loan, the annual
interest rate and the security, ifany, given
for the loan;
2. When the income of a business
entity, including income of a sole pro-
prietorship, is required to be reported by
an employee or officer holding a desig-
nated position, the statement shall con-
tain:
a. The name and address and general
description of the business activity of the
business entity,
b. In the case of a business entity
which provides legal or brokerage serv-
ices, the name of every person who paid
fees to the business entity if the filer's pro
rata share of fees from such person was
equal to or greater than one thousand
dollars ($1,000),
c. In the case of a business entity not
covered by subsection B2a of this section,
the name of every person from who~ the
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business entity received payments if the
filer's pro rata share of gross receipts from
such person was equal to or greater than
ten thousand dollars ($10,000) during a
calendar year.
C. Contents of Management Position
Reports. When management positions
arc required to be reported, officers and
employees holding designated positions
shall list the names of each business
entity not specified above in which they
are a director, officer, partner, trustee or
employee, or in which they hold any
position of management. (Ord. 18 9 6,
1982)
2.24.070' Acquisition or disposal
during reporting period.
In the disclosure statement filed under
Section 2.24.050 C and D, if an invest-
ment or interest in real property was par-
tially or wholly acquired or disposed of
during the period covered by the state-
ment, the date of such acquisition or dis-
posal shall be reported. (Ord. 1897, 1982)
'--../ .
2.24.080 Disqualification.
A. Omcers and employees holding
designated positions must disqualify
themselves from making, participating
in the making, or using their official posi-
tion to influence the making of any deci-
sion in which they have a reportable
financial interest when it is reasonably
foreseeable that such interest might
materially be affected by the decision. No
such officef Of employee shall be
fequired to disqualify himself with
respect to any mattef which could not be
legally acted upon without his participa-
tion.
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B. Notwithstanding the designation of
employees and positions herein, no official
or employee of the city shall make or par-
ticipate in the making of a decision to or
not to license, inspect, permit, contract, cite
or investigate any business or property with
which such official or employee has a fi~
nancial interest. For the purpose of this sub-
section, fmancial interest shall have the
meaning ascribed to it by Section 87103 of
the GoveITUJ1ent Code. (Ord. 18 ~ 8, 1982)
2.24.090 Manner of
disqualification.
An officer or employee holding a desig~
nated position required to disqualify himself
by the provisions of this code shall notify
the City Manager in writing. The City Man-
ager shall fOIWard such notification to the
City Clerk for filing. (Ord. 18 ~ 9, 1982)
2.24.100 Copies of regulations on
file.
Copies of the Political Reform Act of
1974 and administrative regulations adopted
pursuant thereto shall be maintained on file
and available for inspection in the office of
the City Manager. (Ord. 18 ~ 10, 1982)
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2.24.080
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(Dublin 5-94)
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ORDINANCE NO. - 94
AN ORDINANCE OF THE CITY OF DUBLIN
AMENDING CERTAIN PROVISIONS OF THE DUBLIN MUNICIPAL CODE
RELATING TO THE CITY'S CONFLICT OF INTEREST CODE
The city Council of the City of Dublin does ordain as follows:
Section 1. Section 2.24.020 DESIGNATED POSITIONS, TABLE
2.24.020, of the city of DUblin Municipal Code is amended to read
as follows:
Desiqnated positions
Disclosure Cateqorv
Economic Development Manager
Planning Director
Recreation Director
Public Works Director/City Engineer
Consultants*
2
3, 4
2
2
2
(* Those consultants which the city Manager determines
are not "consultants" pursuant to the Fair Political
Practices Commission Regulations are not required to
file economic interest statements.)
Officials Who Manage Public Investments:
It has been determined that the position(s) listed
below manage public investments, are covered by FPPC
Regulation 18720 and should therefore file Form 721.
Administrative Services Director/Assistant City Manager
Section 2. section 2.24.030 DISCLOSURE STATEMENTS, of the
Dublin Municipal Code is amended to read as follows:
Designated positions shall be assigned to one or more disclosure
categories set forth in this section. The disclosure categories
shall be specifically described as set forth in this section.
Each employee or officer holding a designated position shall file
statements disclosing that employee's or officer's interests in
investments, real property, income and positions of management
designated as reportable under the category to which the
employee's or officer's position is assigned at the time, place
and in the manner as hereinafter provided.
A. Disclosure Category 2. Investment in business entities
which are located within, or do business, plan to do
business, or have done business during the preceding
two-year period within the City of Dublin. Interests
in real property located in whole or in part within the
city of Dublin. Sources of income as defined by the
Political Reform Act of 1974, as amended. Business
positions with business entities not otherwise reported
as investments, interest in real property or sources of
income, which are located within, plan to do business,
do business or have done business during the preceding
two years within the City of Dublin.
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B. Disclosure category 3. Investments in and business
positions held in business entities and sources of
income which:
1. Have interests in real property located in whole
or in part within the city of Dublin;
2. Do business, plan to do business, or have done
business during the preceding two-year period
within the City of Dublin and which engage in
architectural, planning, engineering, construc-
tion, building, real estate development or a
related field.
(Business positions need only be reported if the
business entity has not otherwise been reported as
an investment, source of income or interest in
real property.)
C. Disclosure Category 4. Interests in real property
which are located in whole or in part within the city
of Dublin.
Section 3. section 2.24.040 PLACE OF FILING, of the Dublin
Municipal Code is amended to read as follows:
Designated employees required by this code to file disclosure
statements shall file their statements with the City Clerk who
will make the statements available for public inspection and
reproduction. statements for all designated employees will be
retained by the city Clerk.
Section 4. Section 2.24.100 COPIES OF REGULATIONS ON FILE, of
the Dublin Municipal Code is amended to read as follows:
Copies of the Political Reform Act of 1974 and administrative
regulations adopted pursuant thereto shall be maintained on file
and available for inspection in the office of the city Clerk.
Section 5. This Ordinance shall take effect and be in force
30 days following its adoption. The city Clerk of the city of
Dublin shall cause this Ordinance to be posted in at least three
(3) public places in the city of Dublin in accordance with
section 36933 of the Government Code of the State of California.
PASSED, APPROVED AND ADOPTED by the city Council of the city of
Dublin this 3rd day of October, 1994, by the following vote:
AYES:
NOES:
ABSTAIN:
ABSENT:
Mayor
ATTEST:
City Clerk
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