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Conflict of Interest

Under the Political Reform Act (the "ACT"), all public agencies are required to adopt a conflict of interest code (code). The code designates positions required to file Statement of Economic Interests, Form 700, and assigns disclosure categories specifying the types of interests to be reported. The Form 700 is a public document intended to alert public officials and members of the public to the types of financial interest that may create conflict of interest.

 

Three components of Conflict of Interest Code

1. Terms of the Code
The terms of the code comprise the main body of a code and include such provisions as the manner to report financial interests, the disqualification procedures, etc. The FPPC recommends that agencies incorporate FPPC Regulation 18730 by reference because the type of information required to be in the main body of the code is quite complex and Regulation 18730 contains all of these provisions. The FPPC will amend the regulation to include legislative and regulatory changes that affect the main body of the code; therefore, this component of an agency's code is automatically in compliance with the Act.
2. Designated Positions

The code must specifically list positions that make or participate in making decisions. Typically, positions that involve voting on matters, negotiating contracts, or making recommendations on purchases without substantive review must be included in codes. Positions listed in Government Code Section 87200 (Planning Commissioners, Members of the Board of Supervisors, Chief Administrative Officer, District Attorney, County Counsel, Treasurer/Tax Collector).

3. Disclosure Categories

A primary purpose of the code is to require disclosure of those types of investments, interests in real property, sources of income and business positions that designated positions may affect in their decision-making.


Sample Conflict of Interest Code

For the assistance of those developing or reviewing their Conflict of Interest Code, a Sample Conflict of Interest Code is available below, which may be used as a model.

2018 Biennial Notice


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Stephanie Wellemeyer,
Jul 2, 2018, 5:27 PM
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Stephanie Wellemeyer,
Jul 2, 2018, 5:27 PM
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Stephanie Wellemeyer,
Jul 2, 2018, 5:27 PM
ĉ
Stephanie Wellemeyer,
Jul 2, 2018, 5:28 PM
ĉ
Stephanie Wellemeyer,
Jul 2, 2018, 5:28 PM
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