HomeMy WebLinkAbout2022 Board of Ethics Annual Report
City of Bozeman
Board of Ethics
Report
2022
January 2023
Board of Ethics Report, 2023
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Table of Contents
Board of Ethics Summary ………………………………………………………………. Page 3
Members…..……………………………….……………………………………… Page 3
Support Staff……..………………………………………………………...…… Page 3
Membership Details………………………………………………………….. Page 3
Creation of the Board..……………………………………………………… Page 4
Duties and Responsibilities…………………………………………………Page 4
Requirement of Annual Report ………….………………………………Page 6
2022 Report………………………….…………………………………………………..……Page 7
2022 Ethics Training …………………………………………………………. Page 7
Summary of the Board’s Decisions and Opinions ……….…….. Page 7
Upcoming Recommendations..…………………………………………. Page 9
Board of Ethics Report, 2023
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Board of Ethics Summary
Current Board Members:
Sara Rushing – Chair Term expires July, 2023
srushing@bozeman.net
Melissa Frost Term expires July, 2023
mfrost@bozeman.net
Kristin Taylor Term expires July, 2024
ktaylor@bozeman.net
Support Staff:
Julie Hunter – Executive Assistant Administrative and Recording Services
jhunter@bozeman.net
Mike Maas – City Clerk Administrative and Recording Services
mmaas@bozeman.net
Taylor Chambers – Deputy City Clerk Administrative and Recording Services
tchambers@bozeman.net
Greg Sullivan – City Attorney Legal and Procedural Recommendations
gsullivan@bozeman.net
Membership Details
The Board of Ethics is made up of three members appointed by the City Commission to two-
year terms. Members cannot be city elected officials, city employees, or currently serving on
any other city board or commission.
Board of Ethics Report, 2023
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Creation of the Board of Ethics
2008 Bozeman City Charter
The Bozeman City Charter (the “Charter”) was proposed by the City of Bozeman’s 2004-2006
Local Government Study Commission and was approved by the voters at the November 7, 2006
general election. The Charter became effective on January 1, 2008. The Charter confers certain
powers and restrictions, and prescribes procedures and the City’s governmental structure. The
Charter was created …to secure the benefits of local self-government and to provide for an
honest and accountable commission-manager government. (Preamble, City of Bozeman
Charter)
Section 7.01 (b) of the Charter calls for the establishment of an independent Board of Ethics as
well as the requirement for annual training and education of city officials, board members, and
employees regarding the state and city ethics codes.
Ordinance No. 1726, Creation of the Board of Ethics
To establish a Board of Ethics (the “Board”) as required in the voter approved Charter, the City
Commission adopted Ordinance No. 1726 which provide guidelines for the creation of the
board and other ethics related content required in the Charter. These provisions are codified in
the Bozeman Municipal Code at Chapter 2, Article 3, Division 4 (Sect. 2.03.460 et seq., BMC).
Duties and powers of the Board, who may request board action and the limitations of the
board’s power, are included. In May of 2009, the City Commission adopted Ordinance No. 1759
which amended the original Ordinance. Changes made relating to the board itself were minor.
Board Duties and Responsibilities
Bozeman Municipal Code, Chapter 2, Article 3, Division 4 – Code of Ethics
The Code of Ethics is an important piece of City law. As the declaration of policy section
2.03.460 states, The purpose of this code of ethics is to set forth standards of ethical conduct, to
assist public officials and employees in establishing guidelines for their conduct, to foster the
development and maintenance of a tradition of responsible, accountable and effective public
service, and to prohibit conflict between public duty and private interest.
Following are sections within the Code of Ethics directly related to the Board and a brief
summary of each. Other sections within the Code of Ethics provide additional direction to the
Board and the public in addressing ethical issues and violations.
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Sec. 2.03.580 - Board of Ethics.
This section defines the composition and terms of the Board, requirements for membership,
and lists the support City staff will provide.
Sec. 2.03.600 - Duties and powers of the board.
This section provides details about Board procedures related to meetings, conducting hearings,
and reporting and establishing procedures for administration and implementation of the Code
of Ethics. These duties include:
• Evaluating all aspects of the Code of Ethics to ensure the public and all public servants
have a reasonable opportunity and are encouraged to participate;
• Developing a plan to educate public servants about their rights, duties and
responsibilities;
• Submit an annual report of summary decisions, opinions and recommended actions
regarding ethical practices or policies;
• Arrange for an annual workshop or training program for all employees, elected officials
and board and committee members; and
• Conduct hearings as needed.
Sec. 2.03.610 - Who may request board action.
This section outlines that any person may file a complaint with the Board and further explains
who may request of the Board an ethics opinion.
Sec. 2.03.620 – Limitations on board’s power.
This section explains in detail what limitations are placed on the Board and that the Board may
refer a matter to the city attorney for review.
In addition to the City’s Code of Ethics, the Board has jurisdiction over State of Montana Ethics
laws. These provisions are codified in Title 2, Chapter 2, Part 1, MCA (Sect. 2-2-101, et seq.,
MCA).
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Requirement of Annual Report
The annual report of the Board is a way to inform the public, officials and city employees of
what the Board has accomplished in the past year and report any decisions or opinions.
The Bozeman Municipal Code Sec. 2.03.600 specifically states that the board shall:
4. No later than December of each year, submit an annual report to the city commission
concerning its action in the preceding year. The report shall contain:
a. A summary of its decisions and opinions, both open and confidential; the board
shall make any alterations in the summaries necessary to prevent disclosure of
any confidential information pertaining to any individual or to any organization if
the disclosure could lead to the disclosure of the identity of a person who is
entitled to confidentiality; and
b. Recommend any legislative or administrative actions regarding the city’s policies
and practices which the board believes would or could enhance the ethical
environment in which public servants work.
Board of Ethics Report, 2023
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2022 Year-End Report
2022 Ethics Training
This year’s employee and elected and appointed officials ethics training curriculum was
designed by a Steering Committee made up of City Attorney Greg Sullivan, Executive Assistant
Julie Hunter, City Clerk Mike Maas, Deputy Clerk Taylor Chambers, Human Resources Director
Cassandra Tozer, Human Resources Specialist Eilis Gehle, chief Building Official Ben Abbey,
Streets Operator Andy Caldwell, Fire Captain Josh Charles, Librarian II Sarah Creech, Police
Information Coordinator Wendy Elgin, Urban Renewal Program Manager David Fine,
Community Development Technician Jonathan Fuller, Assistant City Attorney Jen Giuttari,
Assistant City Attorney Kelley Rischke, and Municipal Court Clerk Josie Warren. This team
created realistic ethics scenarios for ethics training. Variations of the training provided
customization for employees and boards. The Board of Ethics approved the curriculum and it
was provided to a team of Ethics Trainers, employees from across the organization, who taught
the course to City employees and Advisory Boards.
The City continues to require new employees and board members to complete ethics training
shortly after hiring/appointment to help familiarize them with the Code and to meet the yearly
training requirement even when joining the organization after the yearly training.
Summary of the Board’s Decisions and Opinions
The Board of Ethics received a formal complaint from Daniel Zyvoloski regarding the City’s
actions related to a group daycare in Bozeman. The complaint was that members of the City
Attorney’s Office acted improperly in their actions regarding compliance of the day care
operation with City regulations. Please see February 7, 2022 Board of Ethics Agenda and the
October 3, 2022 Board of Ethics Agenda.
In response to Mr. Zyvoloski’s ethics complaint the Board of Ethics determined employees of
the City Attorney’s office did not deviate from Standards of Conduct, did not create Conflicts of
Interest, or engage in Improper Government Actions. See the Board’s Findings and Conclusions
dated 3/31/22.
Then, in August of 2022, the Board of Ethics received a request from Daniel Zyvoloski to “issue a
formal opinion” on whether:
Board of Ethics Report, 2023
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[l]t is ethically improper for the Mayor of Bozeman to initiate a closed meeting to
influence a forthcoming vote by the City Commissioners, by stating the purpose 'Issue of
Privacy' with a quorum of City Commissioners and then moving on to discussing no-
related topics with regards to a forthcoming vote that was not within the scope of the
statutorily authorized purpose for which the closed meeting was initially called?
The Board of Ethics again referred the matter to their outside attorney whose analysis
determined the Board should decline to consider Mr. Zyvoloski’s August 11 request for formal
opinion because the matter had previously been addressed by the Board with their decision
from earlier in the year. At the Board’s October 3, 2022 meeting, the Board declined to render
an advisory opinion in response to Mr. Zyvoloski’s August 11 request.
Also, on October 3, 2022, Nick Hamilton submitted a request for a formal opinion similar to the
August request submitted by Mr. Zyvoloski. On October 31, the Board sent Mr. Hamilton a
letter declining to issue a formal opinion.
Video links to the Board’s meetings can be found on the City’s website under Commission
Meeting Video (Past Meetings/Board of Ethics).
Board of Ethics Report, 2023
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Upcoming Recommendations
The Board will work with the City Attorney’s Office and City staff to develop additional training
opportunities for the Board; specifically, the Board requests the development of a mock
hearing to refresh and develop the Board’s management of hearings on complaints.