HomeMy WebLinkAboutFinal Adoption of Ordinance 1856, Code of Ethics revisions, conflicts and post employment
Staff Memorandum: Final Adoption of Ordinance 1856 Page 1 of 6
Commission Memorandum
REPORT TO: Honorable Mayor and City Commissioners
FROM: Aimee Brunckhorst, Deputy City Clerk
Board of Ethics
(Chris Carraway, Melissa Frost and Mary Jane McGarity)
SUBJECT: Final adoption of Ordinance 1856, amending the Bozeman
Municipal Code (Code of Ethics) Sections 2.03.520 (clarifying
standards for conflicts of interest), 2.03.560 (clarifying provisions
related to post employment activities) and 2.03.570 (regarding
disclosure of post employment activities).
MEETING DATE: April 22, 2013
AGENDA ITEM TYPE: Consent
RECOMMENDATION: Finally adopt Ordinance 1856.
RECOMMENDED MOTION: I move to finally adopt Ordinance 1856, amending the Bozeman Municipal Code Sections 2.03.520 (clarifying standards for conflicts of interest),
2.03.560 (clarifying provisions related to post employment activities) and 2.03.570 (regarding
disclosure of post employment activities).
BACKGROUND:
The City Commission provisionally passed this Ordinance on April 8, 2013 with several
amendments to the proposed Ordinance draft. Click here for a link to the audio of this discussion.
These amendments are highlighted in yellow on the attached Ordinance and include: (i) moving subsection F of Section 2.03.520 to the beginning of the section (now numbered as
subsection A);
(ii) adding a reference to what is now 2.03.520.A to 2.03.520.C.2; and (iii) to change from no less than ten (10) days to no less than six (6) days the time period in
which a former public servant must file a formal notice prior to a formal or informal appearance
or be restricted in the appearance to only a duly notice public meeting.
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Staff Memorandum: Final Adoption of Ordinance 1856 Page 2 of 6
HISTORY:
In 2009, the Board of Ethics (the “Board”) began examining several provisions of the City’s
code of ethics that City Attorney Greg Sullivan and board members felt were in need of review and possible amendment. During that review, the City Commission requested that the board and staff also draft whistle blowing and anti-retaliation provisions. The Board decided to bring to the
Commission both the changes they were suggesting to the conflict of interest and post
employment activities sections and the Commission requested amendments for whistleblowing at
the same time. During their November 18, 2009 board meeting, the Board voted unanimously to recommend that the Commission approve Ordinance 1775. While the City Commission adopted Ordinance 1775 adding whistle-blowing and anti-retaliation provisions to the code,
recommended edits to the conflict of interest and post employment provisions were set aside.
The City Commission then asked that the Board further review the conflict of interest and post
employment provisions and bring the edits back to them at a later date.
After handling a number of time sensitive projects, in 2012 the Board again spent considerable
time re-examining the code of ethics related to conflicts of interest and post employment. They
also met with prior City Commissioner Jeff Rupp and past Planning Board member Chris
Budeski to gain insight from people that had experience dealing with this portion of the code of ethics. The Board refined several of the original recommended amendments and, with assistance
from staff, a new Ordinance was drafted reflecting these final recommended amendments
Through the passage of Resolution BOE 2013-01 on February 19, 2013, the Board unanimously
voted to recommend that the City Commission make the suggested revisions to the conflict of
interest and post employment activities provisions within the code of ethics by adopting Ordinance No. 1856.
The Board has looked to the City Charter throughout the amendment process to provide
overarching guidance regarding the intent behind the City’s code of ethics. The ultimate goal of
the Charter and the creation of the code of ethics is transparency to achieve trust among the citizenry. In fact, the Bozeman Charter (Sect. 7.01(a)) establishes specific ethical principles that
are required to be addressed by ordinance as can be seen in the following Charter provision:
“The use of public office for private gain is prohibited. The Commission shall implement this prohibition by Ordinance the terms of which shall include but not be limited to: Acting in an official capacity upon matters in which the official has a private financial interest clearly
separate from that of the general public; to the acceptance of gifts and other things of value;
acting in a private capacity on matters dealt with as a public official; the use of confidential
information; in the appearances by city officials before other city agencies on behalf of private interests. This Ordinance shall include a statement of purpose and shall provide for reasonable public disclosure and finances by officials with major decision making authority
over monetary expenditures and contractual and regulatory matters.”
Below we provide a listing relating the Charter requirements with the sections of the code of
ethics that implements each Charter provision. For example, the Charter states the use of public
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Staff Memorandum: Final Adoption of Ordinance 1856 Page 3 of 6
office for private gain is prohibited. Below that requirement, we provide sections of the code of
ethics that we feel implement the Charter statement.
Bozeman City Charter, Section 7.01(a):
1. The use of public office for private gain is prohibited.
a. 2.03.520.A, B, C (Conflict of Interest)
b. 2.03.560.A (Post employment activities)
2. Acting in an official capacity upon matters in which the official has a private
financial interest clearly separate from that of the general public.
a. 2.03.520.A, B, C, D, E (conflict of interest)
b. 2.03.560.A (post employment activities)
3. Acting in a private capacity on matters dealt with as a public official.
a. 2.03.520.A, F (conflict of interest)
b. 2.03.560.A (post employment activities)
4. The appearances by city officials before other city agencies on behalf of private
interests.
a. 2.03.520.A, B, C, D, E (conflict of interest)
b. 2.03.560. A (post employment activities)
c. 2.03.570 (post employment activities)
5. Provide for reasonable public disclosure and finances by officials with major
decision making authority over monetary expenditures and contractual and
regulatory matters.
a. 2.03.560.A (post employment activities)
b. 2.03.570 (public notice required)
Ordinance 1856:
Many of the proposed amendments included in Ordinance 1856 are not substantive but are meant to resolve inconsistencies, clarify and make parallel language, create definitive procedures for
public notice, and make clear the interaction between the city’s ethics code and the state’s ethics
laws.
A detailed description of the proposed amendments per section is as follows:
A legislative intent section is added to the beginning of Ordinance 1856 providing an overview
of the amendments to the municipal code as drafted in Ordinance 1856.
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Staff Memorandum: Final Adoption of Ordinance 1856 Page 4 of 6
Section 3: This section of the ordinance proposes to reorganize and clarify 2.03.520. Conflicts of Interest. In addition to reorganizing the provisions for clarity, the proposed changes to this section include:
• Clarifying that the only officials who may participate in an action on a matter
when a conflict of interest exists are the City Commissioners and only as authorized by Montana statute (see Sect. 2-2-121(10), MCA). See proposed new subsection G (after provisional adoption, now H) to 2.03.520.
• Creating new subsection (H) (after provisional adoption, now I) clarifying the
relationship between state law and the city’s Code of Ethics. The proposal would
make it certain the provisions of the city’s Code of Ethics regarding conflict of interest do NOT absolve any official or employee from complying with Title 2, Chpt. 2, MCA. That is, employees and officials are legally required to abide
by BOTH state law and the city’s ethics code. The proposed subsection continues:
“If any provision of this section is in conflict with Title 2, Chpt. 2, MCA the more
stringent provision, the provision that requires greater disclosure, or the provision that provides less authority to act in furtherance of a conflict, shall apply.”
• Proposing a new subsection (I) (after provisional adoption, now J) that indicates
the disclosure requirements of Sect. 2-2-131, MCA, must be adhered to when an
employee or official takes an act under this section and when disclosure of that act will be required by law. As you will note, this new subsection is written broadly. The intent is to have employees and officials consult directly with the
City Attorney to determine: (i) whether a conflict exists; (ii) whether they are
permitted to act, if at all; and (iii) what steps are legally required if the employee
or official is authorized to act.
• Amending what is labeled as new subsection (F) (amendment at provisional adoption moved this subsection to the beginning of the section moving all
subsections down (new A) to indicate employees or officials are not precluded
from bringing before an agency of the city or the Commission a matter that affects
their own individual legal rights. While newly labeled subsections A (after provisional now B), B, (after provisional now C) and C (after provisional now D)
effectively prohibit an employee of official from engaging in any action where a
conflict of interest exists between their personal interests and those of the city,
this newly labeled subsection does allow a person to do so BUT ONLY IF the
matter is of a strictly personal interest. The employee or official doing so must still comply with all other provisions, including disclosure and a separation of
their official duties from their personal interest. Examples may include a
circumstance where an employee is a member of a home owners association and
must present an application or issue before the City Commission. The employee
may do so dependent upon compliance with all the requirements of this section. A second example would be when a member of the planning board applies for a
certificate of appropriateness for a remodel to their own home. Complying with
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Staff Memorandum: Final Adoption of Ordinance 1856 Page 5 of 6
all other provision of the Code of Ethics, the planning board member may present
their application before the city.
Section 4: In addition to reorganizing this section for clarity, proposed amendments to Section 2.03.560. Post Employment/Service Activities include:
• Adding the word Service to the section title to clarify that this provision includes
not only employees, but elected and appointed officials as well.
• Removing the wording “for compensation” from (A)(2) ensures that this
provision applies even when compensation is not provided.
• Separating (B) from the list of actions prohibited within 12 months post
employment ensures that former public servants cannot use their former title, etc. at any time.
• The addition of (C) makes certain the standards in this section work in concert
with post-employment prohibitions found in state law and clarify the more
stringent provision applies. Section 5: This section of the proposed ordinance was identified by the Board of Ethics
and staff as important in order to clarify under what circumstances and through which
process a former public servant could override the prohibitions found in 2.03.560.
Proposed amendments to Section 2.03.570. - Public notice required for former public servants/compliance with State law include:
• Adding the words “for former public servants/compliance with State law” to the
section title to further clarify the purpose of this section.
• Makes it clear in subsection (A) the only acts a notice can override are those listed in 2.03.560(A) These acts are: (1) “… make any formal or informal appearance
before, or negotiate with, any decision maker regarding a transaction or matter
which was under the former public servant's direct responsibility or which the
former public servant participated personally and substantially; or (2) represent or act or appear on behalf of an individual or entity other than the city in connection
with a transaction or matter which was under the former public servant’s direct
responsibility or which the former public servant participated personally and
substantially as a public servant.”
• The proposed changes also indicate a procedure a former public servant must go through to make the notice effective including providing notice no less than ten
six (amended at provisional adoption) days prior to the meeting and posting by
the clerk on the city’s website.
• The proposed amendments in subsection (B) also allow for relief from the ten day requirement: “A former public servant… who cannot reasonably meet the ten (10)
six (6) (amended at provisional adoption) day notice period… may appear before
a decision maker only at a duly noticed public meeting where a formal record of
the proceedings is made. At the time of doing so, the former public servant shall comply with subsection (A) of this section.” The intent of subsection (B) is that it directly applies to meetings between a former public servant and a decision maker
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Staff Memorandum: Final Adoption of Ordinance 1856 Page 6 of 6
that are to be formally noticed. For those types of meetings, a former public
servant may appear regardless of the time constraints of subsection (A) but only
where the meeting meets the criteria and includes a requirement that a written
statement will still be provided.
• Finally, like other provisions where a potential conflict exists between the
standards in state law and the city’s Code of Ethics, the addition of subsection (C)
makes it clear that if a conflict exists, the more stringent standard applies. The
result may be that while the city provision may allow a former public servant to provide notice and override the prohibitions on acting, state law may not. FISCAL EFFECTS: None foreseen at this time.
ALTERNATIVES: As suggested by the City Commission. Attachments: Revised Ordinance 1856
Report compiled on: April 10, 2013
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Ordinance 1856
Page 1 of 8
ORDINANCE NO. 1856
Final Adoption 4/22/13
AN ORDINANCE OF THE CITY COMMISSION OF THE CITY OF BOZEMAN,
MONTANA, AMENDING BOZEMAN MUNICIPAL CODE SECTIONS 2.03.520
CLARIFYING STANDARDS FOR CONFLICTS OF INTEREST, 2.03.560 CLARIFYING
PROVISIONS RELATED TO POST EMPLOYMENT ACTIVITIES, AND 2.03.570
REGARDING DISCLOSURE OF POST EMPLOYMENT ACTIVITIES.
WHEREAS, the City of Bozeman Board of Ethics, at a duly noticed meeting, via the
approval of Board of Ethics Resolution 2013-01 passed a recommendation to the Bozeman City
Commission that the Commission adopt this ordinance.
NOW THEREFORE, BE IT ORDAINED BY THE CITY COMMISSION OF THE
CITY OF BOZEMAN, MONTANA:
Section 1
Legislative Intent.
1. The City Commission intends that amendments within this ordinance to 2.03.520
(conflict of interest), in addition to minor changes for reorganization, clarify that the only
officials who may participate in an action on a matter when a conflict of interest exists
are the City Commissioners and only as authorized by Montana statute. Additional
amendments to 2.03.520 clarify the duties of an employee or official should a conflict of
interest exist and the relationship between state law and the city’s Code of Ethics.
2. Amendments to 2.03.560 (post employment activities) make certain the standards in this
section work in concert with post-employment prohibitions found in state law and clarify
the more stringent provision or the provision that requires greater disclosure, applies.
3. Amendments to 2.03.570 (public notice) clarify under what circumstances and through
which processes a former public servant could override the prohibitions found in
2.03.560. The new procedures enhance transparency and accountability to the public.
This section also clarifies that if a conflict exists between the standards in state law and
the city’s Code of Ethics, the more stringent standard applies.
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Ordinance 1856
Page 2 of 8
Section 2
That the table of contents of Chapter 2, Article 3, Division 4. – Code of Ethics shall be amended
as follows:
Division 4. – CODE OF ETHICS
Sec. 2.03.460. – Declaration of policy.
Sec. 2.03.470. – Definitions
Sec. 2.03.480. – Persons covered.
Sec. 2.03.490. – Standards of conduct.
Sec. 2.03.500. – Use of city resources.
Sec. 2.03.510. – Treatment of the public.
Sec. 2.03.520. – Conflict of interest.
Sec. 2.03.530. – Confidential information.
Sec. 2.03.540. – Gifts, gratuities and favors.
Sec. 2.03.550. – Financial disclosure statement.
Sec. 2.03.560. – Post employment/service activities.
Sec. 2.03.570. – Public notice required for former public servants/compliance with state law.
Sec. 2.03.580. – Board of ethics.
Sec. 2.03.590. – Reporting improper governmental action/rights/limitations/protected conduct.
Sec. 2.03.600. – Duties and powers of the board.
Sec. 2.03.610. – Who may request board action.
Sec. 2.03.620. – Limitations on board’s power.
Sec. 2.03.630. – City attorney opinions.
Sec. 2.03.640. – Procedures for hearing complaints.
Sec. 2.03.650. – Those subject to removal only by city commission.
Sec. 2.03.660. – Ex parte communications.
Sec. 2.03.670. – Confidentiality of board information.
Sec. 2.03.680. – Waiver of confidentiality.
Sec. 2.03.690. – Statute of Limitations
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Ordinance 1856
Page 3 of 8
Section 3
That Section 2.03.520 of the Bozeman Municipal Code shall be amended as follows:
“Sec. 2.03.520. – Conflict of Interest.
A. Nothing in this section shall be interpreted or construed to prohibit any official or employee
from exercising their own individual legal rights as to their own personal interests in a
transaction or matter pending before the city or any of its agencies, or to prohibit an official
or employee from testifying as a witness in any administrative or judicial proceeding.
However, no official or employee who represents their own personal interest before an
agency of which they are a member or employee, or a member or employee of an agency to
which the matter may be appealed, shall participate in the decision of that agency or the
appellate agency.
B. No official or employee shall engage in any employment or business which conflicts with the
proper discharge of such official or employee’s duties.
C. No official or employee shall take or influence official action if the official or employee
hasve a financial or personal interest, tangibly or intangibly, in a transaction or matter with
the Ccity. as to which he has the power to take or influence official action unless full public
disclosure is made. If an official or employee has any tangible or intangible financial or
personal interest in the outcome of any matter coming before the agency of which he is a
member or by which he is employed, such official or employee shall publicly disclose on the
record of the agency, or to his superior or other appropriate authority, the existence of such
financial or personal interest. An official or employee having such a financial or personal
interest shall not engage in deliberations concerning the matter, shall disqualify himself from
acting on the matter, except in the event of a tie vote, and shall not communicate about such
matter with any person who will participate in the action to be taken on such matter.
D. If an official or employee has a financial or personal interest in the outcome of a transaction
or matter coming before the agency of which they are a member or by which they are
employed, such official or employee shall:
1. Publicly disclose on the record of the agency, or to their superior or other appropriate
authority, the existence of such financial or personal interest; and
2. Except as authorized pursuant to 2.03.520.A and G, shall not engage in deliberations
concerning the matter or transaction, shall be disqualified from acting on the matter or
transaction and shall not communicate about such matter or transaction with any person
who will participate in an action to be taken on such matter or transaction.
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Ordinance 1856
Page 4 of 8
E. No employee, whether paid or unpaid shall represent or appear on behalf of any individual or
entity before any agency of the city, or take any appellate proceedings from any action of
such agency, either personally or through an associate or partner.
F. No official whether paid or unpaid, shall represent or appear on behalf of any individual or
entity in any transaction or matter proceeding of concern to the agency on which that official
serves, either before that agency or any other agency of the city, or before the city
commission, or take any appellate proceedings from any action of such agency or the
commission. Such representation may be made by an the official's associate or partner,
provided no reference to the participation of the involved official is made except for
certification or other required identification on prepared documents. The involved official
shall not engage in deliberations concerning a transaction or matter represented by an
associate or partner, shall disqualify himself/herself from acting on the transaction or matter,
and shall not communicate about such matter with any person who will participate in the
action to be taken on such transaction or
matter.
E. Nothing in this section shall be interpreted or construed to prohibit any official or employee
from exercising their own individual legal rights as to their own personal interests in a
transaction or matter pending before the city or any of its agencies, or to prohibit an official
or employee from testifying as a witness in any administrative or judicial proceeding.
However, no official or employee who represents their own personal interest before an
agency of which they are a member or employee, or a member or employee
of an agency to
which the matter may be appealed, shall participate in the decision of that agency or the
appellate agency.
F.G
. A city commissioner or mayor, as authorized pursuant to 2-2-121(10), MCA, may take
action despite a conflict of interest described in this section if that commissioner’s or
mayor’s participation is necessary for the city commission to obtain a quorum or to
otherwise enable the city commission to act. If so, the commissioner or mayor shall disclose
the interest creating the conflict prior to performing the official act.
G.H
. This section does not absolve any official or employee from complying with Title 2,
Chapter 2, MCA. If any provision of this section is in conflict with Title 2, Chapter 2, MCA
the more stringent provision, the provision that requires greater disclosure, or the provision
that provides less authority to act in furtherance of a conflict, shall apply.
H.I Any official or employee with a conflict of interest under this section shall, in addition to
other requirements in this section and when required by law, comply fully with the
disclosure requirements of 2-2-131, MCA, and shall file this disclosure with the Montana
Commissioner of Political Practices prior to acting.
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Ordinance 1856
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Section 4
That Sec. 2.03.560 of the Bozeman Municipal Code shall be amended as follows:
“2.03.560. Post Employment/Service Activities.
A. No former public servant:
1.
Within 12 months following the date on which a former public
servant ceases service to the city, a former public servant may not, without complying with
the provisions of 2.03.570:
May, during the first 12 months following the date on which the former public
servant ceases service to the city, without complying with the provisions of section
2.03.570 mMake any formal or informal appearance before, or negotiate with any
decision maker on regarding a transaction or matter which was under the former
public servant's direct responsibility as a public servant or which the former public
servant participated personally and substantially
2.
; or
May fFor compensation, without complying with the provisions of section 2.03.570
within 12 months after termination of public service Represent or act or appear on
behalf of any party an individual or entity other than the city in connection with any a
transaction or matter in which was under the former public servant's direct
responsibility or
which the former public servant participated personally and
substantially as a public servant.
B. No former public servant may use or continue to use any former official city title, including
use on business cards, email, or stationery, except that such use is not prohibited if the former
public servant clearly indicates that the service employment to with the city is no longer
ongoing. was former to current employment
.
B. Upon initial employment and annually thereafter each employee, public official and member
of any board or committee shall verify that such employee, public official and board or
committee member has not and will not knowingly violate any provision of this section or
the rules, standards of conduct or rules of ethics established by state law.
B
C. The provisions of this Section do not absolve a public servant from complying with the
prohibitions against contracting in 2-2-105(3), MCA, or the prohibitions against obtaining
employment in 2-2-201, MCA. If any provision of this section is in conflict with Title 2,
Chpt. 2, MCA, the more stringent provision shall apply.”
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Ordinance 1856
Page 6 of 8
Section 5
That Sec. 2.03.570 of the Bozeman Municipal Code shall be amended as follows:
“Sec. 2.03.570. - Public notice required.for former public servants/ compliance with State
law.
During the first 12 months following the date on which a former public servant ceases service to
the city:
A. During the first 12 months following the date on which the former public servant ceases
service to the city, In addition to the requirements of subsection A, any A former public
servant desiring intending to make any formal or informal appearance before or negotiate
with any decision maker to perform an act restricted by 2.03.560.A.1 and 2,
1. File with the
shall:
city clerk of the city commission and with the office of the city
attorney not less than ten (10) six (6) business days prior to the appearance a
written public notice of the former public servant's desire to perform an act
restricted under 2.03.560.A.1 and 2 negotiate with or appear informally or
formally before a decision maker or act on behalf of a party other than the city.
Such written notice disclosure shall state in substance the purpose for which the
former public servant wishes to act other than as required by 2.03.560.A.1 and 2
and shall also indicate the responsibility the former public servant held over the
transaction or matter or the nature of the former public servant’s participation in
the transaction or matter. appear or negotiate with the decision maker, the reason
for such appearance or negotiation and include
2.
a disclosure of all offices or
employment held by the former public servant during the last 12 months of
service to the city.
At the onset of the appearance orally disclose to the decision maker all offices or
employment held by the former public servant while serving the city and the
responsibility the former public servant held over the transaction or matter or the
nature of the former public servant’s participation in the transaction or matter.
The city clerk shall post the written notice in a prominent
publicly accessible location on
the city’s website.
B. A former public servant desiring intending to perform an act restricted by 2.03.560.A.1
and 2 who cannot reasonably meet the ten (10)
six (6) day notice period described in
subsection A of this section may appear before a decision maker only at a duly noticed
public meeting where a formal record of the proceedings is made. At the time of doing
so, the former public servant shall comply with subsection A of this section.
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Ordinance 1856
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C. Unless the act is otherwise prohibited by Title 2, Chapter 2, MCA, upon complying with
subsections A or B of this section as appropriate, filing such written notice disclosure, a
the former public servant is not prohibited from the activities proscribed in section
2.03.560.A.1 and 2.
Nothing herein, however, shall be construed as authority to absolve
any former public servant of their duty to comply with Title 2, Chapter 2, MCA. If any
provision of this section is in conflict with Title 2, Chapter 2, MCA the more stringent
provision shall apply.”
Section 6
Repealer.
All provisions of the ordinances of the City of Bozeman in conflict with the provisions of
this ordinance are, and the same are hereby, repealed and all other provisions of the ordinances
of the City of Bozeman not in conflict with the provisions of this ordinance shall remain in full
force and effect.
Section 7
Savings Provision.
This ordinance does not affect the rights and duties that matured, penalties that were
incurred or proceedings that were begun before the effective date of this ordinance. All other
provision of the Bozeman Municipal Code not amended by this Ordinance shall remain in full
force and effect.
Section 8
Severability.
That should any sentence, paragraph, subdivision, clause, phrase or section of this
ordinance be adjudged or held to be unconstitutional, illegal, or invalid, the same shall not affect
the validity of this ordinance as a whole, or any part or provision thereof, other than the part so
decided to be invalid, illegal or unconstitutional, and shall not affect the validity of the Bozeman
Municipal Code as a whole
Section 9
Codification Instruction.
The provisions of Sections 2, 3, 4, and 5 shall be codified as indicated in Chapter 2.03 of
the Bozeman Municipal Code.
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Ordinance 1856
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Section 10
Effective Date.
This ordinance shall be in full force and effect 30 days after final adoption.
PROVISIONALLY PASSED by the City Commission of the City of Bozeman,
Montana, on first reading at a regular session held on the 7th day of April
, 2013.
____________________________________
SEAN A. BECKER
Mayor
ATTEST:
____________________________________
STACY ULMEN, CMC
City Clerk
FINALLY PASSED, ADOPTED AND APPROVED by the City Commission of the
City of Bozeman, Montana on second reading at a regular session thereof held on the 22nd of
April, 2013. The effective date of this ordinance is May, 22, 2013.
_________________________________
SEAN A. BECKER
Mayor
ATTEST:
_______________________________
STACY ULMEN, CMC
City Clerk
APPROVED AS TO FORM:
_________________________________
GREG SULLIVAN
City Attorney
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