HomeMy WebLinkAboutMINUTES - 12102002 - C50 TO: Board of Supervisors
CONTRA
FROM: Silvano B. Marc esi, County Counsel , 1 COSTA
By: Mary Ann McNett Mason,Deputy County CounselCOUNT,
DATE: November 6, 2002
SUBJECT: Conflict of Interest Code of the Public Works Department
SPECIFIC REQUEST(S)OR RECOMMENDATION(S)&BACKGROUND BACKGR ANIS JUSTIFICATION s
RECOMMENDATION(S):
Approve amendments to the Public "Works Department Conflict of Interest Code to substitute the
attached as Said code.
BACKGROUND/REASON(S) FOR RECOMMENDATION(S):
The Public Works Department has amended its code and submitted the amended code to the Board for
approval pursuant to Government Code section 87306 and 87306.5.
CONTINUED ON ATTACHMENT: YES SIGNATURE:
j✓ RECOMMENDATION OF COUNTY ADMINISTRATOR—RECOMMENDATION OF BOARD
COMMITTEE
&.." APPROVE OTHER.
SIGNATURES}, r
ACTION OF B ON December 10, 2002 APPROVED AS RECOMMENDED_„x_OTHER
VOTE OF SUPERVISORS:
I HEREBY CERTIFY THAT THIS IS A
XX UNANIMOUS (ABSENT_11_) TRUE AND CORRECT COPY OF AN
AYES: NOES: ACTION TAKEN AND ENTERED
ABSENT: ABSTAIN: ON THE MINUTES OF THE BOARD
OF SUPERVISORS ON THE DATE
SHOWN.
ATTESTED: Dacember 10, 2002
JOHN SWEETEN,CLERK OF
THE BOARD OF SUPERVISORS
Contact: County Counsel AND COUNTY ADMINISTRATOR
cc: Clerk,Board of Supervisors
Public Works Department
BY �� .� �'�ci,�:,L.-� ,DEPUTY
TAJ0ANNVAAM1pw bdordcoi.wpd
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Adopted byC n
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Incorporation Page
PUBLIC WORKS DEPARTMENT
The Political Reform Act (Government Code Section 81000, et seq.) required state
and local government agencies to adopt and promulgate conflict of interest codes.
The Fair Political Practices Commission has adopted a regulation (2 Cal. Code of
Regs. 18730) which contains the terms of a standard conflict of interest code.
After public notice and hearing, it may be amended by the Fair Political Practices
Commission to conform to amendments in the Political Reform Act. Therefore, the
terms of 2 California Code of Regulations Section 18730 and any amendments to
it duly adopted by the Fair Political Practices Commission are hereby incorporated
by reference. This regulation and the attached Appendix designating officials and
employees and establishing disclosure categories shall constitute the conflict of
interest code of the Public Works Department.
Designated employees shall file their statements with the office of the Chief of
Administrative Services of the Public Works Department who will make the
statements available for public inspection and reproduction. (Gov. Code Section
81008.) Statements for all designated employees will be retained by the Chief of
Administrative Services of the Public Forks Department, except that in the case
of the Department .Bead, the Chief of Administrative Services shall make and
retain a copy and forward the original to the Clerk of the Board of Supervisors.
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2:2 Data 1+dminitvlichelelContlict of Interestdneorp page 2002.doe
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Amend 2 Cal. Code of Regulations Section 18730 as follows:
18730. provisions of Conflict of Interest Codes.
(a) Incorporation by reference of the terms of this regulation along with the
designation of employees and the formulation of disclosure categories in the Appendix referred
to below constitute the adoption and promulgation of a conflict of interest code within the
meaning of Government Code Section 87300 or the amendment of a conflict of interest code
within the meaning of Government Code Section 87306 if the terms of this regulation are
substituted for terms of a conflict of interest code already in effect. A code so amended or
adopted and promulgated requires the reporting of reportable items in a manner substantially
equivalent to the requirements of Article 2 of Chapter 7 of the Political Reform Act, Government
Code Sections 81000, et seq. the requirements of a conflict of interest code are in addition to
other requirements of the Political Reform Act, such as the general prohibition against conflicts
of interest contained in Government Code Section 87100, and to other state or local laws
pertaining to conflicts of interest.
(b) The terms of a conflict of interest code amended or adopted and promulgated
pursuant to this regulation are as follows:
(1) Section 1. Definitions. The definitions contained in the Political Reform Act of
1974, regulations of the Fair Political Practices Commission(2 Cal. Code of Regs. Sections
18100, et seq.), and any amendments to the Act or regulations, are incorporated by reference into
this conflict of interest code.
(2) Section 2. Designated Employees. The persons holding positions listed in the
Appendix are designated employees. It has been determined that these persons make or
participate in the making of decisions which may foreseeably have a material effect on financial
interests.
(3) Section 3. Disclosure Categories. This code does not establish any disclosure
obligation for those designated employees who are also specified in Government Code Section
87200 if they are designated in this code in that same capacity or if the geographical jurisdiction
of this agency is the same as or is wholly included within the jurisdiction in which those persons
must report their financial interests pursuant to Article 2 of Chapter 7 of the Political Reform
Act, Government Code Section 87200, et seq.
ll/l/02 1 18730
In addition, this code does not establish any disclosure obligation for any designated
employees who are designated in a conflict of interest code for another agency, if all of the
following apply.
(A) The geographical jurisdiction of this agency is the same as or is wholly included
within the jurisdiction of the other agency;
(B) The disclosure assigned in the code of the other agency is the same as that
required under Article 2 of Chapter 7 of the Political Reform Act, Government Code Section
8'7200; and
(C) The filing officer is the same for both agencies.1
Such persons are covered by this code for disqualification purposes only. With respect to
all other designated employees, the disclosure categories set forth in the Appendix specify which
kinds of financial interests are reportable. Such a designated employee shall disclose in his or her
statement of economic interests those financial interests he or she has which are of the kind
described in the disclosure categories to which he or she is assigned in the Appendix.. It has been
determined that the financial interests set forth in a designated employee's disclosure categories
are the kinds of financial interests which he or she foreseeably can affect materially through the
conduct of his or her office.
(4) Section 4. Statements of Economic Interests; Place of Filing. The code of
reviewing body shall instruct all designated employees within its code to file statements of
economic interests with the agency or with the code reviewing body, as provided by the code
reviewing body in the agency's conflict of interest code.2
'Designated employees who are required to file statements of economic interests under any other agency's
conflict of interest code,or under Article 2 for a different jurisdiction,may expand their statement of economic
interests to cover reportable interest in both jurisdictions,and file copies of this expanded statement with both
entities in lieu of filing separate and distinct statements,provided that each copy of such expanded statement filed in
place of an original is signed and verified by the designated employees as if it were an original.See Government
Code Section 81004.
2 See Government Code Section 81010 and 2 Cal.Code of Regs. Section 18115 for the duties of filing
officers and persons in agencies who make and retain copies of statements and forward the originals to the filing
officer.
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(5) Section 5. Statements of Economic Interests: Time of Filing.
(A) Initial Statements. All designated employees employed by the agency on the
effective date of this code, as originally adopted,promulgated and approved by the code
reviewing body, shall file statements within 30 days after the effective date of this code.
Thereafter, each person already in a position when it is designated by an amendment to this code
shall file an initial statement within 30 days after the effective date of the amendment.
(B) Assuming Office Statements. All persons assuming designated positions after the
effective date of this code shall file statements within 30 days after assuming the designated
positions, or if subject to State Senate confirmation, 30 days after being nominated or appointed.
(C) Annual Statements. All designated employees shall file statements no later than
April 1.
(D) Leaving Office Statements. All persons who leave designated positions shall file
statements within 30 days after leaving office.
(5.5) Section 5.5. Statements for Persons Who Resign Prior to Assuming Office. Any
person who resigns within 12 months of initial appointment, or within 30 days of the date of
notice provided by the filing officer to file an assuming office statement, is not deemed to have
assumed office or left office,provided he or she did not make or participate in the making of,or
use his or her position to influence any decision and did not receive or become entitled to receive
any form of payment as a result of his or her appointment. Such persons shall not file either an.
assuming or leaving office statement,
(A) Any person who resigns a position within 30 days of the date of a notice from the
filing officer shall do both of the following:
(1) File a written resignation with the appointing power, and
(2) File a written-statement-with the filing officer declaring under penalty of perjury
that during the period between appointment and resignation he or she did not make,participate in
the making, or use the position to influence any decision of the agency or receive, or become
entitled to receive, any form of payment by virtue of being appointed to the position.
(6) Section 6. Contents of and Period Covered by Statements of Economic Interests.
l l/l/02 3 18730
(A) Contents of Initial Statements. Initial statements shall disclose any reportable
investments, interests in real property and business positions held on the effective date of the
code and income received during the 12 months prior to the effective date of the code.
(B) Contents of Assuming Office Statements. Assuming office statements shall
disclose any reportable investments, interests in real property and business positions held on the
date of assuming office or, if subject to State Senate confirmation or appointment, on the date of
nomination, and income received during the 12 months prior to the date of assuming office or the
date of being appointed or nominated,respectively.
(C) Contents of Annual Statements. Annual statements shall disclose any reportable
investments, interests in real property, income and business positions held or received during the
previous calendar year provided,however,that the period covered by an employee's first annual
statement shall begin on the effective date of the code or the d ate of assuming office whichever
is later.
(D) Contents of Leaving Office Statements. Leaving office statements shall disclose
reportable investments, interests in real property, income and business positions held or received
during the period between the closing date of the last statements filed and the date of leaving
office.
(7) Section 7. Manner of Reporting. Statements of economic interests shall be made
on forms prescribed by the Fair Political Practices Commission and supplied by the agency, and
shall contain the following information.
(A) Investments and Real Property Disclosure. When an investment or an interest in
real property is required to be reported,4 the statement shall contain the following:
1. A statement of the nature of the investment or interest;
2. The name of the business entity in which each investment is held, and a general
description of the business activity in which the business entity is engaged;
3. The address or other precise location of the real property;
4. A statement whether the fair market value of the investment or interest in real
property exceeds one thousand dollars($1,000), exceeds ten thousand dollars ($10,000),or
exceeds one hundred thousand dollars ($100,000).
l l/l/02 4 18730
(B) Personal Income Disclosure. When personal income is required to be reported,5
the statement shall contain:
1. The name and address of each source of income aggregating two hundred fifty
dollars ($250) or more in value or fifty dollars ($50) or more in value if the income was a gift,
and a general description of the business activity, if any, of each source;
2. 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 one thousand dollars ($1,000) or
less, greater than one thousand dollars ($1,000), or greater than ten thousand dollars ($10,000);
3. A description of the consideration, if any, for which the income was received;
4. In the case of a gift, the name, address and business activity of the donor and any
intermediary through which the gift was made; a description of the gift; the amount or value of
the gift; and the date on which the gift was received;
5. In the case of a loan, the annual interest rate and the security, if any, given for the
loan and the term of the loan.
(C) Business Entity Income Disclosure. When income of a business entity, including
income of a sole proprietorship, is required to be reported,b the statement shall contain:
1. The name, address, and a general description of the business activity of the
business entity;
3 For the purpose of disclosure only(not disqualification),an interest in real property does not include the
principal residence of the filer.
4 Investments and interests in real property,which have a fair market value of less than$1,000,are not
investments and interests in real property within the meaning of the Political Reform Act.However,investments or
interests in real property of an individual include those held by the individual's spouse and dependent children as
well as a pro rata share of any investment or interest in real property of any business entity or trust in which the
individual, spouse and dependent children own,in the aggregate,a direct or beneficial interest of 10 percent or
greater.
5 A designated employee's income includes his or her community property interest in the income of his or
her spouse but does not include salary or reimbursement for expenses received from a state,local or federal
government agency.
6 Income of a business entity is reportable if the direct,indirect or beneficial interest of the filer and the
filer's spouse in the business entity aggregates a 10 percent or greater interest.In addition,the disclosure of persons
who are clients or customers of a business entity is required only if the clients or customers are within one of the
disclosure categories of the filer.
11/1/02 5 18730
2. The name of every person from whom the 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).
(D) Business Position Disclosure. When business positions are required to be
reported, a designated employee shall list the name and address of each business entity in which
he or she is a director, officer,partner, trustee, employee, or in which he or she holds any position
of management, a description of the business activity in which the business entity is engaged, and
the designated employee's position with the business entity.
(E) Acquisition or Disposal During Reporting Period. In the case of an annual or
leaving office statement, if an investment or an interest in real property was partially or wholly
acquired or disposed of during the period covered by the statement,the statement shall contain
the date of acquisition or disposal.
(8) Section 8. Prohibition on Receipt of Honoraria.
(A) No member of a state board or commission, and no designated employee of a state
or local government agency, shall accept any honorarium from any source, if the member or
employee would be required to report the receipt on income or gifts from that source on his or
her statement of economic interests. This section shall not apply to any part-time member of the
governing board of any public institution of higher education, unless the member is also an
elected official.
Subdivisions (a), (b), and(c) of Government Code Section 89501 shall apply to the
prohibitions in this section.
This section shall not limit or prohibit payments, advances, or reimbursements for travel
and related lodging and subsistence authorized by Government Code Section 89506,
(8.1) Section 8.1 Prohibition on Receipt of Gifts in Excess of$290.
(A) No member of a state board or commission, and no designated employee of a state
or local government agency, shall accept gifts with a total value of more than$290 in a calendar
year from any single source, if the member or employee would be required to report the receipt of
income or gifts from that source on his or her statement of economic interests. This section shall
not apply to any part-time member of the governing board of any public institution of higher
education,unless the member is also an elected official.
11/1/02 6 18730
44 -mac? .i.;2-
Subdivision(e), (f), and(g) of Government Code Section 89503 shall apply to the
prohibitions in this section.
(8.2) Section 8.2. Loans to Public Officials,
W No elected officer of a state or local Government agency shall from the date of
his or her election to office through the date that he or she vacates office receive a loan from any
officer, employee, member, or consultant of the state local Government agency in which the
elected officer holds office or over which the elected officer's agency has direction and control
No public official who is exempt from the state civil service system pursuant to
subdivisions (c), (d), (e), (f), and(g) of Section 4 of Article 'VII of the Constitution shall while
he or she holds office, receive a personal loan from any officer, employee member or consultant
of the state or local government agency in which the public official holds office or over which
the public official's agency has direction and control. This subdivision shall not apply to loans
made to a public official whose duties are solely secretarial clerical or manual
Q No elected officer of a state or local Government agency shall from the date of
his or her election to office through the date that he or she vacates office, receive a personal loan
from any person who has a contract with the state or local government agency to which that
elected officer has been elected or over which that elected officer's agency has direction and
control. This subdivision shall not apply to loans made by banks or other financial institutions or
to any indebtedness created as part of a retail installment or credit card transaction if the loan is
made or the indebtedness created in the lender's regular course of business on terms available to
members of the public without regard to the elected officer's official-status
No public official who is exempt from the state civil service system pursuant to
subdivisions(c), (d), (e), (f), and(g) of Section 4 of Article VII of the Constitution shall while
he or she holds office receive a personal loan from my person who has a contract with the State
or local government agency to which that elected officer has been elected or over which that
elected officer's agency has direction and control This subdivision shall not apply to loans made
by banks or other financial institutions or to my indebtedness created as part of a retail
installment or credit card transaction if the loan is made or the indebtedness created in the
lender's regular course of business on terms available to members of the public without regard to
11/1/02 7 18730
the elected officer's official status. This subdivision shall not apply to loan made to a public
official whose duties are solely secretarial clerical or manual.
This section shall not apply to the following:
1. Loans made to the campaign committee of an elected officer or candidate for
elective office.
2. Loans made by a public official's spouse child parent grandparent grandchild
brother, sister,parent-in-law,brother-in-law, sister-in-law,nephew, niece aunt uncle or first
cousin, or the shouse of my suchperson provided that the person making the loan is not acting as
an agent to intermedias for or my person not otherwise exempted under this section
3. Loans from a person,which in the aggregate do not exceed two hundred fifty
dollars ($250) at my given time
4. Loans made, or offered in writing before January 1 1998
8.3 Section 8.3. Loan Terms.
Except as set forth in subdivision(B) no elected officer of a state or local
Rovemment agency shall, from the date of his or her election to office through the date he or she
vacates office, receive a personal loan of five hundred dollars 500) or more except when the
loan is in writing and clearly states the terms of the loan, including the parties to the loan
agreement, date of the loan amount of the loan, term of the loan date or dates when payments
shall be due on the loan and the amount of the payments and the rate of interest paid on the loan
Bi) This section shall not appllyto the following types of loans,•
1. Loans made to the campaign committee of the elected officer.
2. Loans made to the elected officer by his or her spouse child parent grandparent
grandchild brother, sister,parent-in-law,brother-in-law, sister-in-law, nephew, niece aunt
uncle or first cousin or the spouse of any such person provided that the person making the loan
is not acting as an agent or intermediary for any person not otherwise exempted under this
section.
3. Loans made, or offered in writing before January 1 1998.
M Nothing in this section shall exeWt any person from any other provision of Title
9 of the Government Code.
11/1/02 8 18730
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8.4 Section 8.4. Personal Loans.
LA Except as set forth in subdivision Q a personal loan received by any designated
employee shall become a gift to the designated employee for the purpose of this section in the
following circumstances;
1. If the loan has a defined date or dates for repayment when the statute of
limitations for filing an action for default has expired.
2. If the loan has no defined date or dates for repayment when one year has elapsed
from the later of the following:
a. The date the loan was made.
b. The date the last payment of one hundred dollars ($100) or more was made on the
loan.
C. The date upon which the debtor has made payments on the loan aggregating to
less than two hundred fifty dollars $250) during the previous 12 months,
This section shall not apply to the following types of loans,
1. A loan made to the campaign committee of an elected officer or a candidate for
elective office.
2. A loan that would otherwise not be a gift as defined in this title,
3. A loan that would otherwise be a gift as set forth under subdivision(A),but on
which the creditor has taken reasonable action to collect the balance due.
4. A loan that would otherwise be a gift as set forth under subdivision(A),but on
which the creditor,based on reasonable business considerations has not undertaken collection
action. Except in a criminal action a creditor who claims that a loan is nota gift on the basis of
this paragraph has the burden of proving that the decision for not taking collection action was
based on reasonable business considerations.
5. A_loan made to a debtor who has filed for bankruptcy and the loan is ultimately
discharged in bankruptcy.
LQ Nothing in this section shall exempt my person from any other provisions of Title
9 of the Government Code.
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(9) Section 9. Disqualification. No designated employee shall make,participate in
making, or in any way attempt to use his or her official position to influence the making of any
governmental decision which he or she knows or has reason to know will have a reasonably
foreseeable material financial effect, distinguishable from its effect on the public generally, on
the official or a member of his or her immediate family or on:
(A) Any business entity in which the designated employee has a direct or indirect
investment worth one thousand dollars ($1,000) or more;
(B) Any real property in which the designated employee has a direct or indirect
interest worth one thousand dollars ($1,000) or more;
(C) Any source of income other than gifts and other loans by a commercial lending
institution in the regular course of business on terms available to the public without regard to
official status, aggregating two hundred fifty dollars ($250) or more in value provided to,
received by or promised to the designated employee within 12 months prior to the time when the
decision is made;
(D) Any business entity in which the designated employee is a director, officer,
partner, trustee, employee, or holds any position of management; or
(E) Any donor of, or any intermediary or agent for a donor of, a gift or gifts
aggregating$290 or more provided to; received by, or promised to the designated employee
within 12 months prior to the time when the decision is made.
(9.3) Section 9.3. Legally Required Participation. No designated employee shall be
prevented from making or participating in the making of any decision to the extent his or her
participation is legally required for the decision to be made. The fact that the vote of a designated
employee who is on a voting body is needed to break a tie does not make his or her participation
legally required for purposes of this section.
(9.5) Section 9.5. Disqualification of State Officers and Employees. In addition to the
general disqualification provisions of Section 9, no state administrative official shall make,
participate in making, or use his or her official position to influence any governmental decision
directly relating to any contract where the state administrative official knows or has reason to
know that any party to the contract is a person with whom the state administrative official, or any
l l/l/02 10 18730
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member of his her immediate family has, within 12 months prior to the time when the official
action is to be taken:
(A) Engaged in a business transaction or transactions on terms not available to
members of the public,regarding any investment or interest in real property; or
(B) Engaged in a business transaction or transactions on terms not available to
members of the public regarding the rendering of goods or services totaling in value one
thousand dollars ($1,000) or more.
(10) Section 10. Manner of Disqualification. When a designated employee determines
that he or she should not make a governmental decision because he or she has a disqualifying
interest in it, the determination not to act must be accompanied by a disclosure of the
disqualifying interest. In the case of a voting body, this determination and disclosure shall be
made part of the agency's official record; in the case of a designated employee who is the head of
an agency,this determination and disclosure shall be made in writing to his or her appointing
authority; and in the case of other designated employees,this determination and disclosure shall
be made in writing to the designated employee's supervisor.
(11) Section 11. Assistance of the Commission and Counsel. Any designated employee
who is unsure of his or her duties under this code may request assistance from the Fair Political
Practices Commission pursuant to Government Code Section 83114 or from the attorney for his
or her agency,provided that nothing in this section requires the attorney for the agency to issue
any formal or informal opinion.
(12) Section 12. Violations. This code has the force and effect of law. Designated
employees violating any provision of this code are subject to the administrative, criminal and
civil sanctions provided in the Political Reform Act, Government Code Sections 81000—91015.
In addition, a decision in relation to which a violation of the disqualification provisions of this
code or of Governmental Code Section 87100 or 87450 has occurred may be set-aside as void
pursuant to Government Code Section 91003.
Note: AUTHORITY: Section 83112, Gov. Code
REFERENCE: Section 87103(e), 87300-87302, 89501, 89502, 89503, Gov. Code
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EXHIBIT A
CONFLICT OF INTEREST-DESIGNATED POSITIONS
Public Works: Disclosure Category:
Administrative Services Assistant II................................................................................All
Administrative Services Assistant III...............................................................................All
Assistant County Surveyor...............................................................................................All
Assistant Director of Airports..........................................................................................All
Assistant Real Property Agent.........................................................................................All
AssociateCivil Engineer..................................................................................................All
Deputy Public Works Director.........................................................................................All
Directorof Airports..........................................................................................................All
Engineer...........................................................................................................................All
Engineering Technician(Journey Level and above)........................................................All
Engineering Technician Supervisor—Construction........................................................All
Engineering Technician Supervisor—Land Surveyor.....................................................All
Engineering Technician Supervisor—M&T Lab.............................................................All
EnvironmentalPlanner.....................................................................................................All
Principal Real Property Agent .........................................................................................All
Public Works Chief of Administrative Services........................... ........ .......... ..........All
PublicWorks Director.....................................................................................................All
Public Works Field Operations Manager.........................................................................All
PublicWorks Fiscal Officer.............................................................................................All
Public Works Maintenance Coordinator..........................................................................All
Public Works Maintenance Superintendent.....................................................................All
Public Works Maintenance Supervisor............................................................................All
SeniorCivil Engineer.......................................................................................................All
SeniorHydrologist...........................................................................................................All
SeniorReal Property Agent.............................................................................................All
Stormwater Pollution Control Manager...........................................................................All
Stormwater Pollution Control Planning Specialist..........................................................All
SupervisingCivil Engineer..............................................................................................All
Supervising Real Property Agent.....................................................................................All
Vegetation Management Supervisor................................................................................All
*Consultants.....................................................................................................................All
*The Department head may determine that a particular consultant is hired to perform a range that is lirnited in scope
and thus is not required to fully comply with the disclosure requirements in this code. The Department Head may
make a determination on a case-by-case basis what disclosure,if any,is required for any particular consultant.
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: 3 1�STH iC1C(Slik ichele\Co iflict of Interest%xhibit A.doC
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EXHIBIT B
Disclosure Category
General Rule
An investment, interest in real property, or income is reportable if the business entity in
which the investment is held, the interest in real property, or the income or source of income may
foreseeably be affected materially by an decision made or participated in by the designated
employee by virtue of the employee's position.
(a) All investments, interests in real property, income and any business entity in which
the person is a director, officer, partner, trustee, employee, or holds any position of management.
Financial interests are reportable only if located within Contra Costa County, or if the business
entity is doing business or planning to do business in the County (and such plans are known by
the designated employee) or has done business within the County at any time during the two
years prior to the filing of the Statement.
(b) Investments in any business entity, and income from any source and status as a
director, officer, partner, trustee, employee, or holder of a position of management in any
business entity which has within the last two years contracted, or foreseeably may contract, with
Contra Costa County or the Public Works Department or any associated special district to
provide services, supplies, materials, machinery, or equipment to the County or Public Works
Department or any of the associated special districts.
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GAG DataWdrnin\Michele\Conflict of Interest\Exhibit B.doc