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File #: 22-0590   
Type: Report to Council Status: Passed
Meeting Body: City Council
On agenda: 9/27/2022
Title: Adopt a Resolution Amending the City of Sunnyvale Local Conflict of Interest Code
Attachments: 1. Resolution, 2. Conflict of Interest Code List Updates-Redlines, 3. 2022 Local Agency Notice

Adopt a Resolution Amending the City of Sunnyvale Local Conflict of Interest Code

The Political Reform Act requires that every state and local agency adopt a local conflict of interest code that identifies all officials and employees within the agency who make governmental decisions based on the positions they hold. Those individuals in the designated positions must then disclose their financial interests as specified in the agency's conflict of interest code.

Every local government agency is required to review its Conflict of Interest Code biennially to determine if the Code is accurate or must be amended. Amendments are necessary if qualifying positions have been added or deleted from the City's classification plan and salary resolution. Amendments to revise titles of existing positions, or to revise disclosure categories are also required.

The City's Conflict of Interest Code applies to the City, as well as designated "City agencies" (i.e., the Successor Agency to the Former Redevelopment Agency of the City of Sunnyvale and the Sunnyvale Financing Authority) and their officers and employees.

The City's Conflict of Interest Code was last amended on March 30, 2021 (Resolution No. 1044-21). Consistent with requirements of the Political Reform Act, the City conducted a biennial review of its Conflict of Interest Code. Staff determined that an amendment is necessary to reflect various changes to classifications that have occurred in the last two years.

This update also includes changes to the language pertaining to consultants retained by the City to more closely align the City's Conflict of Interest Code with Fair Political Practices Commission (FPPC) Regulation 18700.3 (Consultant, Public Official Who Manages Public Investments: Definitions). Based on this FPPC rule, a consultant is a designated employee when the consultant makes governmental decisions or serves in a staff capacity and par...

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