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Fundamentals Of The Conflict Of Interest Code

Under the Political Reform Act, all public agencies are required to adopt a conflict of interest code. In the City of San Diego, each department, agency, and appropriate board and commission has its own code. Each code designates positions required to file a 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 the public to the types of financial interests that may create conflict of interest.

Conflict of Interest Codes

The Three Parts of a Conflict of Interest Code

1. Terms of the Code (the "Body")

The essential terms of a conflict of interest code are found in the code's main body, which includes such provisions as the manner of reporting financial interests, disqualifications procedures, and other information. The Fair Political Practices Commission (FPPC) recommends that agencies incorporate FPPC Regulation 18730 by reference because the information required to be in a code's main body is complex, and Regulation 18730 contains all the necessary provisions. The FPPC periodically amends the regulation to include legislative and regulatory changes that affect the code's main body; by referencing the regulation, the body of an agency's code stays automatically in compliance with the Political Reform Act.

2. Designated Positions (typically, "Appendix A")

A conflict of interest 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 the code. Persons holding positions listed in Government Code section 87200 are considered "statutory filers." Such persons include the Mayor, Councilmembers, the City Attorney, the City Manager, Planning Commissioners, and persons who manage public investments.

3. Disclosure Categories (typically, "Appendix B")

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