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Revolving Door Regulations

What is the "revolving door" and why do I need to know about it?

"Revolving Door" is an expression used to describe the lobbying activities of former City Officials. When people come and go through the "doors" of City service, they leave with insider information that could be detrimental to the City. For example, a person who worked for the City on a project involving the negotiation of a lease of a City property could leave City service and work for a private business seeking to lease the property. Without revolving door restrictions, that former City employee could use confidential information detrimental to the City in contract negotiations.

What do the "revolving door" provisions prevent?

The Ethics Ordinance contains provisions that prevent former City Officials from exercising, or appearing to exercise, improper influence over City decision making. It is important to note that the restrictions are narrowly tailored to prevent improper influence only in those circumstances in which the former official could exert influence through "inside" knowledge of an issue or through access to decision-makers based on relationships developed during his or her City service. These provisions do not restrict the type of employment a City Official may secure after leaving City service, nor do they restrict someone from working for a private company after doing business with that company as a City employee.

Why is it important to regulate the employment of people who are no longer City employees?

It is important that people work for the City for the right reasons. The Ethics Commission believes that employment with the City should not be seen as an opportunity to learn confidential information and build relationships that may later be exploited for private gain.

Who is subject to the City's revolving door regulations?

These regulations apply to former City Officials who received compensation from the City, and who are being compensated to lobby, or assist in lobbying, the City on behalf of a private business.

As an ex-City employee, can I lobby the City if I am not being paid to do so?

Yes. You may lobby the City on any matter at any time if you are not being compensated to perform the lobbying activities.

What does "compensation" include?

For the purposes of the revolving door regulations, compensation includes receiving any monetary or non-monetary payment for the services or time of a person. It includes, but is not limited to, salary, wages, fees, and any discount or economic opportunity not made available in the regular course of business to members of the public.

What is the one-year "cooling off" period?

This is a one-year "cooling off" period that applies to all former City Officials who were required to file a Statement of Economic Interests during their City service. It prohibits such persons from being compensated to lobby the City on any matter for one year after they leave City service.

I was compensated by the City to work on a particular project. How long am I precluded from lobbying the City on that project?

You are subject to a one-year ban from receiving compensation from a private business to lobby the City with regard to that project. This prohibition does not apply if you are lobbying on behalf of another public agency.

What is a "project"?

A project means any matter where a private business has made an application to the City for discretionary funding, discretionary entitlements, or where the City exercises discretion to enter into a lease, agreement, or contract with a private business.

What does it mean to "work on a particular project"?

To “work on a particular project” means to take part personally and substantially in the project by rendering a decision, approval, or disapproval; by making a formal written recommendation; by conducting an investigation; by rendering advice on a significant basis; or by using confidential information.

I am a volunteer board member. Do the revolving door provisions apply to me?

No. The City's revolving door provisions apply only to City Officials who were compensated for their City service.

I know I can't lobby the City directly on a matter, but can I give advice to a lobbyist on that matter?

The answer depends on when you left City service. There is a one-year prohibition on knowingly assisting someone to lobby the City with regard to projects on which you personally and substantially worked.

I still have questions. How do I get help?

The Ethics Commission is available to provide telephonic or written advice regarding these matters.