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POLICY & PROCEDURE
Subject: Index: HUMAN RESOURCES
CODE OF ETHICS Number: 100-07
Effective Date Supersedes Page Staff Contact proved By
9/1/95 9/1/83 1 of 5 B. Nelson Glode
v
1.0 PURPOSE
The purpose of this policy is to establish guidelines for ethical standards of conduct which shall
govern city employees in the performance of city business and the duties of their respective jobs.
This policy is intended to provide positive direction to city employees in order to prevent potential
conflicts of interest.
This policy is not all-encompassing in its definition of conflict of interest. Action deemed
inappropriate by a reasonable person,whether specifically cited in this policy or not, shall be subject
to inquiry under this policy.
2.0 ORGANIZATIONS AFFECTED
All city deparhnents/divisions
3.0 REFERENCES
RCW 35A.42.050
City of Renton Code, Title II, Chapter 2
4.0 POLICY
4.1 Conflict of Interest: No city employee shall engage in any act which is in conflict, or
creates an appearance of conflict,with the performance of official duties. An employee
shall be deemed to have a conflict of interest if the employee:
4.1.1 Has any financial interest in any sale to the city of any service or property when
such financial interest was received with prior knowledge that the city intended to
purchase such property, goods,or services.
4.1.2 Solicits,accepts,or seeks a gift, gratuity, or favor from any person, firm, or
corporation involved in a contract or transaction which is or may be the subject of
official action by the city.
4.1.2.1 Recognizing that personal friendships often precede and can evolve from
official contact between employees and persons engaged in business with
the city, reasonable exceptions to this section are permitted far those
occasions which are social in nature and are not predicated on the
employee's ability to influence, directly or indirectly,any matter before the
city.
The Board of Ethics and the employee will be guided in their interpretation
of this section by the distinction between a gift, gratuity, or favor given ar
received which has significant monetary value and is offered or accepted in
expectation of preferential treatment, and an expression of social courtesy
which is reasonable assumed to be reciprocal in nature. For example: a
meal or social event,privately or publicly hosted by either party; exchanges
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Page 2
of floral offerings or gifts of food to commemarate events such as illness,
death,birth, holidays,promotions, anniversaries or retirement should not be
construed as demeaning to the integrity of either party.
An employee should not make a unilateral decision if there is any doubt
about his/her ability to impartially review a matter involving one's social
contact,acquaintance,or friend. The Mayor's office and/or city attorney
should be consulted.
4.13 Participates in his/her capacity as a city employee in the making of a contract in
which he/she has a private pecuniary interest, direct or indirect, or performs in
regard to such contract some function requiring the exercise of discretion on behalf
of the city.
4.1.4 Engages in,accepts private employment from, or renders services for private
interests for any compensation or consideration having monetary value when such
employment or service is incompatible with the proper discharge of official duties
or would tend to impair independence of judgment or action in performance of
official duties.
4.1.5 Discloses or uses without authorization confidential information concerning the
property or affairs of the city to advance a private interest with respect to any
contract or transaction which is or may be the subject of official action of the city.
4.1.6 Has a financial or personal interest in any legislation coming before the City
Council and participates in discussion with or gives an official opinion to the City
Council unless the employee discloses on the record of the council the nature and
extent of such interest.
4.1.7 Holds directly or indirectly for the purposes of financial gain, investment, or
speculation an interest in real property situated within the city if such employee in
the course of his/her official duties performs any function requiring the exercise of
discretion on behalf of the city in regard to the regulation of land use or
development pertaining to that property; provided,that this prohibition shall not
apply to:
4.1.7.1 real property devoted to the personal use or residence of the employee or
member of the employee's immediate family;
4.1.7.2 any other interest in the real property held by the employee on the effective
date of this policy.
4.2 Use of Public Pronertv: No city employee shall request, use, or permit the use of city-
owned vehicles, equipment,materials, or property for personal convenience or profit. Use
is to be restricted to such services as are available to the public generally and for the
conduct of official business.
43 Political Activities:
4.3.1 No city employee may use city time or property in any manner or his/her autharity
to promote any political issue or candidate,to solicit funds for any political purpose
or to influence the outcome of any election.
4.3.2 No city employee shall accept appointment or seek election to any public office
when the holding of such office would be incompatible or would substantially
interfere with the discharge of official city duties.
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Page 3
5.0 DEFINITIONS
5.1 Emnlovee: Any person holding a regularly compensated position for the City of Renton,
excluding elected officials and persons serving on City boards or commissions.
5.2 Interest: Any direct or indirect monetary or material benefit accruing to a city employee as
a result of a contract or transaction which is or may be the subject of an official act or action
by or with the city except for such contracts or transactions which would confer similar
benefits to all other persons and/or property similarly situated. Examples include:
1.Interest in an employee's family; and
2.Interest in any business entity in which the city employee is an officer, director, or
employee; and
3.Interest in any business entity in which stock or legal beneficial ownership is in
excess of one percent of the total stock or legal and beneficial ownership is
controlled or owned directly or indirectly by the employee; and
4.Interest in any person or business entity with whom a contractual relationship exists
with the employee;provided,that a commercially reasonable loan made in the
ordinary course of business, or a contract for a commercial retail sale shall not be
deemed to create an interest.
5.3 Immediate Familv: Includes spouse,child,parent,parent-in-law, brother, brother-in-law,
sister, sister-in-law, grandparent, son-in-law, daughter-in-law, and grandchildren. This
policy shall also apply to any person related by blood or marriage who is financially
dependent upon the employee and/or is residing in the employee's home.
5.4 Contract: Shall include any contract or agreement, sale, lease,purchase, or any
combination of the foregoing.
6.0 PROCEDURE
6.1 Board of Ethics: A Board of Ethics shall be established to insure the proper
implementation of the code of Ethics and to investigate and report on alleged conflicts of
interest involving city employees. The committee shall be composed of five members who
are appointed by the Mayor subject to confirmation by a majority of the members of the
City Council.
6.1.1 The City Attorney shall be available and shall serve as technical staff for the Board
throughout the review process.
6.1.2 The City Human Resources&Risk Management Administrator shall provide staff
support and other available resources to assist the Board with the investigation of
complaints.
6.13 The Board shall meet within thirty(30)days after receipt of any written complaint
or directive from the Mayor.
6.1.4 Board Authoritv/Duties:
6.1.4.1 The Board shall render advisory opinions to the Mayor, in writing,
concerning questions of ethics,conflicts of interest, and applicability of this
Code of Ethics. The Board shall limit its scope to specific complaints and
shall not go beyond matters relating to the complaint.
6.1.4.1.1 The Board shall investigate all formal written complaints,
from any source,with regard to alleged violations of this
policy.
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6.1.4.1.2 The Board shall also investigate any suspected or alleged
violation of the code of Ethics upon direction of the Mayor.
6.1.4.2 In the course of its investigation,the Board of Ethics may require any city
employee or request any other person to appear before the Board to give
full information under oath and to produce books,memoranda, papers,
documents, financial statements,receipts, canceled checks, or any other
relevant information or data in the possession, custody, or control of the
person ordered or requested to appear.
6.1.4.2.1 All witnesses required or requested to attend such hearings
shall receive written notificatiion, in person or by certified
mail, of the time and place of the hearing at least fifteen
days prior to the date fixed for attendance.
6.1.4.2.2 Whenever a city employee is under investigation for any
alleged violation of this Code, he/she shall receive
appropriate notice in writing from the Board at least fifteen
days prior to any hearing. That employee shall also be
entitled to be present,to examine and cross-examine
witnesses,to be represented by counsel, and to call
witnesses on his/her own behalf.
6.1.4.23 In order to protect the rights and reputation of persons who
may be unjustly attacked or criticized and given the fact
that investigations of complaints may serve as a prelude to
further legal or disciplinary action,hearings concerning
violations of this Code shall be conducted in private. A
record of such proceeding shall,however, be made and
retained.
Provided,however,that any city employee who is the
subject of a complaint may demand a public hearing. All
hearings whether public or private shall be conducted under
the guidelines established herein.
6.1.4.3 The Board shall render a written record of its findings upon conclusion of
the investigation,and a copy of these findings shall be transmitted to the
Mayor.
6.1.4.3.1 The record of the Board's written findings shall be open to
public inspection unless:
1) The information is exempt according to state law
RCW 42.17)and damage to individuals resulting
from the release of the record would outweigh the
public's need to know;
2) The Board of Ethics has determined in the conduct
of any hearing or proceeding under its jurisdiction
that it is reasonable to withhold information in
order to protect individuals who may be unjustly or
improperly accused or who may be
disproportionately harmed or injured in their
reputation, employment,or profession by any
premature disclosure;
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Page 5
3) Civil or criminal action by the City of Renton or
any other governmental agency having jurisdiction
may be pending.
6.1.4.4 Based on the findings of the Board of Ethics,the Mayor shall make the final
determination regarding the degree of violation and the penalty(if any)to
the individual. Any employee who is found to be in violation will be
subject to disciplinary action up to and including termination from
employment.
6.1.4.4.1 In the event the Board's findings disclose an apparent
violation of any state law, a copy of the findings shall be
filed with the Prosecuting Attorney of King County.
6.1.4.4.2 If the Board's findings disclose an apparent violation of any
local law,then the city Attorney may prosecute by
appropriate action of either a criminal or civil nature.