Title
Update to the City’s Conflict-of-Interest Code
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FileID
File ID: 2026-00752
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Location
Location: Citywide
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Recommendation
Recommendation: Adopt a Resolution: 1) adopting the Conflict-of-Interest Code for the City of Sacramento; and 2) rescinding Resolution 2019-0119.
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Contact
Contact: Haley Arata, Administrative Analyst, (916) 808-5204, harata@cityofsacramtento.org; Wendy Klock-Johnson, Assistant City Clerk, (916) 808-7509, wklockjohnson@cityofsacramento.org; Mindy Cuppy, City Clerk, (916) 808-5224, mcuppy@cityofsacramento.org; Office of the City Clerk.
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Presenter
Presenter: None
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Attachments
Attachments:
1-Description/Analysis
2-Resolution (Clean)
3-Resolution (Redline)
4-Notice
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Description/Analysis
IssueDetail
Issue Detail: The Political Reform Act (Government Code section 8100 et seq.) requires local agencies to adopt and promulgate a conflict-of-interest code. Local agencies are also required to conduct a biennial review of their conflict-of-interest codes and to update their codes if there are changed circumstances. The code was last updated in 2019; due to the COVID-19 pandemic, staff and agency changes, review of the code was delayed and began in 2025. Based on the review of the code, city staff determined that changed circumstances require that the code be updated.
Review of the code began in June 2025 and involved extensive coordination between the Office of the City Clerk, the City Attorney’s Office, and conflict-of-interest code coordinators from all city departments to ensure that all positions within the city that make or participate in making government decisions are specifically enumerated in the city’s conflict-of-interest code and that each position is assigned disclosure requirements based on the position’s level of decision making. The Office of the City Clerk also worked with department coordinators and Human Resources to add position numbers to the designated positions list, which is a new feature compared to the last code passed in 2019. The addition of position numbers aims to clarify the specific positions designated in the code and provide an opportunity to further distinguish filing positions in the city’s e-filing system, Netfile.
The Office of the City Clerk posted a notice of intention to amend the conflict-of-interest code at City Hall on February 3, 2026. The notice of intention provided a written comment period, ending on March 6, 2026. The notice of intention and a full copy of the proposed amended code were posted on the city’s website and provided via email to conflict-of-interest code department coordinators, for distribution to conflict-of-interest code designated filers. The Office of the City Clerk received no written public comment during this period but did correct two typographical errors. Revisions to the existing conflict-of-interest code include: revisions to the code to remove provisions covered by Fair Political Practice’s model conflict-of-interest code; revisions to Appendix 1 of the code (Designated Positions) to modify the list of designated employees who are required to file statements of economic interests; and revisions to Appendix 2 of the code (Disclosure Categories) to expand the categories required to be disclosed.
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PolicyConsiderations
Policy Considerations: The city is obligated under the Political Reform Act to update its code to reflect changed circumstances.
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EconomicImpacts
Economic Impacts: None.
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EnvironmentalConsiderations
Environmental Considerations: None.
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Sustainability
Sustainability: None.
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Commission/Committee Action
Commission/Committee Action: None.
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RationaleforRecommendation
Rationale for Recommendation: Pursuant to the Political Reform Act, local agencies are required to review their conflict-of-interest codes and update their codes if there are changed circumstances. The city’s code must be updated because of changed circumstances.
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FinancialConsiderations
Financial Considerations: Not applicable.
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LocalBusinessEnterprise
Local Business Enterprise (LBE): None.
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