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6.3.B. - Page 2 <br /> ANALYSIS <br /> The Political Reform Act of 1974 requires all government agencies to adopt a Conflict of <br /> Interest Code. The purpose of the local code is to require certain employee <br /> classifications to make some level of economic disclosure, depending upon their <br /> position and likelihood of influencing decisions where they might have an economic <br /> interest at stake. According to the Fair Political Practices Commission "...the code must <br /> list all agency positions that involve the making or participation in making of decisions <br /> that "may foreseeably have a material effect on any financial interest." This covers <br /> agency members, officers and employees, and it may include volunteers on a <br /> committee if the members make or participate in making government decisions. The <br /> law further requires that each municipality review and amend its Code when necessary <br /> during even-numbered years. The Conflict of Interest Code designates employees, <br /> members of boards, committees, commissions, City officers and consultants, if <br /> applicable, who by virtue of their positions, make or participate in making decisions <br /> which may affect their financial interests and who therefore must disclose these <br /> interests on the Fair Political Practices Commission Form 700 — Statement of Economic <br /> Interests of Designated Employees. <br /> The Political Reform Act requires every local government agency to review its conflict- <br /> of-interest code every two years to determine whether the code must be amended. The <br /> update entails reviewing the disclosure categories and whether the designated <br /> employee list should be amended. It has been determined that the Codes in question <br /> required updating and the City Council, as the Code reviewing entity, is being notified <br /> and asked to take such action. <br /> The staff review process included affording Department Heads an opportunity to review, <br /> and revise their departments' listings of the Conflict of Interest Code. Amendments <br /> involved either changes in titles, addition or deletion of positions and designation of <br /> disclosure levels. The Successor Agency Conflict of Interest Code is also included. In <br /> regards to the Oversight Board, Craig Labadie, Legal Counsel to that body has <br /> reviewed the Conflict of Interest Code proposed and provided his concurrence. <br /> ALTERNATIVES <br /> It is a State mandate to update the Conflict of Interest Code and staff has determined <br /> that updates are required. <br /> FISCAL IMPACT <br /> The costs related to processing the Statement of Economic Interests are part of the City <br /> Clerk Department budget. <br /> ENVIRONMENTAL REVIEW <br /> The proposed action is not a "project" for purposes of CEQA, as that term is defined in <br /> CEQA Guidelines Section 15378, because it has no potential for resulting in either a <br /> direct or foreseeable physical change in the environment. <br />