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refers to both "conflicts of interest," as defined under applicable state and federal law, and <br />"divided allegiances," as defined in this policy. <br />This policy addresses how the City approaches actual or perceived conflicts. The definitions <br />provided encompass more than the specific conflict -of -interest scenarios addressed by the state <br />or federal laws. A conflict of interest not identified in this policy may still violate those laws. <br />City officials may have a legal conflict of interest even if their conduct does not amount to a <br />conflict under this Policy. Nothing in this policy authorizes, or should be interpreted as <br />authorizing, City officials to have an interest in a transaction prohibited by state or federal law. <br />Employees and elected officials who have a conflict of interest recognized by state or federal law <br />are subject to all applicable legal consequences. <br />The purpose of this Policy is to inform City elected officials, appointed commission members, <br />and staff of the City's broad definition of conflicts and to establish procedures for declaring and <br />monitoring conflicts as they arise. The City Council requires each elected official, appointed <br />commission member, and staff member to be advised of this policy, and provided with a copy <br />upon assuming their City's duties or relationship. All individuals subject to this policy are <br />responsible for understanding and adhering to it. <br />This policy recognizes that a conflict of interest may exist whenever the personal or professional <br />interests of an elected official, appointed commissioner, or staff member are potentially at odds <br />with City's interests. Since the City Council is responsible for ensuring that the organization's <br />management serves the City's best interests, over and above the interests of any insider, this <br />policy broadly defines potential conflicts of interest to include all instances when a person within <br />the organization may be able to exert authority, influence, or bias on any issue in which they may <br />have divided allegiances. <br />The City Council acknowledges that conflicts may exist not only from financial interests in a <br />transaction but also from non -financial interests. In all cases, the City Council is committed to <br />ensuring that whenever a dual interest exists — whether personal, business, organizational, or <br />professional — and it intersects with the position and interests of the City, such conflicts are <br />disclosed, and resulting decisions are managed fairly and appropriately. <br />Furthermore, the procedures outlined in this policy apply not only when an actual conflict is <br />demonstrated but also when the interests or concerns of another party to which one has <br />allegiance may reasonably be seen as competing with the City's interests or concerns. The City <br />Council's decision to apply heighted scrutiny and procedures when a conflict involving elected <br />official, appointed commissioner, or staff member appears to have a conflict acknowledges the <br />public's increasing sensitivity to self -dealing and lax management by public officials. <br />The three types (or "tiers") of conflicts defined in the policy are not mutually exclusive. An <br />interest that qualifies as a conflict of interest under one tier may also qualify under another tier, <br />depending on the specific circumstances. <br />CONFLICT OF INTEREST, DIVIDED ALLEGIANCES, AND DEFINITIONS <br />59 <br />