CONSENT ITEM
E-11
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
VIA: SERGIO GONZALEZ, CITY MANAGER
FROM: JEFFREY LAWRENCE CORNEJO, JR., CITY CLERK
DATE: SEPTEMBER 21, 2026
SUBJECT: CONSIDERATION OF NOTICE FOR BIENNIAL CONFLICT OF INTEREST CODE REVIEW
BACKGROUND:
Public officials and employees who make or influence government decisions are required under California law to file a Statement of Economic Interests, or Form 700, to publicly identify the kinds of financial interests that could be affected by their governmental duties. These public disclosure filings serve as a tool to help detect and avoid potential conflicts of interests and promote public confidence that actions on governmental decisions are made without any regard to personal gain.
The City’s Conflict of Interest Code designates which positions are required to file a Statement of Economic Interests (Form 700) and assigns disclosure categories specifying the types of interests to be reported based on the duties and responsibilities of each position.
Pursuant to the Political Reform Act and Government Code Section 87306.5, the City is required to conduct a review of its Conflict-of-Interest Code during each even-numbered year and make amendments as needed.
RECOMMENDATION:
Staff recommends that the City Council take the following actions:
1) Receive and file the 2026 Local Agency Conflict of Interest Code Biennial Review Notice; and 2) Direct Staff to conduct a biennial review of the City of Azusa Conflict of Interest Code and return to Council for approval.
ANALYSIS:
The Political Reform Act of 1974, Government Code Section 81000 et seq. (the “Act”), requires all public agencies to adopt and maintain a Conflict-of-Interest Code. The Act further requires that agencies regularly review and update their Codes as necessary when directed by the code-reviewing body or when change is necessitated by changed circumstances.
Conflict of Interest Code Review
September 21, 2026
When determining whether to amend, an agency should carefully review its current conflict of interest code and consider the following:
• Is the current code more than five years old?
• Have there been any substantial changes to the agency's organizational structure since the current code was adopted?
• Have any positions been eliminated or renamed since the current code was adopted? • Have any new positions been added since the current code was adopted? • Have there been any substantial changes in duties or responsibilities for any positions since the current code was adopted?
If an amendment to the agency's code is necessary, the code must be approved by the City Council within ninety (90) days.
FISCAL IMPACT:
There is no fiscal impact associated with this action.
Prepared by: Reviewed by:
Annete Juarez, MMC Jeffrey Lawrence Cornejo, Jr.
City Clerk Services Manager City Clerk
Reviewed and Approved:
Sergio Gonzalez
City Manager
Attachments:
1) 2026 Conflict of Interest Code Biennial Notice Instructions for Local Agencies 2) 2026 Local Agency Biennial Notice
[email protected] 1.866.275.3772 or 916.322.5660
www.fppc.ca.gov FPPC • 076-04.2026 • Page 1 of 1
FAIR POLITICAL PRACTICES COMMISSION
2026 Conflict of Interest Code
Biennial Notice Instructions for Local Agencies
The Political Reform Act requires every local government agency to review its conflict of interest code biennially. A conflict of interest code tells public officials, governmental employees, and consultants what financial interests they must disclose on their Statement of Economic Interests (Form 700).
By July 1, 2026: The code reviewing body must notify agencies and special districts within its jurisdiction to review their conflict of interest codes.
By October 1, 2026: The biennial notice must be filed with the agency’s code reviewing body.
The FPPC has prepared a 2026 Local Agency Biennial Notice form for local agencies to complete or send to agencies within its jurisdiction to complete before submitting to the code reviewing body. The City Council is the code reviewing body for city agencies. The County Board of Supervisors is the code reviewing body for county agencies and any other local government agency whose jurisdiction is determined to be solely within the county (e.g., school districts, including certain charter schools). The FPPC is the code reviewing body for any agency with jurisdiction in more than one county and will contact them.
The Local Agency Biennial Notice is not forwarded to the FPPC.
If amendments to an agency’s conflict of interest code are necessary, the amended code must be forwarded to the code reviewing body for approval within 90 days. An agency’s amended code is not effective until it has been approved by the code reviewing body.
If you answer yes, to any of the questions below, your agency’s code probably needs to be amended.
• Is the current code more than five years old?
• Have there been any substantial changes to the agency’s organizational structure since the last code was approved?
• Have any positions been eliminated or re-named since the last code was approved? • Have any new positions been added since the last code was approved? • Have there been any substantial changes in duties or responsibilities for any positions since the last code was approved?
If you have any questions or are still not sure if you should amend your agency’s conflict of interest code, please contact the FPPC. Additional information including an online webinar regarding how to amend a conflict of interest code is available on FPPC’s website. www.fppc.ca.gov
FPPC Advice: [email protected] (866.275.3772)
2026 Local Agency Biennial Notice
Name of Agency:
Mailing Address:
Contact Person: Phone No.
Email: Alternate Email:
Accurate disclosure is essential to monitor whether officials have conflicts of interest and to help ensure public trust in government. The biennial review examines current programs to ensure that the agency’s code includes disclosure by those agency officials who make or participate in making governmental decisions.
This agency has reviewed its conflict of interest code and has determined that (check one BOX):
An amendment is required. The following amendments are necessary:
(Check all that apply.)
Include new positions
Revise disclosure categories
Revise the titles of existing positions
Delete titles of positions that have been abolished and/or positions that no longer make or participate in making governmental decisions
Other (describe)
The code is currently under review by the code reviewing body.
No amendment is required. (If your code is over five years old, amendments may be necessary.)
Verification (to be completed if no amendment is required) This agency’s code accurately designates all positions that make or participate in the making of governmental decisions. The disclosure assigned to those positions accurately requires that all investments, business positions, interests in real property, and sources of income that may foreseeably be affected materially by the decisions made by those holding designated positions are reported. The code includes all other provisions required by Government Code Section 87302.
__________________________________________ _________________________ Signature of Chief Executive Officer Date
All agencies must complete and return this notice regardless of how recently your code was approved or amended. Please return this notice no later than October 1, 2026, or by the date specified by your agency, if earlier, to:
(PLACE RETURN ADDRESS OF CODE REVIEWING BODY HERE)
PLEASE DO NOT RETURN THIS FORM TO THE FPPC.