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2026-09-15; City Council; 03; 2026 Conflict of Interest Code Update

Carlsbad City Council
September 15, 2026

Document
2026-09-15; City Council; 03; 2026 Conflict of Interest Code Update
Meeting
September 15, 2026
Body
Carlsbad City Council
Pages
79
Original file
130 KB
Text extracted from the city's file for reading and search. Open the original on records.carlsbadca.gov. That file is the official record.

CA Review AZ

Meeting Date: Sept. 15, 2026

To: Mayor/President and City Council/Board

From: Geoff Patnoe, City Manager

Staff Contact: Morgen Fry, Assistant City Clerk
[email protected], 442-339-2808

Adriana Trujillo, Deputy City Clerk
[email protected], 442-339-2035

Anayeli Zavala, Deputy City Attorney
[email protected], 442-339-5272

Subject: 2026 Conflict of Interest Code Update

District: All

Recommended Action
1) Adopt a resolution amending the Conflict of Interest Code for the City of Carlsbad; and 2) Adopt a Carlsbad Municipal Water District Board of Directors resolution amending the Conflict of Interest Code for the District; and
3) Adopt a Community Development Commission resolution amending the Conflict of Interest Code for the Commission; and
4) Adopt a Public Financing Authority resolution amending the Conflict of Interest Code for the Authority; and
5) Adopt a City Council as a Successor Agency to the Redevelopment Agency resolution amending the Conflict of Interest Code for the Agency.

Executive Summary
The Political Reform Act of 1974 requires agencies to biennially review their local conflict of interest codes and amend them as necessary to reflect changes in designated positions and disclosure requirements. These codes designate the positions that are subject to financial disclosure requirements, and the level of disclosure that is required for each position.

Staff have reviewed the Conflict of Interest Code and prepared amendments reflecting changes to the code, to the disclosure categories and in designated positions that have been modified, added or deleted since the code was last reviewed in 2024.

The law requires the City Council’s approval of any such changes.

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Explanation & Analysis
Conflict of Interest Code
By agreement with the City of Carlsbad, the Carlsbad Municipal Water District, the Community Development Commission, the Carlsbad Public Financing Authority, and the City Council as the Successor Agency to the Redevelopment Agency have their services performed by city employees, and the city is reimbursed by the other legal entities for those costs. The appendix to the Conflict of Interest Code lists the designated positions that require anyone holding such positions to disclose their investments, real property interests, business positions and sources of income. An employee in a designated position may be disqualified from taking certain actions because the employee’s duties for the city or the other agencies include making or participating in making decisions that could affect the employee’s personal financial interests.

Staff’s biennial review of the code identified several designated positions that have been added, reclassified or eliminated, which requires the List of Designated Positions and Disclosure Categories to the Conflict of Interest Code to be amended accordingly.

Additionally, this biennial update also includes changes required by recent state legislation.

Assembly Bill 1029, effective Jan. 1, 2027, expands the definition of investments to include digital financial assets, such as cryptocurrencies. Assembly Bill 1286, effective Jan. 1, 2026, requires applicable positions to disclose arrangements for prospective employment in which a person has accepted a job offer from a future employer.

As provided in the Conflict of Interest Code, employees occupying these designated positions can expand their disclosure statements to cover reportable interests for all the jurisdictions they report. They can file these expanded disclosure statements with the City Clerk, provided each copy of the expanded disclosure statement is signed and verified by the designated employee as if it was an original.

The City Clerk’s Office, working with Human Resources and the City Attorney’s Office, has prepared an updated Conflict of Interest Code to reflect all changes in positions and disclosure requirements since the code was last adopted in 2024. A version showing all changes to the code is attached as Exhibit 6 to this report.

Fiscal Analysis
There is no significant fiscal impact as a result of adoption of these resolutions.

Next Steps
The City Clerk’s Office will post the updated Conflict of Interest Code with an amended appendix on the city’s website and notify affected employees of the amendments.

Environmental Evaluation
The proposed action to update the Conflict of Interest Code is exempt from environmental review under California Environmental Quality Act, or CEQA, Guidelines Section 15061(b)(3) and 15378(b)(5) as it can be seen with certainty that there is no possibility the proposed action may have a significant effect on the environment.

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Exhibits

1. City Council resolution

2. Carlsbad Municipal Water District resolution

3. Community Development Commission resolution

4. Public Financing Authority resolution

5. City Council as a Successor Agency to the Redevelopment Agency resolution

6. Amended Conflict of Interest Code, with revisions highlighted Sept. 15, 2026
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RESOLUTION NO. 2026-169 .

A

RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CARLSBAD,

CALIFORNIA, AMENDING THE CONFLICT OF INTEREST CODE FOR THE CITY

OF CARLSBAD
W
HEREAS, the City of Carlsbad has previously adopted and amended its Conflict of Interest Code; and
WHEREAS, provisions of the Political Reform Act of 1974 (“the Act”) (Government Code Sections 81000 et seq.) require an amendment to the code due to revisions to the Act, changed circumstances, changed duties or new positions; and
WHEREAS, the City Council is the code reviewing body within the meaning of the Act; and WHEREAS, the City Clerk’s Office has prepared amendments to the Conflict of Interest Code , Appendix, and List of Designated Positions and Disclosure Categories that are required to be incorporated in the code.

NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Carlsbad, California, as follows:

1. That the above recitations are true and correct.

2. The proposed action to update the Conflict of Interest Code is exempt from environmental review under California Environmental Quality Act, or CEQA, Guidelines Section 15061(b)(3) and 15378(b)(5) as it can be seen with certainty that there is no possibility the proposed action may have a significant effect on the environment.

3. That the revised Conflict of Interest Code (Attachment A), Appendix (Attachment B) and List of Designated Positions and Disclosure Categories (Attachment C) for the combined City of Carlsbad, City Council as Successor Agency to the Redevelopment Agency, Community Development Commission, Carlsbad Municipal Water District, and Public Financing Authority reflecting change s to designated positions and disclosure requirements since the last amendment are approved.

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Docusign Envelope ID: 6BCF492D-2272-8C49-80FE-E4825FBF206F PASSED, APPROVED AND ADOPTED at a Joint Special Meeting of the City Council of the City of Carlsbad, the Carlsbad Municipal Water District, the Community Development Commission, the Public Financing Authority, and the City Council a s Successor Agency to the Redevelopment Agency on the 15th day of September, 2026, by the following vote, to wit:

AYES: Blackburn, Bhat-Patel, Acosta, Burkholder, Shin.

NAYS: None.

ABSTAIN: None.

ABSENT: None.
_______
_______________________________
KEITH BLACKBURN, Mayor
_______
_______________________________
SHERRY FREISINGER, City Clerk
(SEAL)
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Attachment A

CONFLICT
OF

INTEREST CODE

for the

City of Carlsbad
Carlsbad Municipal Water District
Community Development Commission
Carlsbad Public Financing Authority
City of Carlsbad as Successor Agency to the Carlsbad
Redevelopment Agency

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Carlsbad Local Conflict of Interest Code
Sept. 15, 2026

SECTION I: Title: This code shall be known and may be cited as "Conflict of Interest Code for the City of Carlsbad, the Carlsbad Municipal Water District , the Community Development Commission, Carlsbad Public Financing Authority and the City of Carlsbad as Successor Agency to the Carlsbad Redevelopment Agency."

SECTION II: Authority: This code is adopted under the provisions of the Political Reform Act of 1974, found in the California Government Code beginning with Section 81000, and its implementing regulations, found in Title 2 of the California Code of Regulations beginning with Section 18700.

SECTION III: Purpose: This code is adopted in order to:

A. Assure that all designated employees and individuals perform their duties in an impartial manner, free from bias caused by financial interests; B. Enumerate and differentiate the positions of employment within the c ity which involve the making of decisions which may foreseeably have a material effect upon a financial interest;
C. Require the disclosure of such interests, by setting forth the specific types of interests which are reportable for each position; and
D. Require that designated employees disqualify themselves f rom participation in city decision-making which may involve a conflict of interest.

SECTION IV: Incorporation by Reference : Except as stated in Section V below, t he standard conflict of interest code prepared by the Fair Political Practices Commission, found in Title 2, Section 18730, of the California Code of Regulations, as it may be amended from time to time, is incorporated by this reference. Together with the attached Appendix and List of D esignated Positions and Disclosure Categories, it constitutes the “Conflict of Interest Code for the City of Carlsbad, the Carlsbad Municipal Water District, the Community Development Commission, Carlsbad Public Financing Authority and the City of Carlsbad as Successor Agency to the Carlsbad Redevelopment Agency."

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Carlsbad Local Conflict of Interest Code
Sept. 15, 2026

SECTION V: Amendments to Standard Conflict of Interest Code:

A. Section 9.5 of the standard conflict of interest code found in Title 2, Section 18730, of the California Code of Regulations is deleted as it applies only to state officers and employees.

B. Section 4 of the standard conflict of interest code found in Title 2, Section 18730, of the California Code of Regulations is amended to read as follows:

Section 4: All designated employees and individuals shall file their statements of economic interests with the City of Carlsbad’s City Clerk ’s Office, which will make the statements available on the city’s website for public viewing and downloading.

SECTION VI: Repeal: This code shall repeal and supersede all previous versions of the “Conflict of Interest Code for the City of Carlsbad, the Carlsbad Municipal Water District, the Community Development Commission, Carlsbad Public Financing Authority and the City of Carlsbad as Successor Agency to the Carlsbad Redevelopment Agency."

SECTION VII: Effective date: This code shall be effective upon adoption by resolution of the appropriate code reviewing body.

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APPENDIX
for

CONFLICT OF INTEREST CODE

DISCLOSURE CATEGORIES AND DESIGNATED POSITIONS

General Provisions
When designated employees or individuals are required to disclose investments, business positions and sources of income, they need to only disclose investments in business entities and sources of income which do business in the c ity, plan to do business in the c ity or have done business in the c ity within the past 2 years. In addition to other activities, a business entity is doing business within the city if it owns real property within the city. When designated employees or individuals are required to disclose real property they need to only disclose that which is located in whole or in part, within or not more than 2 miles outside the boundaries of the city or within 2 miles of any land owned or used by the city. Digital financial assets must be disclosed commencing January 1, 2027, if the fair market value of the in vestment equals or exceeds two thousand dollars ($2,000) and must be identified by the name of the asset as commonly known to the public.

Designated employees or individuals shall disclose their financial interest pursuant to the appropriate disclosure category as indicated in the List of Designated Positions and Disclosure Categories.

Resource: Title 2, California Code of Regulations, Section 18730 Provisions of Conflict of Interest Codes.

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Disclosure Categories

Category 1: Designated employees or individuals shall report all investments, including digital financial assets (e.g., cryptocurrency), business positions in business entities, and income , including gifts, loans and travel payment s, from sources in or doing business in Carlsbad.

Category 2: Designated employees and individuals shall report all real property interests within Carlsbad, including property located within a two -mile radius of any property owned or used by the City of Carlsbad.

Category 3: Designated employees or individuals shall report all investments, including digital financial assets (e.g., cryptocurrency), business positions in business entities and income, including gifts, loans and travel payments, from sources which engage in the appraisal, acquisition, disposal, development, rehabilitation, or construction of improvements on real property in Carlsbad, including real property located within a two -mile radius of any property owned or used by the City of Carlsbad.

Category 4: Designated employees or individuals shall report all investments, including digital financial assets (e.g., cryptocurrency), business positions in business entities, and income, including gifts, loans and travel payments, from any source, in or doing business within Carlsbad, which provide s services, supplies, materials, machinery or equipment of the type utilized by the city.

Category 5: Designated employees or individuals shall report all investments, including digital financial assets (e.g., cryptocurrency), business positions in business entities, and income, including gifts, loans and travel payments, from any source, in or doing business within Carlsbad, which provide s services, supplies, materials, machinery or equipment of the type utilized by the designated employee’s or individual’s department.

Section 87200 Filers
Employees and individuals to whom California Government Code Section 87200 applies, including the City Council and City Treasurer, candidates for these elected offices, the P lanning Commission, the City Manager, the City Attorney, the Deputy City Manager of Administrative Services, and other public officials who manage public investments, are required to fully disclose their personal assets and income, including digital financial assets as provided in the General Provisions above . These employees and individuals shall also disclos e any arrangement for prospective employment, which applies when the person has accepted an offer of employment, whether the acceptance is verbal or written, and the disclosure must contain (i) the date the filer accepted the offer of employment, (ii) the business position, (iii) general description of the business activity of the prospective employer, and (iv) the name and street address of the prospective employer.

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Consultants
“Consultant” is defined by the Fair Political Practices Commission, as an individual who, pursuant to a contract with a state or local governmental agency:
(a) Makes a governmental decision to:

1. Approve a rate, rule or regulation;

2. Adopt or enforce a law;

3. Issue, deny, suspend, or revoke any permit, license, application, certificate, approval, order, or similar authorization or entitlement;

4. Authorize the agency to enter into, modify, or renew a contract provided it is the type of contract that requires agency approval;

5. Grant agency approval to a contract that requires agency approval and in which the agency is a party, or to the specifications for such a contract;

6. Grants agency approval to a plan, design, report, study, or similar item;

7. Adopt, or grant agency approval of, policies, standards, or guidelines for the agency, or for any subdivision of the agency; or

(b ) Serves in a staff capacity with the agency and in that capacity participates in making a governmental decision or performs the same or substantially all the same duties for the agency that would otherwise be performed by an individual holding a position designated in the agency’s conflict of interest code.

A consultant does not act in a staff capacity where the work is to be performed on one project or a limited number of projects over a limited period of time, or where the relationship between the contractor and the agency would last only 12-16 months with no ongoing relationship contemplated, or where, under a multi -year contract, the contractor would perform only on a sporadic basis.

A consultant participates in making a governmental decision if the consultant provides information, an opinion, or a recommendation for the purpose of affecting the decision without significant intervene substantive review.

The staff person most knowledgeable of the work that a c onsultant will be performing shall designate whether the consultant must file a Statement of Economic Interest by marking the appropriate box in the contract and/or on the c ontract cover sheet. When a consultant is designated and is responsible for disclosure, the consultant shall be required to file a Statement of Economic Interest disclosing reportable interests in Disclosure Categories 1 and 2.

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LIST OF DESIGNATED POSITIONS AND DISCLOSURE CATEGORIES

FULL DISCLOSURE DESIGNATED POSITIONS DISCLOSURE CATEGORIES Mayor & City Council Members (87200 Filer) Full Disclosure Treasurer (87200 Filer) Full Disclosure
City Clerk Full Disclosure
Planning Commission Members (87200 Filer) Full Disclosure City Manager (87200 Filer) Full Disclosure
City Attorney (87200 Filer) Full Disclosure
Members of the Successor Agency of the Carlsbad Redevelopment Agency – Includes Chairman/Members, Executive Director, Counsel, Secretary (87200 Filer)
Full Disclosure
Public Financing Authority Members – Includes
Chairman/Members, Executive Director, Counsel, Secretary, Treasurer (87200 Filer)
Full Disclosure
Community Development Commission Members – Includes
Chairman/Members, Executive Director, Counsel, Secretary (87200 Filer)
Full Disclosure
Carlsbad Municipal Water District Board of Directors Members – Includes Board Members, Counsel, Secretary (87200 Filer) Full Disclosure

OFFICIALS WHO MANAGE PUBLIC INVESTMENTS
Deputy City Manager (Administrative Services) (87200 Filer) Full Disclosure Finance Director (87200 Filer) Full Disclosure
Investment Review Board Members (87200 Filer) Full Disclosure Senior Accountant (87200 Filer) Full Disclosure

POSITIONS UNDER THE CITY MANAGER

DESIGNATED POSITIONS DISCLOSURE CATEGORIES
Accountant 1, 2
Accounting Supervisor 1, 2
Assistant City Clerk 1, 2
Assistant City Manager 1, 2
Assistant Director of Community Development 1, 2
Assistant Director of Emergency Services 1, 2
Assistant Director of Transportation 1, 2
Assistant Engineer 2, 3, 5
Assistant Finance Director 1, 2
Assistant Fire Chief 1, 2
Assistant Fire Marshal 2, 3, 5
Assistant Human Resources Director 1, 2
Assistant IT Director 1, 2
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Carlsbad Local Conflict of Interest Code
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Assistant Planner 2, 3, 5
Assistant Police Chief 1, 2
Assistant Utilities Director 1, 2
Associate Contract Administrator 1, 2
Associate Engineer 2, 3, 5
Associate Management Analyst 2, 3, 5
Associate Planner 2, 3, 5
Building Inspector I/II 1, 2
Building Official 1, 2
Business Intelligence & Analytics Manager 1, 2
Business Intelligence Analyst 1, 2
Business Systems Specialist 2, 5
Business Technology Manager 1, 2
Buyer/Contract Administrator 1, 2
City Planner 1, 2
City Traffic Engineer 1, 2
Code Enforcement Manager 1, 2
Code Enforcement Officer I/II 1, 2
Communication & Engagement Director 1, 2
Communications Coordinator 1, 2
Community Arts Coordinator 1, 2
Community Development Director 1, 2
Community Health Nurse 1, 2
Community Relations Manager 2, 5
Construction Inspector I/II 1,2
Contract Administrator 1, 2
Cultural Arts Manager 1, 2
Deputy City Clerk 1, 2
Deputy City Manager (Administrative Services – see OFFICIALS WHO

MANAGE PUBLIC INVESTMENTS)
1, 2
Deputy Library Director 1, 2
Deputy Fire Marshall 2, 3, 5
Development Services Manager 1, 2
Development Services Supervisor 2, 3
Director of Constituent & Clerk Services 1, 2
Economic Development Director 1, 2
Engineering Manager 1, 2
Environmental Manager 1, 2
Environmental Specialist I/II/Senior 2, 3, 5
Environmental Sustainability Director 1,2
Executive Assistant 1, 2
Finance Manager 1, 2
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Carlsbad Local Conflict of Interest Code
Sept. 15, 2026

Finance/Payroll/IT Manager 1, 2
Fire Administrator 1, 2
Fire Battalion Chief 1, 2
Fire Chief 1, 2
Fire Division Chief 1, 2
Fire Inspector 1, 2
GIS Administrator 1, 2
GIS Analyst 1,2
Homeless Services Manager 1, 2
Housing & Homeless Services Director 1, 2
Housing Services Manager 1, 2
Human Resources Analyst 1,2
Human Resources Director 1, 2
Human Resources Manager 1, 2
Information Technology Director 1, 2
Information Technology Manager 1, 2
Information Technology Project Manager 1, 2
Information Technology Security Manager 1, 2
Information Technology Senior Project Manager 1,2
Inspector I/II 1, 2
Intergovernmental Affairs Director 1, 2
Internal Audit Manager 1, 2
Library & Cultural Arts Director 1, 2
Management Analyst 1, 2
Management Assistant 1,2
Meter Services Supervisor 2, 5
Municipal Projects Manager 1, 2
Parks and Recreation Director 1, 2
Park Planner 2, 3, 5
Park Planning Manager 1, 2
Parks Services Manager 1, 2
Parks Superintendent 1, 2
Parks/Trees Supervisor 2, 5
Police Administrative Manager 1, 2
Police Captain 1, 2
Police Chief 1, 2
Police Communications Manager 1, 2
Police Lieutenant 1, 2
Principal Engineer 1,2
Principal Librarian 1, 5
Principal Planner 1, 2
Principal Management Analyst 1,2
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Carlsbad Local Conflict of Interest Code
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Program Manager 1, 2
Public Works Manager 1, 2
Public Works Superintendent 1, 2
Public Works Supervisor 2, 4
Real Estate Manager 1, 2
Recreation Area Manager 1, 2
Recreation Services Manager 1, 2
Risk Manager 1, 2
Safety & Compliance Manager 1, 2
Safety Training Center Supervisor 1, 2
SCADA Supervisor 2, 5
Senior Applications Analyst 2, 5
Senior Building Inspector 1, 2
Senior Business Systems Specialist 1, 2
Senior Code Enforcement Officer 1, 2
Senior Construction Inspector 1, 2
Senior Contract Administrator 1, 2
Senior Database Administrator 1, 2
Senior Deputy City Clerk 1, 2
Senior Engineer 1, 2
Senior Fire Inspector/Investigator 1, 2
Senior Human Resources Officer 1, 2
Senior Management Analyst 1, 2
Senior Network Engineer 2, 4, 5
Senior Planner 1, 2
Senior Program Manager 1, 2
Senior System Administrator 2, 5
Special Projects Manager 1, 2
Systems Administrator 2, 5
Transportation Director 1, 2
Transportation Planning & Mobility Manager 1, 2
Utilities Director 1, 2
Utilities Maintenance Planner 1, 2
Utilities Manager 1, 2
Utilities Senior Engineer 1, 2
Utilities Superintendent 1, 2
Utilities Supervisor 2, 5
Utilities Technical Services Manager 1, 2
Warehouse Technician 2, 5

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Carlsbad Local Conflict of Interest Code
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CITY ATTORNEY’S OFFICE

DESIGNATED POSITIONS DISCLOSURE CATEGORIES
Assistant City Attorney 1, 2
Deputy City Attorney 1, 2
Executive Assistant 1, 2
Senior Assistant City Attorney 1, 2
Senior Management Analyst 1, 2

BOARDS/COMMISSIONS/COMMITTEES (Members of Designated Appointed Positions)

DESIGNATED POSITIONS DISCLOSURE CATEGORIES
Agricultural Conversion Mitigation Fee Ad Hoc Citizens Advisory Committee
1, 2
Arts Commission 1, 2
Board of Library Trustees 1, 2
Community-Police Engagement Commission 1, 2
Environmental Sustainability Commission 1,2
Historic Preservation Commission 1, 2
Housing Commission 1, 2
Parks & Recreation Commission 1, 2
Senior Commission 1, 2
Traffic Safety & Mobility Commission 1, 2

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RESOLUTION NO. 1811 .

A

RESOLUTION OF THE CARLSBAD MUNICIPAL WATER DISTRICT BOARD OF

DIRECTORS OF THE CITY OF CARLSBAD, CALIFORNIA, AMENDING THE

CONFLICT OF INTEREST CODE FOR THE DISTRICT
W
HEREAS, the Carlsbad Municipal Water District has previously adopted and amended its Conflict of Interest Code; and
WHEREAS, provisions of the Political Reform Act of 1974 (“the Act”) (Government Code Sections 81000 et seq.) require an amendment to the code due to revisions to the Act, changed circumstances, changed duties or new positions; and
WHEREAS, the Board of Directors is the code reviewing body within the meaning of the Act; and WHEREAS, the Secretary has prepared amendments to the Conflict of Interest Code, Appendix, and List of Designated Positions and Disclosure Categories that are required to be incorporated in the code.

NOW, THEREFORE, BE IT RESOLVED by the Carlsbad Municipal Water District of the City of Carlsbad, California, as follows:

1. That the above recitations are true and correct.

2. The proposed action to update the Conflict of Interest Code is exempt from environmental review under California Environmental Quality Act, or CEQA, Guidelines Section 15061(b)(3) and 15378(b)(5) as it can be seen with certainty that there is no possibility the proposed action may have a significant effect on the environment.

3. That the revised Conflict of Interest Code (Attachment A), Appendix (Attachment B) and List of Designated Positions and Disclosure Categories (Attachment C) for the combined City of Carlsbad, City Council as Successor Agency to the Redevelopment Agency, Community Development Commission, Carlsbad Municipal Water District, and Public Financing Authority reflecting the change s to designated positions and disclosure requirements since the last amendment are approved.

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Docusign Envelope ID: 6BCF492D-2272-8C49-80FE-E4825FBF206F PASSED, APPROVED AND ADOPTED at a Joint Special Meeting of the Carlsbad Municipal Water District, the City Council of the City of Carlsbad, the Community Development Commission, the Public Financing Authority, and the City Council as Successor Agency to the Redevelopment Agency on the 15th day of September, 2026, by the following vote, to wit:

AYES: Blackburn, Bhat-Patel, Acosta, Burkholder, Shin.

NAYS: None.

ABSTAIN: None.

ABSENT: None.
_______
_______________________________
KEITH BLACKBURN, President
_______
_______________________________
SHERRY FREISINGER, Secretary
(SEAL)
Sept. 15, 2026
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Attachment A

CONFLICT
OF

INTEREST CODE
for the
City of Carlsbad
Carlsbad Municipal Water District
Community Development Commission
Carlsbad Public Financing Authority
City of Carlsbad as Successor Agency to the Carlsbad
Redevelopment Agency
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Docusign Envelope ID: 6BCF492D-2272-8C49-80FE-E4825FBF206F Carlsbad Local Conflict of Interest Code
Sept. 15, 2026
SECTION I: Title: This code shall be known and may be cited as "Conflict of Interest Code for the City of Carlsbad, the Carlsbad Municipal Water District , the Community Development Commission, Carlsbad Public Financing Authority and the City of Carlsbad as Successor Agency to the Carlsbad Redevelopment Agency."
S
ECTION II: Authority: This code is adopted under the provisions of the Political Reform Act of 1974, found in the California Government Code beginning with Section 81000, and its implementing regulations, found in Title 2 of the California Code of Regulations beginning with Section 18700.

SE
CTION III: Purpose: This code is adopted in order to:

A. As
sure that all designated employees and individuals perform their duties in an impartial manner, free from bias caused by financial interests; B. Enumerate and differentiate the positions of employment within the c ity which involve the making of decisions which may foreseeably have a material effect upon a financial interest;
C. Require the disclosure of such interests, by setting forth the specific types of interests which are reportable for each position; and
D. Require that designated employees disqualify themselves f rom participation in city decision-making which may involve a conflict of interest.

S
ECTION IV: Incorporation by Reference : Except as stated in Section V below, t he standard conflict of interest code prepared by the Fair Political Practices Commission, found in Title 2, Section 18730, of the California Code of Regulations, as it may be amended from time to time, is incorporated by this reference. Together with the attached Appendix and List of D esignated Positions and Disclosure Categories, it constitutes the “Conflict of Interest Code for the City of Carlsbad, the Carlsbad Municipal Water District, the Community Development Commission, Carlsbad Public Financing Authority and the City of Carlsbad as Successor Agency to the Carlsbad Redevelopment Agency."
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Sept. 15, 2026
SECTION V: Amendments to Standard Conflict of Interest Code:

A. Se
ction 9.5 of the standard conflict of interest code found in Title 2, Section 18730, of the California Code of Regulations is deleted as it applies only to state officers and employees.

B. Section 4 of the standard conflict of interest code found in Title 2, Section 18730, of the California Code of Regulations is amended to read as follows:

Se
ction 4: All designated employees and individuals shall file their statements of economic interests with the City of Carlsbad’s City Clerk ’s Office, which will make the statements available on the city’s website for public viewing and downloading.

S
ECTION VI: Repeal: This code shall repeal and supersede all previous versions of the “Conflict of Interest Code for the City of Carlsbad, the Carlsbad Municipal Water District, the Community Development Commission, Carlsbad Public Financing Authority and the City of Carlsbad as Successor Agency to the Carlsbad Redevelopment Agency." SE
CTION VII: Effective date: This code shall be effective upon adoption by resolution of the appropriate code reviewing body.

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Docusign Envelope ID: 6BCF492D-2272-8C49-80FE-E4825FBF206F Attachment B

APPENDIX
for

CONFLICT OF INTEREST CODE

DISCLOSURE CATEGORIES AND DESIGNATED POSITIONS

General Provisions
When designated employees or individuals are required to disclose investments, business positions and sources of income, they need to only disclose investments in business entities and sources of income which do business in the c ity, plan to do business in the c ity or have done business in the c ity within the past 2 years. In addition to other activities, a business entity is doing business within the city if it owns real property within the city. When designated employees or individuals are required to disclose real property they need to only disclose that which is located in whole or in part, within or not more than 2 miles outside the boundaries of the city or within 2 miles of any land owned or used by the city. Digital financial assets must be disclosed commencing January 1, 2027, if the fair market value of the in vestment equals or exceeds two thousand dollars ($2,000) and must be identified by the name of the asset as commonly known to the public.

Designated employees or individuals shall disclose their financial interest pursuant to the appropriate disclosure category as indicated in the List of Designated Positions and Disclosure Categories.

Resource: Title 2, California Code of Regulations, Section 18730 Provisions of Conflict of Interest Codes.

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D
isclosure Categories
C
ategory 1: Designated employees or individuals shall report all investments, including digital financial assets (e.g., cryptocurrency), business positions in business entities, and income , including gifts, loans and travel payment s, from sources in or doing business in Carlsbad.

C
ategory 2: Designated employees and individuals shall report all real property interests within Carlsbad, including property located within a two -mile radius of any property owned or used by the City of Carlsbad.

C
ategory 3: Designated employees or individuals shall report all investments, including digital financial assets (e.g., cryptocurrency), business positions in business entities and income, including gifts, loans and travel payments, from sources which engage in the appraisal, acquisition, disposal, development, rehabilitation, or construction of improvements on real property in Carlsbad, including real property located within a two -mile radius of any property owned or used by the City of Carlsbad.

C
ategory 4: Designated employees or individuals shall report all investments, including digital financial assets (e.g., cryptocurrency), business positions in business entities, and income, including gifts, loans and travel payments, from any source, in or doing business within Carlsbad, which provide s services, supplies, materials, machinery or equipment of the type utilized by the city.

C
ategory 5: Designated employees or individuals shall report all investments, including digital financial assets (e.g., cryptocurrency), business positions in business entities, and income, including gifts, loans and travel payments, from any source, in or doing business within Carlsbad, which provide s services, supplies, materials, machinery or equipment of the type utilized by the designated employee’s or individual’s department.

Se
ction 87200 Filers
Employees and individuals to whom California Government Code Section 87200 applies, including the City Council and City Treasurer, candidates for these elected offices, the P lanning Commission, the City Manager, the City Attorney, the Deputy City Manager of Administrative Services, and other public officials who manage public investments, are required to fully disclose their personal assets and income, including digital financial assets as provided in the General Provisions above . These employees and individuals shall also disclos e any arrangement for prospective employment, which applies when the person has accepted an offer of employment, whether the acceptance is verbal or written, and the disclosure must contain (i) the date the filer accepted the offer of employment, (ii) the business position, (iii) general description of the business activity of the prospective employer, and (iv) the name and street address of the prospective employer.

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Consultants
“Consultant” is defined by the Fair Political Practices Commission, as an individual who, pursuant to a contract with a state or local governmental agency:
(a) Makes a governmental decision to:

1. Approve a rate, rule or regulation;

2. Adopt or enforce a law;

3. Issue, deny, suspend, or revoke any permit, license, application, certificate, approval, order, or similar authorization or entitlement;

4. Authorize the agency to enter into , modify, or renew a contract provided it is the type of contract that requires agency approval;

5. Grant agency approval to a contract that requires agency approval and in which the agency is a party, or to the specifications for such a contract;

6. Grants agency approval to a plan, design, report, study, or similar item;

7. Adopt, or grant agency approval of, policies, standards, or guidelines for the agency, or for any subdivision of the agency; or

(b ) Serves in a staff capacity with the agency and in that capacity participates in making a governmental decision or performs the same or substantially all the same duties for the agency that would otherwise be performed by an individual holding a position designated in the agency’s conflict of interest code.

A consultant does not act in a staff capacity where the work is to be performed on one project or a limited number of projects over a limited period of time, or where the relationship between the contractor and the agency would last only 12-16 months with no ongoing relationship contemplated, or where, under a multi -year contract, the contractor would perform only on a sporadic basis.

A consultant participates in making a governmental decision if the consultant provides information, an opinion, or a recommendation for the purpose of affecting the decision without significant intervene substantive review.

The staff person most knowledgeable of the work that a c onsultant will be performing shall designate whether the consultant must file a Statement of Economic Interest by marking the appropriate box in the contract and/or on the c ontract cover sheet. When a consultant is designated and is responsible for disclosure, the consultant shall be required to file a Statement of Economic Interest disclosing reportable interests in Disclosure Categories 1 and 2.

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Docusign Envelope ID: 6BCF492D-2272-8C49-80FE-E4825FBF206F Attachment C

LIST OF DESIGNATED POSITIONS AND DISCLOSURE CATEGORIES

FULL DISCLOSURE DESIGNATED POSITIONS DISCLOSURE CATEGORIES Mayor & City Council Members (87200 Filer) Full Disclosure Treasurer (87200 Filer) Full Disclosure
City Clerk Full Disclosure
Planning Commission Members (87200 Filer) Full Disclosure City Manager (87200 Filer) Full Disclosure
City Attorney (87200 Filer) Full Disclosure
Members of the Successor Agency of the Carlsbad Redevelopment Agency – Includes Chairman/Members, Executive Director, Counsel, Secretary (87200 Filer)
Full Disclosure
Public Financing Authority Members – Includes
Chairman/Members, Executive Director, Counsel, Secretary, Treasurer (87200 Filer)
Full Disclosure
Community Development Commission Members – Includes
Chairman/Members, Executive Director, Counsel, Secretary (87200 Filer)
Full Disclosure
Carlsbad Municipal Water District Board of Directors Members – Includes Board Members, Counsel, Secretary (87200 Filer) Full Disclosure

OFFICIALS WHO MANAGE PUBLIC INVESTMENTS
Deputy City Manager (Administrative Services) (87200 Filer) Full Disclosure Finance Director (87200 Filer) Full Disclosure
Investment Review Board Members (87200 Filer) Full Disclosure Senior Accountant (87200 Filer) Full Disclosure

POSITIONS UNDER THE CITY MANAGER

DESIGNATED POSITIONS DISCLOSURE CATEGORIES
Accountant 1, 2
Accounting Supervisor 1, 2
Assistant City Clerk 1, 2
Assistant City Manager 1, 2
Assistant Director of Community Development 1, 2
Assistant Director of Emergency Services 1, 2
Assistant Director of Transportation 1, 2
Assistant Engineer 2, 3, 5
Assistant Finance Director 1, 2
Assistant Fire Chief 1, 2
Assistant Fire Marshal 2, 3, 5
Assistant Human Resources Director 1, 2
Assistant IT Director 1, 2
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Assistant Planner 2, 3, 5
Assistant Police Chief 1, 2
Assistant Utilities Director 1, 2
Associate Contract Administrator 1, 2
Associate Engineer 2, 3, 5
Associate Management Analyst 2, 3, 5
Associate Planner 2, 3, 5
Building Inspector I/II 1, 2
Building Official 1, 2
Business Intelligence & Analytics Manager 1, 2
Business Intelligence Analyst 1, 2
Business Systems Specialist 2, 5
Business Technology Manager 1, 2
Buyer/Contract Administrator 1, 2
City Planner 1, 2
City Traffic Engineer 1, 2
Code Enforcement Manager 1, 2
Code Enforcement Officer I/II 1, 2
Communication & Engagement Director 1, 2
Communications Coordinator 1, 2
Community Arts Coordinator 1, 2
Community Development Director 1, 2
Community Health Nurse 1, 2
Community Relations Manager 2, 5
Construction Inspector I/II 1,2
Contract Administrator 1, 2
Cultural Arts Manager 1, 2
Deputy City Clerk 1, 2
Deputy City Manager (Administrative Services – see OFFICIALS WHO

MANAGE PUBLIC INVESTMENTS)
1, 2
Deputy Library Director 1, 2
Deputy Fire Marshall 2, 3, 5
Development Services Manager 1, 2
Development Services Supervisor 2, 3
Director of Constituent & Clerk Services 1, 2
Economic Development Director 1, 2
Engineering Manager 1, 2
Environmental Manager 1, 2
Environmental Specialist I/II/Senior 2, 3, 5
Environmental Sustainability Director 1,2
Executive Assistant 1, 2
Finance Manager 1, 2
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Finance/Payroll/IT Manager 1, 2
Fire Administrator 1, 2
Fire Battalion Chief 1, 2
Fire Chief 1, 2
Fire Division Chief 1, 2
Fire Inspector 1, 2
GIS Administrator 1, 2
GIS Analyst 1,2
Homeless Services Manager 1, 2
Housing & Homeless Services Director 1, 2
Housing Services Manager 1, 2
Human Resources Analyst 1,2
Human Resources Director 1, 2
Human Resources Manager 1, 2
Information Technology Director 1, 2
Information Technology Manager 1, 2
Information Technology Project Manager 1, 2
Information Technology Security Manager 1, 2
Information Technology Senior Project Manager 1,2
Inspector I/II 1, 2
Intergovernmental Affairs Director 1, 2
Internal Audit Manager 1, 2
Library & Cultural Arts Director 1, 2
Management Analyst 1, 2
Management Assistant 1,2
Meter Services Supervisor 2, 5
Municipal Projects Manager 1, 2
Parks and Recreation Director 1, 2
Park Planner 2, 3, 5
Park Planning Manager 1, 2
Parks Services Manager 1, 2
Parks Superintendent 1, 2
Parks/Trees Supervisor 2, 5
Police Administrative Manager 1, 2
Police Captain 1, 2
Police Chief 1, 2
Police Communications Manager 1, 2
Police Lieutenant 1, 2
Principal Engineer 1,2
Principal Librarian 1, 5
Principal Planner 1, 2
Principal Management Analyst 1,2
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Program Manager 1, 2
Public Works Manager 1, 2
Public Works Superintendent 1, 2
Public Works Supervisor 2, 4
Real Estate Manager 1, 2
Recreation Area Manager 1, 2
Recreation Services Manager 1, 2
Risk Manager 1, 2
Safety & Compliance Manager 1, 2
Safety Training Center Supervisor 1, 2
SCADA Supervisor 2, 5
Senior Applications Analyst 2, 5
Senior Building Inspector 1, 2
Senior Business Systems Specialist 1, 2
Senior Code Enforcement Officer 1, 2
Senior Construction Inspector 1, 2
Senior Contract Administrator 1, 2
Senior Database Administrator 1, 2
Senior Deputy City Clerk 1, 2
Senior Engineer 1, 2
Senior Fire Inspector/Investigator 1, 2
Senior Human Resources Officer 1, 2
Senior Management Analyst 1, 2
Senior Network Engineer 2, 4, 5
Senior Planner 1, 2
Senior Program Manager 1, 2
Senior System Administrator 2, 5
Special Projects Manager 1, 2
Systems Administrator 2, 5
Transportation Director 1, 2
Transportation Planning & Mobility Manager 1, 2
Utilities Director 1, 2
Utilities Maintenance Planner 1, 2
Utilities Manager 1, 2
Utilities Senior Engineer 1, 2
Utilities Superintendent 1, 2
Utilities Supervisor 2, 5
Utilities Technical Services Manager 1, 2
Warehouse Technician 2, 5

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CITY ATTORNEY’S OFFICE

DESIGNATED POSITIONS DISCLOSURE CATEGORIES
Assistant City Attorney 1, 2
Deputy City Attorney 1, 2
Executive Assistant 1, 2
Senior Assistant City Attorney 1, 2
Senior Management Analyst 1, 2
B
OARDS/COMMISSIONS/COMMITTEES (Members of Designated Appointed Positions)

DESIGNATED POSITIONS DISCLOSURE CATEGORIES
Agricultural Conversion Mitigation Fee Ad Hoc Citizens Advisory Committee
1, 2
Arts Commission 1, 2
Board of Library Trustees 1, 2
Community-Police Engagement Commission 1, 2
Environmental Sustainability Commission 1,2
Historic Preservation Commission 1, 2
Housing Commission 1, 2
Parks & Recreation Commission 1, 2
Senior Commission 1, 2
Traffic Safety & Mobility Commission 1, 2
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Docusign Envelope ID: 6BCF492D-2272-8C49-80FE-E4825FBF206F Exhibit 3
RESOLUTION NO. 585 .

A

RESOLUTION OF THE COMMUNITY DEVELOPMENT COMMISSION OF THE

CITY OF CARLSBAD, CALIFORNIA, AMENDING THE C ONFLICT OF INTEREST

CODE FOR THE COMMISSION
W
HEREAS, the Community Development Commission has previously adopted and amended its Conflict of Interest Code; and
WHEREAS, provisions of the Political Reform Act of 1974 (“the Act”) (Government Code Sections 81000 et seq.) require an amendment to the code due to revisions to the Act, changed circumstances, changed duties or new positions; and
WHEREAS, the Community Development Commission is the code reviewing body within the meaning of the Act; and
WHEREAS, the Secretary has prepared amendments to the Conflict of Interest Code, Appendix, and List of Designated Positions and Disclosure Categories that are required to be incorporated in the code.

NOW, THEREFORE, BE IT RESOLVED by the Community Development Commission of the City of Carlsbad, California, as follows:

1. That the above recitations are true and correct.

2. The proposed action to update the Conflict of Interest Code is exempt from environmental review under California Environmental Quality Act, or CEQA, Guidelines Section 15061(b)(3) and 15378(b)(5) as it can be seen with certainty that there is no possibility the proposed action may have a significant effect on the environment.

3. That the revised Conflict of Interest Code (Attachment A), Appendix (Attachment B) and List of Designated Positions and Disclosure Categories (Attachment C) for the combined City of Carlsbad, City Council as Successor Agency to the Redevelopment Agency, Community Development Commission, Carlsbad Municipal Water District, and Public Financing Authority reflecting the change s to designated position s and disclosure requirements since the last amendment are approved.

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Docusign Envelope ID: 6BCF492D-2272-8C49-80FE-E4825FBF206F PASSED, APPROVED AND ADOPTED at a Joint Special Meeting of the Community Development Commission, the Carlsbad Municipal Water District, the City Council of the City of Carlsbad, the Public Financing Authority, and the City Council a s Successor Agency to the Redevelopment Agency on the 15th day of September, 2026, by the following vote, to wit:

AYES: Blackburn, Bhat-Patel, Acosta, Burkholder, Shin.

NAYS: None.

ABSTAIN: None.

ABSENT: None.
_______
_______________________________
KEITH BLACKBURN, Chairperson
_______
_______________________________
GEOFF PATNOE, Secretary
(SEAL)
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Attachment A

CONFLICT
OF

INTEREST CODE

for the

City of Carlsbad
Carlsbad Municipal Water District
Community Development Commission
Carlsbad Public Financing Authority
City of Carlsbad as Successor Agency to the Carlsbad
Redevelopment Agency

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Carlsbad Local Conflict of Interest Code
Sept. 15, 2026

SECTION I: Title: This code shall be known and may be cited as "Conflict of Interest Code for the City of Carlsbad, the Carlsbad Municipal Water District , the Community Development Commission, Carlsbad Public Financing Authority and the City of Carlsbad as Successor Agency to the Carlsbad Redevelopment Agency."

SECTION II: Authority: This code is adopted under the provisions of the Political Reform Act of 1974, found in the California Government Code beginning with Section 81000, and its implementing regulations, found in Title 2 of the California Code of Regulations beginning with Section 18700.

SECTION III: Purpose: This code is adopted in order to:

A. Assure that all designated employees and individuals perform their duties in an impartial manner, free from bias caused by financial interests; B. Enumerate and differentiate the positions of employment within the c ity which involve the making of decisions which may foreseeably have a material effect upon a financial interest;
C. Require the disclosure of such interests, by setting forth the specific types of interests which are reportable for each position; and
D. Require that designated employees disqualify themselves f rom participation in city decision-making which may involve a conflict of interest.

SECTION IV: Incorporation by Reference : Except as stated in Section V below, t he standard conflict of interest code prepared by the Fair Political Practices Commission, found in Title 2, Section 18730, of the California Code of Regulations, as it may be amended from time to time, is incorporated by this reference. Together with the attached Appendix and List of D esignated Positions and Disclosure Categories, it constitutes the “Conflict of Interest Code for the City of Carlsbad, the Carlsbad Municipal Water District, the Community Development Commission, Carlsbad Public Financing Authority and the City of Carlsbad as Successor Agency to the Carlsbad Redevelopment Agency."

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Carlsbad Local Conflict of Interest Code
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SECTION V: Amendments to Standard Conflict of Interest Code:

A. Section 9.5 of the standard conflict of interest code found in Title 2, Section 18730, of the California Code of Regulations is deleted as it applies only to state officers and employees.

B. Section 4 of the standard conflict of interest code found in Title 2, Section 18730, of the California Code of Regulations is amended to read as follows:

Section 4: All designated employees and individuals shall file their statements of economic interests with the City of Carlsbad’s City Clerk ’s Office, which will make the statements available on the city’s website for public viewing and downloading.

SECTION VI: Repeal: This code shall repeal and supersede all previous versions of the “Conflict of Interest Code for the City of Carlsbad, the Carlsbad Municipal Water District, the Community Development Commission, Carlsbad Public Financing Authority and the City of Carlsbad as Successor Agency to the Carlsbad Redevelopment Agency."

SECTION VII: Effective date: This code shall be effective upon adoption by resolution of the appropriate code reviewing body.

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A

PPENDIX
for

CONFLICT OF INTEREST CODE

DISCLOSURE CATEGORIES AND DESIGNATED POSITIONS
General Provisions
When designated employees or individuals are required to disclose investments, business positions and sources of income, they need to only disclose investments in business entities and sources of income which do business in the c ity, plan to do business in the c ity or have done business in the c ity within the past 2 years. In addition to other activities, a business entity is doing business within the city if it owns real property within the city. When designated employees or individuals are required to disclose real property they need to only disclose that which is located in whole or in part, within or not more than 2 miles outside the boundaries of the city or within 2 miles of any land owned or used by the city. Digital financial assets must be disclosed commencing January 1, 2027, if the fair market value of the in vestment equals or exceeds two thousand dollars ($2,000) and must be identified by the name of the asset as commonly known to the public.

Designated employees or individuals shall disclose their financial interest pursuant to the appropriate disclosure category as indicated in the List of Designated Positions and Disclosure Categories.

Resource: Title 2, California Code of Regulations, Section 18730 Provisions of Conflict of Interest Codes.

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Disclosure Categories

Category 1: Designated employees or individuals shall report all investments, including digital financial assets (e.g., cryptocurrency), business positions in business entities, and income , including gifts, loans and travel payment s, from sources in or doing business in Carlsbad.

Category 2: Designated employees and individuals shall report all real property interests within Carlsbad, including property located within a two -mile radius of any property owned or used by the City of Carlsbad.

Category 3: Designated employees or individuals shall report all investments, including digital financial assets (e.g., cryptocurrency), business positions in business entities and income, including gifts, loans and travel payments, from sources which engage in the appraisal, acquisition, disposal, development, rehabilitation, or construction of improvements on real property in Carlsbad, including real property located within a two -mile radius of any property owned or used by the City of Carlsbad.

Category 4: Designated employees or individuals shall report all investments, including digital financial assets (e.g., cryptocurrency), business positions in business entities, and income, including gifts, loans and travel payments, from any source, in or doing business within Carlsbad, which provide s services, supplies, materials, machinery or equipment of the type utilized by the city.

Category 5: Designated employees or individuals shall report all investments, including digital financial assets (e.g., cryptocurrency), business positions in business entities, and income, including gifts, loans and travel payments, from any source, in or doing business within Carlsbad, which provide s services, supplies, materials, machinery or equipment of the type utilized by the designated employee’s or individual’s department.

Section 87200 Filers
Employees and individuals to whom California Government Code Section 87200 applies, including the City Council and City Treasurer, candidates for these elected offices, the P lanning Commission, the City Manager, the City Attorney, the Deputy City Manager of Administrative Services, and other public officials who manage public investments, are required to fully disclose their personal assets and income, including digital financial assets as provided in the General Provisions above . These employees and individuals shall also disclos e any arrangement for prospective employment, which applies when the person has accepted an offer of employment, whether the acceptance is verbal or written, and the disclosure must contain (i) the date the filer accepted the offer of employment, (ii) the business position, (iii) general description of the business activity of the prospective employer, and (iv) the name and street address of the prospective employer.

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Consultants
“Consultant” is defined by the Fair Political Practices Commission, as an individual who, pursuant to a contract with a state or local governmental agency:
(a) Makes a governmental decision to:

1. Approve a rate, rule or regulation;

2. Adopt or enforce a law;

3. Issue, deny, suspend, or revoke any permit, license, application, certificate, approval, order, or similar authorization or entitlement;

4. Authorize the agency to enter into , modify, or renew a contract provided it is the type of contract that requires agency approval;

5. Grant agency approval to a contract that requires agency approval and in which the agency is a party, or to the specifications for such a contract;

6. Grants agency approval to a plan, design, report, study, or similar item;

7. Adopt, or grant agency approval of, policies, standards, or guidelines for the agency, or for any subdivision of the agency; or

(b ) Serves in a staff capacity with the agency and in that capacity participates in making a governmental decision or performs the same or substantially all the same duties for the agency that would otherwise be performed by an individual holding a position designated in the agency’s conflict of interest code.

A consultant does not act in a staff capacity where the work is to be performed on one project or a limited number of projects over a limited period of time, or where the relationship between the contractor and the agency would last only 12-16 months with no ongoing relationship contemplated, or where, under a multi -year contract, the contractor would perform only on a sporadic basis.

A consultant participates in making a governmental decision if the consultant provides information, an opinion, or a recommendation for the purpose of affecting the decision without significant intervene substantive review.

The staff person most knowledgeable of the work that a c onsultant will be performing shall designate whether the consultant must file a Statement of Economic Interest by marking the appropriate box in the contract and/or on the c ontract cover sheet. When a consultant is designated and is responsible for disclosure, the consultant shall be required to file a Statement of Economic Interest disclosing reportable interests in Disclosure Categories 1 and 2.

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Docusign Envelope ID: 6BCF492D-2272-8C49-80FE-E4825FBF206F Attachment C

LIST OF DESIGNATED POSITIONS AND DISCLOSURE CATEGORIES

FULL DISCLOSURE DESIGNATED POSITIONS DISCLOSURE CATEGORIES Mayor & City Council Members (87200 Filer) Full Disclosure Treasurer (87200 Filer) Full Disclosure
City Clerk Full Disclosure
Planning Commission Members (87200 Filer) Full Disclosure City Manager (87200 Filer) Full Disclosure
City Attorney (87200 Filer) Full Disclosure
Members of the Successor Agency of the Carlsbad Redevelopment Agency – Includes Chairman/Members, Executive Director, Counsel, Secretary (87200 Filer)
Full Disclosure
Public Financing Authority Members – Includes
Chairman/Members, Executive Director, Counsel, Secretary, Treasurer (87200 Filer)
Full Disclosure
Community Development Commission Members – Includes
Chairman/Members, Executive Director, Counsel, Secretary (87200 Filer)
Full Disclosure
Carlsbad Municipal Water District Board of Directors Members – Includes Board Members, Counsel, Secretary (87200 Filer) Full Disclosure

OFFICIALS WHO MANAGE PUBLIC INVESTMENTS
Deputy City Manager (Administrative Services) (87200 Filer) Full Disclosure Finance Director (87200 Filer) Full Disclosure
Investment Review Board Members (87200 Filer) Full Disclosure Senior Accountant (87200 Filer) Full Disclosure

POSITIONS UNDER THE CITY MANAGER

DESIGNATED POSITIONS DISCLOSURE CATEGORIES
Accountant 1, 2
Accounting Supervisor 1, 2
Assistant City Clerk 1, 2
Assistant City Manager 1, 2
Assistant Director of Community Development 1, 2
Assistant Director of Emergency Services 1, 2
Assistant Director of Transportation 1, 2
Assistant Engineer 2, 3, 5
Assistant Finance Director 1, 2
Assistant Fire Chief 1, 2
Assistant Fire Marshal 2, 3, 5
Assistant Human Resources Director 1, 2
Assistant IT Director 1, 2
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Assistant Planner 2, 3, 5
Assistant Police Chief 1, 2
Assistant Utilities Director 1, 2
Associate Contract Administrator 1, 2
Associate Engineer 2, 3, 5
Associate Management Analyst 2, 3, 5
Associate Planner 2, 3, 5
Building Inspector I/II 1, 2
Building Official 1, 2
Business Intelligence & Analytics Manager 1, 2
Business Intelligence Analyst 1, 2
Business Systems Specialist 2, 5
Business Technology Manager 1, 2
Buyer/Contract Administrator 1, 2
City Planner 1, 2
City Traffic Engineer 1, 2
Code Enforcement Manager 1, 2
Code Enforcement Officer I/II 1, 2
Communication & Engagement Director 1, 2
Communications Coordinator 1, 2
Community Arts Coordinator 1, 2
Community Development Director 1, 2
Community Health Nurse 1, 2
Community Relations Manager 2, 5
Construction Inspector I/II 1,2
Contract Administrator 1, 2
Cultural Arts Manager 1, 2
Deputy City Clerk 1, 2
Deputy City Manager (Administrative Services – see OFFICIALS WHO

MANAGE PUBLIC INVESTMENTS)
1, 2
Deputy Library Director 1, 2
Deputy Fire Marshall 2, 3, 5
Development Services Manager 1, 2
Development Services Supervisor 2, 3
Director of Constituent & Clerk Services 1, 2
Economic Development Director 1, 2
Engineering Manager 1, 2
Environmental Manager 1, 2
Environmental Specialist I/II/Senior 2, 3, 5
Environmental Sustainability Director 1,2
Executive Assistant 1, 2
Finance Manager 1, 2
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Finance/Payroll/IT Manager 1, 2
Fire Administrator 1, 2
Fire Battalion Chief 1, 2
Fire Chief 1, 2
Fire Division Chief 1, 2
Fire Inspector 1, 2
GIS Administrator 1, 2
GIS Analyst 1,2
Homeless Services Manager 1, 2
Housing & Homeless Services Director 1, 2
Housing Services Manager 1, 2
Human Resources Analyst 1,2
Human Resources Director 1, 2
Human Resources Manager 1, 2
Information Technology Director 1, 2
Information Technology Manager 1, 2
Information Technology Project Manager 1, 2
Information Technology Security Manager 1, 2
Information Technology Senior Project Manager 1,2
Inspector I/II 1, 2
Intergovernmental Affairs Director 1, 2
Internal Audit Manager 1, 2
Library & Cultural Arts Director 1, 2
Management Analyst 1, 2
Management Assistant 1,2
Meter Services Supervisor 2, 5
Municipal Projects Manager 1, 2
Parks and Recreation Director 1, 2
Park Planner 2, 3, 5
Park Planning Manager 1, 2
Parks Services Manager 1, 2
Parks Superintendent 1, 2
Parks/Trees Supervisor 2, 5
Police Administrative Manager 1, 2
Police Captain 1, 2
Police Chief 1, 2
Police Communications Manager 1, 2
Police Lieutenant 1, 2
Principal Engineer 1,2
Principal Librarian 1, 5
Principal Planner 1, 2
Principal Management Analyst 1,2
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Program Manager 1, 2
Public Works Manager 1, 2
Public Works Superintendent 1, 2
Public Works Supervisor 2, 4
Real Estate Manager 1, 2
Recreation Area Manager 1, 2
Recreation Services Manager 1, 2
Risk Manager 1, 2
Safety & Compliance Manager 1, 2
Safety Training Center Supervisor 1, 2
SCADA Supervisor 2, 5
Senior Applications Analyst 2, 5
Senior Building Inspector 1, 2
Senior Business Systems Specialist 1, 2
Senior Code Enforcement Officer 1, 2
Senior Construction Inspector 1, 2
Senior Contract Administrator 1, 2
Senior Database Administrator 1, 2
Senior Deputy City Clerk 1, 2
Senior Engineer 1, 2
Senior Fire Inspector/Investigator 1, 2
Senior Human Resources Officer 1, 2
Senior Management Analyst 1, 2
Senior Network Engineer 2, 4, 5
Senior Planner 1, 2
Senior Program Manager 1, 2
Senior System Administrator 2, 5
Special Projects Manager 1, 2
Systems Administrator 2, 5
Transportation Director 1, 2
Transportation Planning & Mobility Manager 1, 2
Utilities Director 1, 2
Utilities Maintenance Planner 1, 2
Utilities Manager 1, 2
Utilities Senior Engineer 1, 2
Utilities Superintendent 1, 2
Utilities Supervisor 2, 5
Utilities Technical Services Manager 1, 2
Warehouse Technician 2, 5

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Carlsbad Local Conflict of Interest Code
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CITY ATTORNEY’S OFFICE

DESIGNATED POSITIONS DISCLOSURE CATEGORIES
Assistant City Attorney 1, 2
Deputy City Attorney 1, 2
Executive Assistant 1, 2
Senior Assistant City Attorney 1, 2
Senior Management Analyst 1, 2

BOARDS/COMMISSIONS/COMMITTEES (Members of Designated Appointed Positions)

DESIGNATED POSITIONS DISCLOSURE CATEGORIES
Agricultural Conversion Mitigation Fee Ad Hoc Citizens Advisory Committee
1, 2
Arts Commission 1, 2
Board of Library Trustees 1, 2
Community-Police Engagement Commission 1, 2
Environmental Sustainability Commission 1,2
Historic Preservation Commission 1, 2
Housing Commission 1, 2
Parks & Recreation Commission 1, 2
Senior Commission 1, 2
Traffic Safety & Mobility Commission 1, 2

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RESOLUTION NO. 105 .

A

RESOLUTION OF THE PUBLIC FINANCING AUTHORITY OF THE CITY OF

CARLSBAD, CALIFORNIA, AMENDING THE C ONFLICT OF INTEREST CODE

FOR THE AUTHORITY
W
HEREAS, the Public Financing Authority has previously adopted and amended its Conflict of Interest Code; and
WHEREAS, provisions of the Political Reform Act of 1974 (“the Act”) (Government Code Sections 81000 et seq.) require an amendment to the code due to revisions to the Act, changed circumstances, changed duties or new positions; and
WHEREAS, the Public Financing Authority is the code reviewing body within the meaning of the Act; and
WHEREAS, the Secretary has prepared amendments to the Conflict of Interest Code, Appendix, and List of Designated Positions and Disclosure Categories that are required to be incorporated in the code.

NOW, THEREFORE, BE IT RESOLVED by Public Financing Authority of the City of Carlsbad, California, as follows:

1. That the above recitations are true and correct.

2. The proposed action to update the Conflict of Interest Code is exempt from environmental review under California Environmental Quality Act, or CEQA, Guidelines Section 15061(b)(3) and 15378(b)(5) as it can be seen with certainty that there is no possibility the proposed action may have a significant effect on the environment.

3. That the revised Conflict of Interest Code (Attachment A), Appendix (Attachment B) and List of Designated Positions and Disclosure Categories (Attachment C) for the combined City of Carlsbad, City Council as Successor Agency to the Redevelopment Agency, Community Development Commission, Carlsbad Municipal Water District, and Public Financing Authority reflecting the change s to designated positions and disclosure requirements since the last amendment are approved.

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Docusign Envelope ID: 6BCF492D-2272-8C49-80FE-E4825FBF206F PASSED, APPROVED AND ADOPTED at a Joint Special Meeting of the Public Financing Authority, the City Council of the City of Carlsbad, the Carlsbad Municipal Water District, the Community Development Commission, and the City Council as Successor Agency to the Redevelopment Agency on the 15th day of September, 2026, by the following vote, to wit:

AYES: Blackburn, Bhat-Patel, Acosta, Burkholder, Shin.

NAYS: None.

ABSTAIN: None.

ABSENT: None.
_______
_______________________________
KEITH BLACKBURN, Chairperson
_______
_______________________________
SHERRY FREISINGER, Secretary
(SEAL)
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Attachment A

CONFLICT
OF

INTEREST CODE

for the

City of Carlsbad
Carlsbad Municipal Water District
Community Development Commission
Carlsbad Public Financing Authority
City of Carlsbad as Successor Agency to the Carlsbad
Redevelopment Agency

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Carlsbad Local Conflict of Interest Code
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SECTION I: Title: This code shall be known and may be cited as "Conflict of Interest Code for the City of Carlsbad, the Carlsbad Municipal Water District , the Community Development Commission, Carlsbad Public Financing Authority and the City of Carlsbad as Successor Agency to the Carlsbad Redevelopment Agency."

SECTION II: Authority: This code is adopted under the provisions of the Political Reform Act of 1974, found in the California Government Code beginning with Section 81000, and its implementing regulations, found in Title 2 of the California Code of Regulations beginning with Section 18700.

SECTION III: Purpose: This code is adopted in order to:

A. Assure that all designated employees and individuals perform their duties in an impartial manner, free from bias caused by financial interests; B. Enumerate and differentiate the positions of employment within the c ity which involve the making of decisions which may foreseeably have a material effect upon a financial interest;
C. Require the disclosure of such interests, by setting forth the specific types of interests which are reportable for each position; and
D. Require that designated employees disqualify themselves f rom participation in city decision-making which may involve a conflict of interest.

SECTION IV: Incorporation by Reference : Except as stated in Section V below, t he standard conflict of interest code prepared by the Fair Political Practices Commission, found in Title 2, Section 18730, of the California Code of Regulations, as it may be amended from time to time, is incorporated by this reference. Together with the attached Appendix and List of D esignated Positions and Disclosure Categories, it constitutes the “Conflict of Interest Code for the City of Carlsbad, the Carlsbad Municipal Water District, the Community Development Commission, Carlsbad Public Financing Authority and the City of Carlsbad as Successor Agency to the Carlsbad Redevelopment Agency."

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Carlsbad Local Conflict of Interest Code
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SECTION V: Amendments to Standard Conflict of Interest Code:

A. Section 9.5 of the standard conflict of interest code found in Title 2, Section 18730, of the California Code of Regulations is deleted as it applies only to state officers and employees.

B. Section 4 of the standard conflict of interest code found in Title 2, Section 18730, of the California Code of Regulations is amended to read as follows:

Section 4: All designated employees and individuals shall file their statements of economic interests with the City of Carlsbad’s City Clerk ’s Office, which will make the statements available on the city’s website for public viewing and downloading.

SECTION VI: Repeal: This code shall repeal and supersede all previous versions of the “Conflict of Interest Code for the City of Carlsbad, the Carlsbad Municipal Water District, the Community Development Commission, Carlsbad Public Financing Authority and the City of Carlsbad as Successor Agency to the Carlsbad Redevelopment Agency."

SECTION VII: Effective date: This code shall be effective upon adoption by resolution of the appropriate code reviewing body.

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Docusign Envelope ID: 6BCF492D-2272-8C49-80FE-E4825FBF206F Attachment B

APPENDIX
for

CONFLICT OF INTEREST CODE

DISCLOSURE CATEGORIES AND DESIGNATED POSITIONS

General Provisions
When designated employees or individuals are required to disclose investments, business positions and sources of income, they need to only disclose investments in business entities and sources of income which do business in the c ity, plan to do business in the c ity or have done business in the c ity within the past 2 years. In addition to other activities, a business entity is doing business within the city if it owns real property within the city. When designated employees or individuals are required to disclose real property they need to only disclose that which is located in whole or in part, within or not more than 2 miles outside the boundaries of the city or within 2 miles of any land owned or used by the city. Digital financial assets must be disclosed commencing January 1, 2027, if the fair market value of the in vestment equals or exceeds two thousand dollars ($2,000) and must be identified by the name of the asset as commonly known to the public.

Designated employees or individuals shall disclose their financial interest pursuant to the appropriate disclosure category as indicated in the List of Designated Positions and Disclosure Categories.

Resource: Title 2, California Code of Regulations, Section 18730 Provisions of Conflict of Interest Codes.

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Disclosure Categories

Category 1: Designated employees or individuals shall report all investments, including digital financial assets (e.g., cryptocurrency), business positions in business entities, and income , including gifts, loans and travel payment s, from sources in or doing business in Carlsbad.

Category 2: Designated employees and individuals shall report all real property interests within Carlsbad, including property located within a two -mile radius of any property owned or used by the City of Carlsbad.

Category 3: Designated employees or individuals shall report all investments, including digital financial assets (e.g., cryptocurrency), business positions in business entities and income, including gifts, loans and travel payments, from sources which engage in the appraisal, acquisition, disposal, development, rehabilitation, or construction of improvements on real property in Carlsbad, including real property located within a two -mile radius of any property owned or used by the City of Carlsbad.

Category 4: Designated employees or individuals shall report all investments, including digital financial assets (e.g., cryptocurrency), business positions in business entities, and income, including gifts, loans and travel payments, from any source, in or doing business within Carlsbad, which provide s services, supplies, materials, machinery or equipment of the type utilized by the city.

Category 5: Designated employees or individuals shall report all investments, including digital financial assets (e.g., cryptocurrency), business positions in business entities, and income, including gifts, loans and travel payments, from any source, in or doing business within Carlsbad, which provide s services, supplies, materials, machinery or equipment of the type utilized by the designated employee’s or individual’s department.

Section 87200 Filers
Employees and individuals to whom California Government Code Section 87200 applies, including the City Council and City Treasurer, candidates for these elected offices, the P lanning Commission, the City Manager, the City Attorney, the Deputy City Manager of Administrative Services, and other public officials who manage public investments, are required to fully disclose their personal assets and income, including digital financial assets as provided in the General Provisions above . These employees and individuals shall also disclos e any arrangement for prospective employment, which applies when the person has accepted an offer of employment, whether the acceptance is verbal or written, and the disclosure must contain (i) the date the filer accepted the offer of employment, (ii) the business position, (iii) general description of the business activity of the prospective employer, and (iv) the name and street address of the prospective employer.

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Consultants
“Consultant” is defined by the Fair Political Practices Commission, as an individual who, pursuant to a contract with a state or local governmental agency:
(a) Makes a governmental decision to:

1. Approve a rate, rule or regulation;

2. Adopt or enforce a law;

3. Issue, deny, suspend, or revoke any permit, license, application, certificate, approval, order, or similar authorization or entitlement;

4. Authorize the agency to enter into , modify, or renew a contract provided it is the type of contract that requires agency approval;

5. Grant agency approval to a contract that requires agency approval and in which the agency is a party, or to the specifications for such a contract;

6. Grants agency approval to a plan, design, report, study, or similar item;

7. Adopt, or grant agency approval of, policies, standards, or guidelines for the agency, or for any subdivision of the agency; or

(b ) Serves in a staff capacity with the agency and in that capacity participates in making a governmental decision or performs the same or substantially all the same duties for the agency that would otherwise be performed by an individual holding a position designated in the agency’s conflict of interest code.

A consultant does not act in a staff capacity where the work is to be performed on one project or a limited number of projects over a limited period of time, or where the relationship between the contractor and the agency would last only 12-16 months with no ongoing relationship contemplated, or where, under a multi -year contract, the contractor would perform only on a sporadic basis.

A consultant participates in making a governmental decision if the consultant provides information, an opinion, or a recommendation for the purpose of affecting the decision without significant intervene substantive review.

The staff person most knowledgeable of the work that a c onsultant will be performing shall designate whether the consultant must file a Statement of Economic Interest by marking the appropriate box in the contract and/or on the c ontract cover sheet. When a consultant is designated and is responsible for disclosure, the consultant shall be required to file a Statement of Economic Interest disclosing reportable interests in Disclosure Categories 1 and 2.

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LIST OF DESIGNATED POSITIONS AND DISCLOSURE CATEGORIES

FULL DISCLOSURE DESIGNATED POSITIONS DISCLOSURE CATEGORIES Mayor & City Council Members (87200 Filer) Full Disclosure Treasurer (87200 Filer) Full Disclosure
City Clerk Full Disclosure
Planning Commission Members (87200 Filer) Full Disclosure City Manager (87200 Filer) Full Disclosure
City Attorney (87200 Filer) Full Disclosure
Members of the Successor Agency of the Carlsbad Redevelopment Agency – Includes Chairman/Members, Executive Director, Counsel, Secretary (87200 Filer)
Full Disclosure
Public Financing Authority Members – Includes
Chairman/Members, Executive Director, Counsel, Secretary, Treasurer (87200 Filer)
Full Disclosure
Community Development Commission Members – Includes
Chairman/Members, Executive Director, Counsel, Secretary (87200 Filer)
Full Disclosure
Carlsbad Municipal Water District Board of Directors Members – Includes Board Members, Counsel, Secretary (87200 Filer) Full Disclosure

OFFICIALS WHO MANAGE PUBLIC INVESTMENTS
Deputy City Manager (Administrative Services) (87200 Filer) Full Disclosure Finance Director (87200 Filer) Full Disclosure
Investment Review Board Members (87200 Filer) Full Disclosure Senior Accountant (87200 Filer) Full Disclosure

POSITIONS UNDER THE CITY MANAGER

DESIGNATED POSITIONS DISCLOSURE CATEGORIES
Accountant 1, 2
Accounting Supervisor 1, 2
Assistant City Clerk 1, 2
Assistant City Manager 1, 2
Assistant Director of Community Development 1, 2
Assistant Director of Emergency Services 1, 2
Assistant Director of Transportation 1, 2
Assistant Engineer 2, 3, 5
Assistant Finance Director 1, 2
Assistant Fire Chief 1, 2
Assistant Fire Marshal 2, 3, 5
Assistant Human Resources Director 1, 2
Assistant IT Director 1, 2
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Assistant Planner 2, 3, 5
Assistant Police Chief 1, 2
Assistant Utilities Director 1, 2
Associate Contract Administrator 1, 2
Associate Engineer 2, 3, 5
Associate Management Analyst 2, 3, 5
Associate Planner 2, 3, 5
Building Inspector I/II 1, 2
Building Official 1, 2
Business Intelligence & Analytics Manager 1, 2
Business Intelligence Analyst 1, 2
Business Systems Specialist 2, 5
Business Technology Manager 1, 2
Buyer/Contract Administrator 1, 2
City Planner 1, 2
City Traffic Engineer 1, 2
Code Enforcement Manager 1, 2
Code Enforcement Officer I/II 1, 2
Communication & Engagement Director 1, 2
Communications Coordinator 1, 2
Community Arts Coordinator 1, 2
Community Development Director 1, 2
Community Health Nurse 1, 2
Community Relations Manager 2, 5
Construction Inspector I/II 1,2
Contract Administrator 1, 2
Cultural Arts Manager 1, 2
Deputy City Clerk 1, 2
Deputy City Manager (Administrative Services – see OFFICIALS WHO

MANAGE PUBLIC INVESTMENTS)
1, 2
Deputy Library Director 1, 2
Deputy Fire Marshall 2, 3, 5
Development Services Manager 1, 2
Development Services Supervisor 2, 3
Director of Constituent & Clerk Services 1, 2
Economic Development Director 1, 2
Engineering Manager 1, 2
Environmental Manager 1, 2
Environmental Specialist I/II/Senior 2, 3, 5
Environmental Sustainability Director 1,2
Executive Assistant 1, 2
Finance Manager 1, 2
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Finance/Payroll/IT Manager 1, 2
Fire Administrator 1, 2
Fire Battalion Chief 1, 2
Fire Chief 1, 2
Fire Division Chief 1, 2
Fire Inspector 1, 2
GIS Administrator 1, 2
GIS Analyst 1,2
Homeless Services Manager 1, 2
Housing & Homeless Services Director 1, 2
Housing Services Manager 1, 2
Human Resources Analyst 1,2
Human Resources Director 1, 2
Human Resources Manager 1, 2
Information Technology Director 1, 2
Information Technology Manager 1, 2
Information Technology Project Manager 1, 2
Information Technology Security Manager 1, 2
Information Technology Senior Project Manager 1,2
Inspector I/II 1, 2
Intergovernmental Affairs Director 1, 2
Internal Audit Manager 1, 2
Library & Cultural Arts Director 1, 2
Management Analyst 1, 2
Management Assistant 1,2
Meter Services Supervisor 2, 5
Municipal Projects Manager 1, 2
Parks and Recreation Director 1, 2
Park Planner 2, 3, 5
Park Planning Manager 1, 2
Parks Services Manager 1, 2
Parks Superintendent 1, 2
Parks/Trees Supervisor 2, 5
Police Administrative Manager 1, 2
Police Captain 1, 2
Police Chief 1, 2
Police Communications Manager 1, 2
Police Lieutenant 1, 2
Principal Engineer 1,2
Principal Librarian 1, 5
Principal Planner 1, 2
Principal Management Analyst 1,2
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Program Manager 1, 2
Public Works Manager 1, 2
Public Works Superintendent 1, 2
Public Works Supervisor 2, 4
Real Estate Manager 1, 2
Recreation Area Manager 1, 2
Recreation Services Manager 1, 2
Risk Manager 1, 2
Safety & Compliance Manager 1, 2
Safety Training Center Supervisor 1, 2
SCADA Supervisor 2, 5
Senior Applications Analyst 2, 5
Senior Building Inspector 1, 2
Senior Business Systems Specialist 1, 2
Senior Code Enforcement Officer 1, 2
Senior Construction Inspector 1, 2
Senior Contract Administrator 1, 2
Senior Database Administrator 1, 2
Senior Deputy City Clerk 1, 2
Senior Engineer 1, 2
Senior Fire Inspector/Investigator 1, 2
Senior Human Resources Officer 1, 2
Senior Management Analyst 1, 2
Senior Network Engineer 2, 4, 5
Senior Planner 1, 2
Senior Program Manager 1, 2
Senior System Administrator 2, 5
Special Projects Manager 1, 2
Systems Administrator 2, 5
Transportation Director 1, 2
Transportation Planning & Mobility Manager 1, 2
Utilities Director 1, 2
Utilities Maintenance Planner 1, 2
Utilities Manager 1, 2
Utilities Senior Engineer 1, 2
Utilities Superintendent 1, 2
Utilities Supervisor 2, 5
Utilities Technical Services Manager 1, 2
Warehouse Technician 2, 5

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CITY ATTORNEY’S OFFICE

DESIGNATED POSITIONS DISCLOSURE CATEGORIES
Assistant City Attorney 1, 2
Deputy City Attorney 1, 2
Executive Assistant 1, 2
Senior Assistant City Attorney 1, 2
Senior Management Analyst 1, 2

BOARDS/COMMISSIONS/COMMITTEES (Members of Designated Appointed Positions)

DESIGNATED POSITIONS DISCLOSURE CATEGORIES
Agricultural Conversion Mitigation Fee Ad Hoc Citizens Advisory Committee
1, 2
Arts Commission 1, 2
Board of Library Trustees 1, 2
Community-Police Engagement Commission 1, 2
Environmental Sustainability Commission 1,2
Historic Preservation Commission 1, 2
Housing Commission 1, 2
Parks & Recreation Commission 1, 2
Senior Commission 1, 2
Traffic Safety & Mobility Commission 1, 2

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RESOLUTION NO. 2026-170
A

RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CARLSBAD,

CALIFORNIA, ACTING AS SUCCESSOR AGENCY TO THE REDEVELOPMENT

AGENCY, AMENDING THE CONFLICT OF INTEREST CODE FOR THE AGENCY W
HEREAS, the City Council as the Successor Agency to the Redevelopment Agency has previously adopted and amended its Conflict of Interest Code; and WHEREAS, provisions of the Political Reform Act of 1974 (“the Act”) (Government Code Sections 81000 et seq.) require an amendment to the code due to revisions to the Act, changed circumstances, changed duties or new positions; and
WHEREAS, the City Council as the Successor Agency to the Redevelopment Agency is the code reviewing body within the meaning of the Act; and
WHEREAS, the City Clerk has prepared amendments to the Conflict of Interest Code, Appendix, and List of Designated Positions and Disclosure Categories that are required to be incorporated in the code.

NOW, THEREFORE, BE IT RESOLVED by City Council as the Successor Agency to the Redevelopment Agency of the City of Carlsbad, California, as follows:

1. That the above recitations are true and correct.

2. The proposed action to update the Conflict of Interest Code is exempt from environmental review under California Environmental Quality Act, or CEQA, Guidelines Section 15061(b)(3) and 15378(b)(5) as it can be seen with certainty that there is no possibility the proposed action may have a significant effect on the environment.

3. That the revised Conflict of Interest Code (Attachment A), Appendix (Attachment B) and List of Designated Positions and Disclosure Categories (Attachment C) for the combined City of Carlsbad, City Council as Successor Agency to the Redevelopment Agency, Community Development Commission, Carlsbad Municipal Water District, and Public Financing Authority reflecting the change s to designated positions and disclosure requirements since the last amendment are approved.

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Docusign Envelope ID: 6BCF492D-2272-8C49-80FE-E4825FBF206F PASSED, APPROVED AND ADOPTED at a Joint Special Meeting of the City Council as Successor Agency to the Redevelopment Agency, the Public Financing Authority, the City Council of the City of Carlsbad, the Ca rlsbad Municipa l Water District, and the Community Development Commission on the 15th day of September, 2026, by the following vote, to wit:

AYES: Blackburn, Bhat-Patel, Acosta, Burkholder, Shin.

NAYS: None.

ABSTAIN: None.

ABSENT: None.
_______
_______________________________
KEITH BLACKBURN, Mayor
_______
_______________________________
SHERRY FREISINGER, City Clerk
(SEAL)
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Attachment A

CONFLICT
OF

INTEREST CODE

for the

City of Carlsbad
Carlsbad Municipal Water District
Community Development Commission
Carlsbad Public Financing Authority
City of Carlsbad as Successor Agency to the Carlsbad
Redevelopment Agency

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Carlsbad Local Conflict of Interest Code
Sept. 15, 2026

SECTION I: Title: This code shall be known and may be cited as "Conflict of Interest Code for the City of Carlsbad, the Carlsbad Municipal Water District , the Community Development Commission, Carlsbad Public Financing Authority and the City of Carlsbad as Successor Agency to the Carlsbad Redevelopment Agency."

SECTION II: Authority: This code is adopted under the provisions of the Political Reform Act of 1974, found in the California Government Code beginning with Section 81000, and its implementing regulations, found in Title 2 of the California Code of Regulations beginning with Section 18700.

SECTION III: Purpose: This code is adopted in order to:

A. Assure that all designated employees and individuals perform their duties in an impartial manner, free from bias caused by financial interests; B. Enumerate and differentiate the positions of employment within the c ity which involve the making of decisions which may foreseeably have a material effect upon a financial interest;
C. Require the disclosure of such interests, by setting forth the specific types of interests which are reportable for each position; and
D. Require that designated employees disqualify themselves f rom participation in city decision-making which may involve a conflict of interest.

SECTION IV: Incorporation by Reference : Except as stated in Section V below, t he standard conflict of interest code prepared by the Fair Political Practices Commission, found in Title 2, Section 18730, of the California Code of Regulations, as it may be amended from time to time, is incorporated by this reference. Together with the attached Appendix and List of D esignated Positions and Disclosure Categories, it constitutes the “Conflict of Interest Code for the City of Carlsbad, the Carlsbad Municipal Water District, the Community Development Commission, Carlsbad Public Financing Authority and the City of Carlsbad as Successor Agency to the Carlsbad Redevelopment Agency."

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Carlsbad Local Conflict of Interest Code
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SECTION V: Amendments to Standard Conflict of Interest Code:

A. Section 9.5 of the standard conflict of interest code found in Title 2, Section 18730, of the California Code of Regulations is deleted as it applies only to state officers and employees.

B. Section 4 of the standard conflict of interest code found in Title 2, Section 18730, of the California Code of Regulations is amended to read as follows:

Section 4: All designated employees and individuals shall file their statements of economic interests with the City of Carlsbad’s City Clerk ’s Office, which will make the statements available on the city’s website for public viewing and downloading.

SECTION VI: Repeal: This code shall repeal and supersede all previous versions of the “Conflict of Interest Code for the City of Carlsbad, the Carlsbad Municipal Water District, the Community Development Commission, Carlsbad Public Financing Authority and the City of Carlsbad as Successor Agency to the Carlsbad Redevelopment Agency."

SECTION VII: Effective date: This code shall be effective upon adoption by resolution of the appropriate code reviewing body.

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Docusign Envelope ID: 6BCF492D-2272-8C49-80FE-E4825FBF206F Attachment B

APPENDIX
for

CONFLICT OF INTEREST CODE

DISCLOSURE CATEGORIES AND DESIGNATED POSITIONS

General Provisions
When designated employees or individuals are required to disclose investments, business positions and sources of income, they need to only disclose investments in business entities and sources of income which do business in the c ity, plan to do business in the c ity or have done business in the c ity within the past 2 years. In addition to other activities, a business entity is doing business within the city if it owns real property within the city. When designated employees or individuals are required to disclose real property they need to only disclose that which is located in whole or in part, within or not more than 2 miles outside the boundaries of the city or within 2 miles of any land owned or used by the city. Digital financial assets must be disclosed commencing January 1, 2027, if the fair market value of the in vestment equals or exceeds two thousand dollars ($2,000) and must be identified by the name of the asset as commonly known to the public.

Designated employees or individuals shall disclose their financial interest pursuant to the appropriate disclosure category as indicated in the List of Designated Positions and Disclosure Categories.

Resource: Title 2, California Code of Regulations, Section 18730 Provisions of Conflict of Interest Codes.

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Disclosure Categories

Category 1: Designated employees or individuals shall report all investments, including digital financial assets (e.g., cryptocurrency), business positions in business entities, and income , including gifts, loans and travel payment s, from sources in or doing business in Carlsbad.

Category 2: Designated employees and individuals shall report all real property interests within Carlsbad, including property located within a two -mile radius of any property owned or used by the City of Carlsbad.

Category 3: Designated employees or individuals shall report all investments, including digital financial assets (e.g., cryptocurrency), business positions in business entities and income, including gifts, loans and travel payments, from sources which engage in the appraisal, acquisition, disposal, development, rehabilitation, or construction of improvements on real property in Carlsbad, including real property located within a two -mile radius of any property owned or used by the City of Carlsbad.

Category 4: Designated employees or individuals shall report all investments, including digital financial assets (e.g., cryptocurrency), business positions in business entities, and income, including gifts, loans and travel payments, from any source, in or doing business within Carlsbad, which provide s services, supplies, materials, machinery or equipment of the type utilized by the city.

Category 5: Designated employees or individuals shall report all investments, including digital financial assets (e.g., cryptocurrency), business positions in business entities, and income, including gifts, loans and travel payments, from any source, in or doing business within Carlsbad, which provide s services, supplies, materials, machinery or equipment of the type utilized by the designated employee’s or individual’s department.

Section 87200 Filers
Employees and individuals to whom California Government Code Section 87200 applies, including the City Council and City Treasurer, candidates for these elected offices, the P lanning Commission, the City Manager, the City Attorney, the Deputy City Manager of Administrative Services, and other public officials who manage public investments, are required to fully disclose their personal assets and income, including digital financial assets as provided in the General Provisions above . These employees and individuals shall also disclos e any arrangement for prospective employment, which applies when the person has accepted an offer of employment, whether the acceptance is verbal or written, and the disclosure must contain (i) the date the filer accepted the offer of employment, (ii) the business position, (iii) general description of the business activity of the prospective employer, and (iv) the name and street address of the prospective employer.

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Consultants
“Consultant” is defined by the Fair Political Practices Commission, as an individual who, pursuant to a contract with a state or local governmental agency:
(a) Makes a governmental decision to:

1. Approve a rate, rule or regulation;

2. Adopt or enforce a law;

3. Issue, deny, suspend, or revoke any permit, license, application, certificate, approval, order, or similar authorization or entitlement;

4. Authorize the agency to enter into, modify, or renew a contract provided it is the type of contract that requires agency approval;

5. Grant agency approval to a contract that requires agency approval and in which the agency is a party, or to the specifications for such a contract;

6. Grants agency approval to a plan, design, report, study, or similar item;

7. Adopt, or grant agency approval of, policies, standards, or guidelines for the agency, or for any subdivision of the agency; or

(b ) Serves in a staff capacity with the agency and in that capacity participates in making a governmental decision or performs the same or substantially all the same duties for the agency that would otherwise be performed by an individual holding a position designated in the agency’s conflict of interest code.

A consultant does not act in a staff capacity where the work is to be performed on one project or a limited number of projects over a limited period of time, or where the relationship between the contractor and the agency would last only 12-16 months with no ongoing relationship contemplated, or where, under a multi -year contract, the contractor would perform only on a sporadic basis.

A consultant participates in making a governmental decision if the consultant provides information, an opinion, or a recommendation for the purpose of affecting the decision without significant intervene substantive review.

The staff person most knowledgeable of the work that a c onsultant will be performing shall designate whether the consultant must file a Statement of Economic Interest by marking the appropriate box in the contract and/or on the c ontract cover sheet. When a consultant is designated and is responsible for disclosure, the consultant shall be required to file a Statement of Economic Interest disclosing reportable interests in Disclosure Categories 1 and 2.

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Docusign Envelope ID: 6BCF492D-2272-8C49-80FE-E4825FBF206F Attachment C

LIST OF DESIGNATED POSITIONS AND DISCLOSURE CATEGORIES

FULL DISCLOSURE DESIGNATED POSITIONS DISCLOSURE CATEGORIES Mayor & City Council Members (87200 Filer) Full Disclosure Treasurer (87200 Filer) Full Disclosure
City Clerk Full Disclosure
Planning Commission Members (87200 Filer) Full Disclosure City Manager (87200 Filer) Full Disclosure
City Attorney (87200 Filer) Full Disclosure
Members of the Successor Agency of the Carlsbad Redevelopment Agency – Includes Chairman/Members, Executive Director, Counsel, Secretary (87200 Filer)
Full Disclosure
Public Financing Authority Members – Includes
Chairman/Members, Executive Director, Counsel, Secretary, Treasurer (87200 Filer)
Full Disclosure
Community Development Commission Members – Includes
Chairman/Members, Executive Director, Counsel, Secretary (87200 Filer)
Full Disclosure
Carlsbad Municipal Water District Board of Directors Members – Includes Board Members, Counsel, Secretary (87200 Filer) Full Disclosure

OFFICIALS WHO MANAGE PUBLIC INVESTMENTS
Deputy City Manager (Administrative Services) (87200 Filer) Full Disclosure Finance Director (87200 Filer) Full Disclosure
Investment Review Board Members (87200 Filer) Full Disclosure Senior Accountant (87200 Filer) Full Disclosure

POSITIONS UNDER THE CITY MANAGER

DESIGNATED POSITIONS DISCLOSURE CATEGORIES
Accountant 1, 2
Accounting Supervisor 1, 2
Assistant City Clerk 1, 2
Assistant City Manager 1, 2
Assistant Director of Community Development 1, 2
Assistant Director of Emergency Services 1, 2
Assistant Director of Transportation 1, 2
Assistant Engineer 2, 3, 5
Assistant Finance Director 1, 2
Assistant Fire Chief 1, 2
Assistant Fire Marshal 2, 3, 5
Assistant Human Resources Director 1, 2
Assistant IT Director 1, 2
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Assistant Planner 2, 3, 5
Assistant Police Chief 1, 2
Assistant Utilities Director 1, 2
Associate Contract Administrator 1, 2
Associate Engineer 2, 3, 5
Associate Management Analyst 2, 3, 5
Associate Planner 2, 3, 5
Building Inspector I/II 1, 2
Building Official 1, 2
Business Intelligence & Analytics Manager 1, 2
Business Intelligence Analyst 1, 2
Business Systems Specialist 2, 5
Business Technology Manager 1, 2
Buyer/Contract Administrator 1, 2
City Planner 1, 2
City Traffic Engineer 1, 2
Code Enforcement Manager 1, 2
Code Enforcement Officer I/II 1, 2
Communication & Engagement Director 1, 2
Communications Coordinator 1, 2
Community Arts Coordinator 1, 2
Community Development Director 1, 2
Community Health Nurse 1, 2
Community Relations Manager 2, 5
Construction Inspector I/II 1,2
Contract Administrator 1, 2
Cultural Arts Manager 1, 2
Deputy City Clerk 1, 2
Deputy City Manager (Administrative Services – see OFFICIALS WHO

MANAGE PUBLIC INVESTMENTS)
1, 2
Deputy Library Director 1, 2
Deputy Fire Marshall 2, 3, 5
Development Services Manager 1, 2
Development Services Supervisor 2, 3
Director of Constituent & Clerk Services 1, 2
Economic Development Director 1, 2
Engineering Manager 1, 2
Environmental Manager 1, 2
Environmental Specialist I/II/Senior 2, 3, 5
Environmental Sustainability Director 1,2
Executive Assistant 1, 2
Finance Manager 1, 2
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Finance/Payroll/IT Manager 1, 2
Fire Administrator 1, 2
Fire Battalion Chief 1, 2
Fire Chief 1, 2
Fire Division Chief 1, 2
Fire Inspector 1, 2
GIS Administrator 1, 2
GIS Analyst 1,2
Homeless Services Manager 1, 2
Housing & Homeless Services Director 1, 2
Housing Services Manager 1, 2
Human Resources Analyst 1,2
Human Resources Director 1, 2
Human Resources Manager 1, 2
Information Technology Director 1, 2
Information Technology Manager 1, 2
Information Technology Project Manager 1, 2
Information Technology Security Manager 1, 2
Information Technology Senior Project Manager 1,2
Inspector I/II 1, 2
Intergovernmental Affairs Director 1, 2
Internal Audit Manager 1, 2
Library & Cultural Arts Director 1, 2
Management Analyst 1, 2
Management Assistant 1,2
Meter Services Supervisor 2, 5
Municipal Projects Manager 1, 2
Parks and Recreation Director 1, 2
Park Planner 2, 3, 5
Park Planning Manager 1, 2
Parks Services Manager 1, 2
Parks Superintendent 1, 2
Parks/Trees Supervisor 2, 5
Police Administrative Manager 1, 2
Police Captain 1, 2
Police Chief 1, 2
Police Communications Manager 1, 2
Police Lieutenant 1, 2
Principal Engineer 1,2
Principal Librarian 1, 5
Principal Planner 1, 2
Principal Management Analyst 1,2
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Program Manager 1, 2
Public Works Manager 1, 2
Public Works Superintendent 1, 2
Public Works Supervisor 2, 4
Real Estate Manager 1, 2
Recreation Area Manager 1, 2
Recreation Services Manager 1, 2
Risk Manager 1, 2
Safety & Compliance Manager 1, 2
Safety Training Center Supervisor 1, 2
SCADA Supervisor 2, 5
Senior Applications Analyst 2, 5
Senior Building Inspector 1, 2
Senior Business Systems Specialist 1, 2
Senior Code Enforcement Officer 1, 2
Senior Construction Inspector 1, 2
Senior Contract Administrator 1, 2
Senior Database Administrator 1, 2
Senior Deputy City Clerk 1, 2
Senior Engineer 1, 2
Senior Fire Inspector/Investigator 1, 2
Senior Human Resources Officer 1, 2
Senior Management Analyst 1, 2
Senior Network Engineer 2, 4, 5
Senior Planner 1, 2
Senior Program Manager 1, 2
Senior System Administrator 2, 5
Special Projects Manager 1, 2
Systems Administrator 2, 5
Transportation Director 1, 2
Transportation Planning & Mobility Manager 1, 2
Utilities Director 1, 2
Utilities Maintenance Planner 1, 2
Utilities Manager 1, 2
Utilities Senior Engineer 1, 2
Utilities Superintendent 1, 2
Utilities Supervisor 2, 5
Utilities Technical Services Manager 1, 2
Warehouse Technician 2, 5

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CITY ATTORNEY’S OFFICE

DESIGNATED POSITIONS DISCLOSURE CATEGORIES
Assistant City Attorney 1, 2
Deputy City Attorney 1, 2
Executive Assistant 1, 2
Senior Assistant City Attorney 1, 2
Senior Management Analyst 1, 2

BOARDS/COMMISSIONS/COMMITTEES (Members of Designated Appointed Positions)

DESIGNATED POSITIONS DISCLOSURE CATEGORIES
Agricultural Conversion Mitigation Fee Ad Hoc Citizens Advisory Committee
1, 2
Arts Commission 1, 2
Board of Library Trustees 1, 2
Community-Police Engagement Commission 1, 2
Environmental Sustainability Commission 1,2
Historic Preservation Commission 1, 2
Housing Commission 1, 2
Parks & Recreation Commission 1, 2
Senior Commission 1, 2
Traffic Safety & Mobility Commission 1, 2

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Docusign Envelope ID: 6BCF492D-2272-8C49-80FE-E4825FBF206F Exhibit 6

CONFLICT
OF

INTEREST CODE

for the

City of Carlsbad
Carlsbad Municipal Water District
Community Development Commission
Carlsbad Public Financing Authority
City of Carlsbad as Successor Agency to the Carlsbad
Redevelopment Agency

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Docusign Envelope ID: 6BCF492D-2272-8C49-80FE-E4825FBF206F Carlsbad Local Conflict of Interest Code
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Sept. 15, 2026
SECTION I: Title: This code shall be known and may be cited as "Conflict of Interest Code for of the City of Carlsbad, the Carlsbad Municipal Water District , the Community Development Commission, Carlsbad Public Financing Authority and the City of Carlsbad as Successor Agency to the Carlsbad Redevelopment Agency."

SECTION II: Authority: This code is adopted under the provisions of the Political Reform Act of 1974, found in the California Government Code beginning with Section 81000, and its implementing regulations, found in Title 2 of the California Code of Regulations beginning with Section 18700.

SECTION III: Purpose: This code is adopted in order to:

A. Assure that all designated employees and individuals perform their duties in an impartial manner, free from bias caused by financial interests; B. Enumerate and differentiate the positions of employment within the city which involve the making of decisions which may foreseeably have a material effect upon a financial interest;
C. Require the disclosure of such interests, by setting forth the specific types of interests which are reportable for each position; and
D. Require that designated employees disqualify themselves from participation in city decision-making which may involve a conflict of interest.

SECTION IV: Incorporation by Reference : Except as stated in Section V below, the standard conflict of interest code prepared by the Fair Political Practices Commission, found in Title 2, Section 18730, of the California Code of Regulations, as it may be amended from time to time, is incorporated by this reference . Together with the attach ed Appendix and List of Designated Positions and Disclosure Categories, it constitutes the “Conflict of Interest Code for of the City of Carlsbad, the Carlsbad Municipal Water District, the Community Development Commission, Carlsbad Public Financing Authority and the City of Carlsbad as Successor Agency to the Carlsbad Redevelopment Agency."

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Sept. 15, 2026
SECTION V: Amendments to Standard Conflict of Interest Code:

A. Section 9 . 5 of the standard conflict of interest code found in Title 2, Section 18730, of the California Code of Regulations is deleted as it applies only to state officers and employees.

B. Section 4 of the standard conflict of interest code found in Title 2, Section 18730, of the California Code of Regulations is amended to read as follows:

Section 4: All designated employees and individuals shall file their statements of economic interests with the City of Carlsbad’s City Clerk ’s Office, which will make the statements available on the city’s website for public viewing and downloading.

SECTION VI: Repeal: This code shall repeal and supersede all previous versions of the “Conflict of Interest Code for of the City of Carlsbad, the Carlsbad Municipal Water District , the Community Development Commission, Carlsbad Public Financing Authority and the City of Carlsbad as Successor Agency to the Carlsbad Redevelopment Agency."

SECTION VII: Effective date: This code shall be effective upon adoption by resolution of the appropriate code reviewing body.

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APPENDIX
for

CONFLICT OF INTEREST CODE

DISCLOSURE CATEGORIES AND DESIGNATED POSITIONS

General Provisions
When designated employees or individuals are required to disclose investments, business positions and sources of income, they need to only disclose investments in business entities and sources of income which do business in the city, plan to do business in the city or have done business in the city within the past 2 years. In addition to other activities, a business entity is doing business within the city if it owns real property within the city. When designated employees or individuals are required to dis close real property they need to only disclose that which is located in whole or in part, within or not more than 2 miles outside the boundaries of the city or within 2 miles of any land owned or used by the city. Digital financial assets must be disclosed commencing January 1, 2027, if the fair market value of the investment equals or exceeds two thousand dollars ($2,000) and must be identified by the name of the asset as commonly known to the public.

Designated employees or individuals shall disclose their financial interest pursuant to the appropriate disclosure category as indicated in the List of Designated Positions and Disclosure Categories.

Resource: Title 2, California Code of Regulations, Section 18730 Provisions of Conflict of Interest Codes.

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Disclosure Categories

Category 1: Designated employees or individuals shall report all investments, including digital financial assets (e.g., cryptocurrency), business positions in business entities, and income, including gifts, loans and travel payments, from sources in or doing business in Carlsbad.

Category 2: Designated employees and individuals shall report all real property interests within the Carlsbad, including property located within a two-mile radius of any property owned or used by the City of Carlsbad.

Category 3: Designated employees or individuals shall report all investments, including digital financial assets (e.g., cryptocurrency), business positions in business entities and income, including gifts, loans and travel payments, from sources which engage in the appraisal, acquisition, disposal, development, rehabilitation, or construction of improvements on real property in Carlsbad, including real property located within a two -mile radius of any property owned or used by the City of Carlsbad.

Category 4: Designated employees or individuals shall report all investments, including digital financial assets (e.g., cryptocurrency), business positions in business entities, and income, including gifts, loans and travel payments, from any source, in or doing business within Carlsbad, which provides services, supplies, materials, machinery or equipment of the type utilized by the city.

Category 5: Designated employees or individuals shall report all investments, including digital financial assets (e.g., cryptocurrency), business positions in business entities, and income, including gifts, loans and travel payments, from any source, in or doing business within Carlsbad, which provides services, supplies, materials, machinery or equipment of the type utilized by the designated employee’s or individual’s department.

Section 87200 Filers
Employees and individuals to whom California Government Code Section 87200 applies, including the City Council and Treasurer, candidates for these elected offices, the Planning Commission, the City Manager, the City Attorney, the Deputy City Manager of Adm inistrative Services, and other public officials who manage public investments, are required to fully disclose their personal assets and income , including digital financial assets as provided in the General Provisions above . These employees and individuals shall also disclose any arrangement for prospective employment, which applies when the person has accepted an offer of employment, whether the acceptance is verbal or written, and the disclosure must contain (i) the date the filer accepted the offer of employment, (ii) the business position, (iii) general description of the business activity of the prospective employer, and (iv) the name and street address of the prospective employer.

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Sept. 15, 2026

Consultants
“Consultant” is defined by the Fair Political Practices Commission, as an individual who, pursuant to a contract with a state or local governmental agency:
(a) Makes a governmental decision to:
1) Approve a rate, rule or regulation;
2) Adopt or enforce a law;
3) Issue, deny, suspend, or revoke any permit, license, application, certificate, approval, order, or similar authorization or entitlement; 4) Authorize the agency to enter into, modify, or renew a contract provided it is the type of contract that requires agency approval;
5) Grant agency approval to a contract that requires agency approval and in which the agency is a party, or to the specifications for such a contract; 6) Grants agency approval to a plan, design, report, study, or similar item; 7) Adopt, or grant agency approval of, policies, standards, or guidelines for the agency, or for any subdivision of the agency; or

(b) Serves in a staff capacity with the agency and in that capacity participates in making a governmental decision or performs the same or substantially all the same duties for the agency that would otherwise be performed by an individual holding a position designated in the agency’s conflict of interest code.

A consultant does not act in a staff capacity where the work is to be performed on one project or a limited number of projects over a limited period of time, or where the relationship between the contractor and the agency would last only 12-16 months with no ongoing relationship contemplated, or where, under a multi-year contract, the contractor would perform only on a sporadic basis.

A consultant participates in making a governmental decision if the consultant provides information, an opinion, or a recommendation for the purpose of affecting the decision without significant intervene substantive review.

The staff person most knowledgeable of the work that a consultant will be performing shall designate whether the consultant must file a Statement of Economic Interest by marking the appropriate box in the contract and/or on the contract cover sheet. When a consultant is designated and is responsible for disclosure, the consultant shall be required to file a Statement of Economic Interest disclosing reportable interests in Disclosure Categories 1 and 2.

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Summary of Changes
for the List of Designated Positions and Disclosure Categories

NEW OR RECLASSIFIED POSITIONS ADDED TO THE CODE:

DESIGNATED POSITIONS DISCLOSURE CATEGORIES
Assistant City Clerk 1, 2
Assistant Director of Transportation 1, 2
Construction Inspector I/II 1, 2
Development Services Supervisor 2, 3
Director of Constituent & Clerk Services 1, 2
GIS Analyst 1, 2
Management Assistant 1, 2
Principal Engineer 1, 2
Principal Management Analyst 1, 2

DESIGNATED POSITIONS

BOARDS/COMMISSIONS/COMMITTEES
(Members of Designated Appointed Positions)

DISCLOSURE CATEGORIES
Beach Preservation Commission Environmental Sustainability Commission
1, 2

OFFICIALS WHO MANAGE PUBLIC INVESTMENTS DISCLOSURE CATEGORIES Deputy City Manager (Administrative Services) (87200 Filer) Full Disclosure Finance Director Deputy City Treasurer (87200 Filer) Full Disclosure Investment Review Committee Board Members (87200 Filer) Full Disclosure Assistant to the City Treasurer Senior Accountant (87200 Filer) Full Disclosure

POSITIONS REMOVED FROM THE CODE:

DESIGNATED POSITIONS DISCLOSURE CATEGORIES
City Clerk Service Director 1, 2
Emergency Preparedness Manager 1, 2
Fire Prevention Specialist I/II 1, 2
Utilities Associate Engineer 2, 3, 5

DESIGNATED POSITIONS

BOARDS/COMMISSIONS/COMMITTEES
(Members of Designated Appointed Positions)

DISCLOSURE CATEGORIES
Carlsbad Tourism Business Improvement District 1, 2
Housing Element Advisory Committee 1, 2

OFFICIALS WHO MANAGE PUBLIC INVESTMENTS DISCLOSURE CATEGORIES Assistant to the City Treasurer Full Disclosure

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ALL OTHER POSITIONS WITH NEW OR UNCHANGED DISCLOSURE CATEGORIES:

DESIGNATED POSITIONS DISCLOSURE CATEGORIES
Accountant 1, 2
Accounting Supervisor 1, 2
Assistant City Clerk 1, 2
Assistant City Manager 1, 2
Assistant Director of Community Development 1, 2
Assistant Director of Emergency Services 1, 2
Assistant Director of Transportation 1, 2
Assistant Engineer 2, 3, 5
Assistant Finance Director 1, 2
Assistant Fire Chief 1, 2
Assistant Fire Marshal 2, 3, 5
Assistant Human Resources Director 1, 2
Assistant IT Director 1, 2
Assistant Planner 2, 3, 5
Assistant Police Chief 1, 2
Assistant Utilities Director 1, 2
Associate Contract Administrator 1, 2
Associate Engineer 2, 3, 5
Associate Management Analyst 2, 3, 5
Associate Planner 2, 3, 5
Building Inspector I/II 1, 2
Building Official 1, 2
Business Intelligence & Analytics Manager 1, 2
Business Intelligence Analyst 1, 2
Business Systems Specialist 2, 5
Business Technology Manager 1, 2
Buyer/Contract Administrator 1, 2
City Clerk Services Director 1, 2
City Planner 1, 2
City Traffic Engineer 1, 2
Code Enforcement Manager 1, 2
Code Enforcement Officer I/II 1, 2
Communication & Engagement Director 1, 2
Communications Coordinator 1, 2
Community Arts Coordinator 1, 2
Community Development Director 1, 2
Community Health Nurse 1, 2
Community Relations Manager 2, 5
Construction Inspector I/II 1, 2
Contract Administrator 1, 2
Cultural Arts Manager 1, 2
Deputy City Clerk 1, 2
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Deputy City Manager (Administrative Services – see OFFICIALS

WHO MANAGE PUBLIC INVESTMENTS)
1, 2
Deputy Library Director 1, 2
Deputy Fire Marshall 2, 3, 5
Development Services Manager 1, 2
Development Services Supervisor 2, 3
Director of Legislative & Constituent & Clerk Services 1, 2 Economic Development Director 1, 2
Engineering Manager 1, 2
Emergency Preparedness Manager 1, 2
Environmental Manager 1, 2
Environmental Specialist I/II/Senior 2, 3, 5
Environmental Sustainability Director 1,2
Executive Assistant 1, 2
Finance Director 1, 2
Finance Manager 1, 2
Finance/Payroll/IT Manager 1, 2
Fire Administrator 1, 2
Fire Battalion Chief 1, 2
Fire Chief 1, 2
Fire Division Chief 1, 2
Fire Inspector 1, 2
Fire Prevention Specialist I/II 1, 2
GIS Administrator 1, 2
GIS Analyst 1, 2
Homeless Services Manager 1, 2
Housing & Homeless Services Director 1, 2
Housing Services Manager 1, 2
Human Resources Analyst 1, 2
Human Resources Director 1, 2
Human Resources Manager 1, 2
Information Technology Director 1, 2
Information Technology Manager 1, 2
Information Technology Project Manager 1, 2
Information Technology Security Manager 1, 2
Information Technology Senior Project Manager Senior IT Project Manager
1, 2
Inspector I/II 1, 2
Intergovernmental Affairs Director 1, 2
Internal Audit Manager 1, 2
Library & Cultural Arts Director 1, 2
Management Analyst 1, 2
Management Assistant 1, 2
Meter Services Supervisor 2, 5
Municipal Projects Manager 1, 2
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Parks and Recreation Director 1, 2
Park Planner 2, 3, 5
Park Planning Manager 1, 2
Parks Services Manager 1, 2
Parks Superintendent 1, 2
Parks/Trees Supervisor 2, 5
Police Administrative Manager 1, 2
Police Captain 1, 2
Police Chief 1, 2
Police Communications Manager 1, 2
Police Lieutenant 1, 2
Principal Engineer 1, 2
Principal Librarian 1, 5
Principal Planner 1, 2
Principal Management Analyst 1, 2
Program Manager 1, 2
Public Works Manager 1, 2
Public Works Superintendent 1, 2
Public Works Supervisor 2, 4
Real Estate Manager 1, 2
Recreation Area Manager 1, 2
Recreation Services Manager 1, 2
Risk Manager 1, 2
Safety & Compliance Manager 1, 2
Safety Training Center Supervisor 1, 2
SCADA Supervisor 2, 5
Senior Accountant 1, 2
Senior Applications Analyst 2, 5
Senior Building Inspector 1, 2
Senior Business Systems Specialist 1, 2
Senior Code Enforcement Officer 1, 2
Senior Construction Inspector 1, 2
Senior Contract Administrator 1, 2
Senior Database Administrator 1, 2
Senior Deputy City Clerk 1, 2
Senior Engineer 1, 2
Senior Fire Inspector/Investigator 1, 2
Senior Human Resources Officer 1, 2
Senior Management Analyst 1, 2
Senior Network Engineer 2, 4, 5
Senior Planner 1, 2
Senior Program Manager 1, 2
Senior System Administrator 2, 5
Special Projects Manager 1, 2
Systems Administrator 2, 5
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Transportation Director 1, 2
Transportation Planning & Mobility Manager 1, 2
Utilities Associate Engineer 2, 3, 5
Utilities Director 1, 2
Utilities Maintenance Planner 1, 2
Utilities Manager 1, 2
Utilities Senior Engineer 1, 2
Utilities Superintendent 1, 2
Utilities Supervisor 2, 5
Utilities Technical Services Manager 1, 2
Warehouse Technician 2, 5

DESIGNATED POSITIONS

WHO REPORT TO THE CITY ATTORNEY

DISCLOSURE CATEGORIES
Assistant City Attorney 1, 2
Deputy City Attorney 1, 2
Executive Assistant 1, 2
Senior Assistant City Attorney 1, 2
Senior Management Analyst 1, 2

DESIGNATED POSITIONS

BOARDS/COMMISSIONS/COMMITTEES
(Members of Designated Appointed Positions)

DISCLOSURE CATEGORIES
Agricultural Conversion Mitigation Fee Ad Hoc Citizens Advisory Committee
1, 2
Arts Commission 1, 2
Beach Preservation Commission Environmental Sustainability Commission
1, 2
Board of Library Trustees 1, 2
Carlsbad Tourism Business Improvement District 1, 2
Community-Police Engagement Commission 1, 2
Historic Preservation Commission 1, 2
Housing Commission 1, 2
Housing Element Advisory Committee 1, 2
Parks & Recreation Commission 1, 2
Senior Commission 1, 2
Traffic Safety & Mobility Commission 1, 2

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