-1-
1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16
17 18
19 20
21 22
23 24
25 26
27 28
RESOLUTION NO. 2026-R_____
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
CULVER CITY, CALIFORNIA, AMENDING THE CITY’S
CONFLICT OF INTEREST CODE PURSUANT TO THE
POLITICAL REFORM ACT, INCORPORATING BY
REFERENCE, THE TERMS OF THE FAIR POLITICAL
PRACTICES COMMISSION’S MODEL CONFLICT OF
INTEREST CODE, AS SET FORTH IN TITLE 2 OF CALIFORNIA
CODE OF REGULATIONS SECTION 18730, AND RESCINDING
RESOLUTION NO. 2024-R061.
WHEREAS, the Political Reform Act (Government Code §§ 81000, et seq.), requires every state and local government agency to adopt and promulgate a Conflict of Interest Code; and
WHEREAS, the Political Reform Act requires every local government agency to review its Conflict of Interest Code biennially to determine if it is accurate or, alternatively, that the Conflict of Interest Code must be amended; and
WHEREAS, it has been determined that the City’s current Conflict of Interest Code, as adopted by Resolution No. 2024-R061, needs to be amended due to positions that have been created, eliminated, or revised as well as significant structural reorganization of City departments; and
WHEREAS, the Fair Political Practices Commission (FPPC) has adopted a regulation (Title 2 California Code of Regulations § 18730), which may be incorporated by reference, and which may be amended by the FPPC to conform to amendments in the Political Reform Act, after public notice and hearing conducted by the FPPC pursuant to the Administrative Procedure Act, Government Code §§ 11370, et seq.; and WHEREAS, the City Council has determined that Appendix “A”, attached hereto and incorporated herein, accurately sets forth a list of disclosure categories of reportable -2-
1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16
17 18
19 20
21 22
23 24
25 26
27 28
financial interests along with Appendices “B” and “C”, attached hereto, a list of designated officials and employees.
NOW, THEREFORE, the City Council of the City of Culver City, California, DOES HEREBY RESOLVE as follows:
1. The terms of Title 2 California Code of Regulations § 18730, and any amendments thereto, which have been duly adopted by the Fair Political Practices Commission (FPPC), are hereby incorporated by reference and, together with the attached Appendices “A” through “C”, which designates City officials and employees and establishes respective financial disclosure categories, shall constitute the City of Culver City Conflict of Interest Code.
2. Future amendments to the terms of Title 2 California Code of Regulations § 18730, which are duly adopted by the FPPC, shall become part of the Culver City Conflict of Interest Code upon the expiration of forty-five (45) days after receipt by the City Council, unless the City Council, by Resolution, decides not to adopt such amendments in whole or in part.
The City Council hereby reserves the right not to adopt any provisions not within the jurisdiction of the FPPC pursuant to Government Code §§ 81000, et seq.
3. Designated employees and elected and appointed officials identified in Appendix “B” shall file Statements of Economic Interests (Form 700 Statements) with the City Clerk, to whom the City Council hereby delegates the authority to carry out the duties of Filing Officer. The Form 700 Statements of designated employees shall be retained as official records by the City Clerk and shall be made available for public inspection and reproduction, in accordance with Government Code § 81008.
4. Pursuant to AB 1170, effective January 1, 2025, public officials for which the FPPC is the filing officer, such as City officials identified in Government Code § 87200, including the Council Members, City Manager, City Attorney, Chief Financial Officer/City -3-
1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16
17 18
19 20
21 22
23 24
25 26
27 28
Treasurer, and Planning Commissioners, must electronically file their Statements of Economic Interests directly with the FPPC, and these statements may be accessed through the FPPC Form 700 search webpage.
5. Resolution No. 2024-R061 is hereby rescinded.
6. This Resolution shall take effect on September 28, 2026.
APPROVED AND ADOPTED this ____ day of _______ 2026.
________________________________
FREDDY PUZA, MAYOR
City of Culver City, California
ATTEST: APPROVED AS TO FORM:
__________________________ ______________________________
JEREMY BOCCHINO, HEATHER BAKER,
City Clerk City Attorney
-4-
1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16
17 18
19 20
21 22
23 24
25 26
27 28
CONFLICT OF INTEREST CODE
APPENDIX “A”
GENERAL PROVISIONS
When a designated employee is required to disclose investments and sources of income, they need only disclose investments in business entities and sources of income, which do business in the jurisdiction, plan to do business in the jurisdiction or have done business in the jurisdiction, within the past two (2) years. In addition to other activities, a business entity is doing business within the jurisdiction if it owns real property within the jurisdiction. When a designated employee is required to disclose interest in real property, they need only disclose real property, which is located in whole or in part within not more than two (2) miles outside the boundaries of the jurisdiction or within (2) miles of any land owned or used by the local government agency.
Designated employees shall disclose their financial interests pursuant to the appropriate disclosure category designated for each position.
DISCLOSURE CATEGORIES
Category 1: Persons in this category shall disclose all interests in real property.
Category 2: Persons in this category shall disclose all investments.
Category 3: Persons in this category shall disclose all sources of income.
Category 4: Persons in this category shall disclose all investments in business entities and sources
of income of the type which, within the past two
years, have contracted with the designated
employee’s department to provide services,
supplies, materials, machinery or equipment.
Category 5: Persons in this category shall disclose any business entity in which the designated
employee is a director, officer, partner, trustee,
employee or holds any other position.
Category 6: Persons in this category shall disclose all investments, interests in real property and
sources of income subject to the regulatory,
permit or licensing authority of the Board or
Commission on which the member serves.
-5-
1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16
17 18
19 20
21 22
23 24
25 26
27 28
Disclosure
Category:
Persons in this Category shall
disclose the following:
700 Schedules
1 All interests in real property B
2 All investments A-1, A-2
3 All sources of income A-2, B, C, D, E
4 Investments in business entities
of the type which, within the past
two years, have contracted with
the designated employee’s
department to provide services,
supplies, materials, machinery or
equipment
Sources of income of the type
which, within the past two years,
have contracted with the
designated employee’s department
to provide services, supplies,
materials, machinery or equipment
A-1, A-2
A-2, B, C, D, E
5 Any business entity in which the
designated employee is a director,
officer, partner, trustee, employee
or holds any other position
A-2, C
6 All investments subject to the
regulatory, permit or licensing
authority of the Board of
Commission on which the member
serves
All interests in real property
subject to the regulatory, permit or
licensing authority of the Board or
Commission on which the member
serves
All sources of income subject to
the regulatory, permit or licensing
authority of the Board or
Commission on which the member
serves.
A-1, A-2
B
A-2, B, C, D, E
-6-
1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16
17 18
19 20
21 22
23 24
25 26
27 28
CONFLICT OF INTEREST CODE
APPENDIX “B”
Designated Position Disclosure Category
City Attorney
City Attorney *87200 Filer
Assistant City Attorney 1, 2, 3, 4, 5
Deputy City Attorney I, II, and III 1, 2, 3, 4, 5
Paralegal 1, 2, 3, 4, 5
City Council
Council Member *87200 Filer
City Manager
City Manager *87200 Filer
Assistant City Manager – Economic Vitality and Equity 1, 2, 3, 4, 5 Assistant City Manager – Fiscal Sustainability and Transparency 1, 2, 3, 4, 5 Assistant to the City Manager – Process Improvement 4
Business Development and Community Events Manager 1, 2, 3, 4, 5 Chief Public Affairs and Engagement Officer 4
City Clerk 1, 2, 3, 4, 5
Communications/Public information Manager 4
Cultural Affairs Manager 4
Deputy City Clerk 1, 2, 3, 4, 5
Economic Development Director 1, 2, 3, 4, 5
Economic Development Project Manager 1, 2, 3, 4, 5
Government and Legislative Affairs Coordinator 4
Management Analyst - Cultural Affairs 4
Senior Assistant City Manager 1, 2, 3, 4, 5
-7-
1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16
17 18
19 20
21 22
23 24
25 26
27 28
Consultants/Contract Employees
All Departments and Divisions **
Finance Department
Chief Financial Officer/City Treasurer *87200 Filer
Accounting and Investment Manager 1, 2, 3, 4, 5
Accounting Supervisor 4
Assistant Chief Financial Officer 1, 2, 3, 4, 5
Assistant Chief Financial Officer/Controller 1, 2, 3, 4, 5 Buyer 1, 2, 3, 4, 5
Finance Manager 1, 2, 3, 4, 5
Finance Operations Administrator 4
Financial Systems/Purchasing Manager 1, 2, 3, 4, 5
Management Analyst 4
Management Analyst – Budget 4
Payroll Analyst 4
Payroll Manager 1, 2, 3, 4, 5
Payroll Supervisor 4
Purchasing Supervisor 1, 2, 3, 4, 5
Revenue and Budget Supervisor 1, 2, 3, 4, 5
Senior Accountant 4
Senior Financial Systems Business Analyst 4
Senior Management Analyst 4
Senior Management Analyst – Budget 4
Warehouse Supervisor 2, 3, 4, 5
-8-
1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16
17 18
19 20
21 22
23 24
25 26
27 28
Fire Department
Fire Chief 1, 2, 3, 5
Assistant Fire Chief 1, 2, 3, 5
Battalion Chief 1, 2, 3, 5
Emergency Preparedness Coordinator 4
Fire Captain (including Training Officer and EMS Coordinator) 1, 2, 3 Fire Marshal 1, 2, 3, 5
Housing and Human Services Department
Housing and Human Services Director 1, 2, 3, 4, 5, 6
Enforcement Services Manager 1, 2, 3, 4, 5, 6
Housing and Human Services Project Manager 1, 2, 3, 4, 5, 6 Housing and Rent Stabilization Manager 1, 2, 3, 4, 5
Housing Programs Supervisor 2, 3, 4, 5
Housing Rehabilitation Inspector 1, 4
Housing Specialist 1, 4
Human Services and Crisis Intervention Manager 1, 2, 3, 4, 5, 6 Management Analyst 4
Mental Health Clinician 1, 2, 3, 4, 5
Mental Health Specialist 1, 2, 3, 4, 5
Rent Stabilization Coordinator 1, 4
-9-
1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16
17 18
19 20
21 22
23 24
25 26
27 28
Human Resources Department
Chief Human Resources Officer 1, 2, 3, 4, 5
Deputy Human Resources Director 1, 2, 3, 4, 5
Human Resources Analyst 4
Management Analyst 4
Risk Manager 1, 2, 3, 4, 5
Senior Human Resources Analyst – EEO 4
Senior Human Resources Analyst 4
Workforce Development Manager 1, 2, 3, 4, 5
Information Technology Department
Chief Information Officer 2, 3, 4, 5
Systems Support Manager 4
Parks, Recreation and Community Services Department
Parks, Recreation and Community Services Director 1, 2, 3, 4, 5 Parks, Recreation and Community Services Deputy Director 1, 2, 3, 4, 5 Parks Maintenance Supervisor 4
Recreation and Community Services Manager 1, 2, 3, 4, 5 Recreation and Community Services Supervisor 4
Senior Management Analyst 4
-10-
1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16
17 18
19 20
21 22
23 24
25 26
27 28
Planning and Development Department
Planning and Development Director 1, 2, 3, 4, 5
Advance Planning Manager 1, 2, 3, 4, 5
Building Official 1, 2, 3, 4, 5
Current Planning Manager 1, 2, 3, 4, 5
Deputy Building Official 1, 2, 3, 4, 5
Senior Building and Safety Inspector 1, 2, 3
Senior Management Analyst 4
Senior Planner 1, 2, 3, 4, 5
Police Department
Police Chief 1, 2, 3, 4, 5
Administrative Services Manager 4
Assistant Police Chief 1, 2, 3, 4, 5
Forensic Supervisor 4
Management Analyst 4
Police Captain 1, 2, 3, 5
Police Lieutenant 1, 2, 3, 5
Police Records Manager 4
-11-
1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16
17 18
19 20
21 22
23 24
25 26
27 28
Public Works
Public Works Director/City Engineer 1, 2, 3, 4, 5
Assistant Environment Programs and Operations Manager 4 Assistant Maintenance Operations Manager 4
Building Maintenance Supervisor 1, 2, 3, 4, 5
CIP1 and Environmental Compliance Inspector 4
Engineering Services Manager 4
Environmental Coordinator 4
Environmental Programs and Operations Manager 4
Facility/Electrical Maintenance Supervisor 1, 2, 3, 4, 5 Maintenance Operations Manager 4
Management Analyst 4
Mobility and Traffic Engineering Manager 4
Senior Civil Engineer 1, 2, 3, 5
Senior Management Analyst 4
Senior Public Works Inspector 4
Senior Solid Waste and Recycling Crew Supervisor 4
Street Maintenance Supervisor 1, 2, 3, 4, 5
Traffic Engineering Analyst 4
Traffic Engineering Manager 4
1 Capital Improvement Projects
-12-
1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16
17 18
19 20
21 22
23 24
25 26
27 28
Transportation Department
Chief Transportation Officer 1, 2, 3, 4, 5
Deputy Transportation Officer 1, 2, 3, 4, 5
Facility Maintenance Supervisor 4
Fleet and Facilities Services Manager 4
Management Analyst 4
Senior Management Analyst 4
Training and Safety Instructor 5
Transit Operations Manager 4
Transit Planning Manager 4
Transportation Administration Manager 4
*Disclosure obligations for these designated positions are set forth in Government Code § 87200, et seq. These positions are designated in this Conflict of Interest Code solely for disqualification purposes.
**Consultants and Contract Employees shall be included in the list of designated employees and shall disclose pursuant to the broadest disclosure category in this Code subject to the following limitation: The City Manager may determine, in writing and in accordance with applicable law, which consultants or contract employees, in “designated positions,” are hired to perform a range of duties that do not involve making or participating in making governmental decisions on behalf of the City and, thus, are not required to comply with the broadest disclosure requirements herein. Such written determination shall include a description of the consultant’s duties and, based upon that description, a statement of the extent of disclosure requirements. The City Manager’s determination is a public record and shall be retained for public inspection in the same manner and location as this Code.
-13-
1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16
17 18
19 20
21 22
23 24
25 26
27 28
CONFLICT OF INTEREST CODE
APPENDIX “C”
Designated Position Disclosure Category
Building and Safety Appeals Board
Board Member 1, 2, 3, 4, 5, 6
Civil Service Commission
Commissioner 1, 2, 3, 4, 5
Consultants/Contract Employees
All Departments and Divisions **
Cultural Affairs Commission
Commissioner 1, 2, 3, 4, 5, 6
Finance Advisory Committee
Committee Member 1, 2, 3, 4, 5
Municipal Code Appeals Committee
Committee Member 1, 2, 3, 4, 5, 6
Parks, Recreation and Community Services Commission
Commissioner 1, 2, 3, 4, 5
Planning Commission
Planning Commissioner *87200 Filer
-14-
1 2
3 4
5 6
7 8
9 10
11 12
13 14
15 16
17 18
19 20
21 22
23 24
25 26
27 28
*Disclosure obligations for these designated positions are set forth in Government Code § 87200, et seq. These positions are designated in this Conflict of Interest Code solely for disqualification purposes.
**Consultants and Contract Employees shall be included in the list of designated employees and shall disclose pursuant to the broadest disclosure category in this Code subject to the following limitation: The City Manager may determine, in writing and in accordance with applicable law, which consultants or contract employees, in “designated positions,” are hired to perform a range of duties that do not involve making or participating in making governmental decisions on behalf of the City and, thus, are not required to comply with the broadest disclosure requirements herein. Such written determination shall include a description of the consultant’s duties and, based upon that description, a statement of the extent of disclosure requirements. The City Manager’s determination is a public record and shall be retained for public inspection in the same manner and location as this Code.