CC - 09-01- 2026
#10
Conflict of Interest Code
Amendment
Desk Item
CC - 09-01- 2026
#10
Conflict of Interest Code
Amendment
Supplemental Report
RESOLUTION NO. 26-XXX
A RESOLUTION OF THE CUPERTINO CITY COUNCIL
RESCINDING RESOLUTION NO. 24-099 AND AMENDING THE
CITY OF CUPERTINO CONFLICT OF INTEREST CODE
FOR OFFICIALS AND DESIGNATED EMPLOYEES
WHEREAS, the Political Reform Act of 1974, Government Code section 81000 et seq. (the “Act” or “Political Reform Act”), governs the disclosure of political campaign contributions and spending by candidates and ballot measure committees, and sets ethics rules for state and local government officials that impose limits on decisions or votes that affect the official's financial interests; and
WHEREAS, the City Clerk is the local filing officer for all filings and statements required by the Political Reform Act including campaign contribution and expenditure reports from candidates for City Council, controlled committees, and independent expenditure committees, as well as Statements of Economic Interest from current City officials and designated employees, per the City's Conflict of Interest Code; and WHEREAS, the Political Reform Act requires every state or local government agency to adopt and promulgate a Conflict of Interest Code; and
WHEREAS, the City Council last updated the City’s Conflict of Interest Code on December 3, 2024 by adoption of Resolution No. 24-099; and
WHEREAS, the City Council now desires to amend the City’s Conflict of Interest Code to update the list of designated positions.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF CUPERTINO DOES HEREBY RESOLVE AS FOLLOWS:
1. That Resolution No. 24-099 is hereby rescinded; and
2. That the terms of Title 2 California Code of Regulations section 18730 and any amendments to it duly adopted by the FPPC shall, along with the Code entitled, “City of Cupertino Conflict of Interest Code for Officials and Designated Employees” as set forth in Exhibit A along with attached Appendices A and B, in which members, consultants, and employees are Resolution No. 26-
designated and disclosure categories are set forth, constitute the Conflict of Interest Code of the City of Cupertino; and
3. That all Statements of Economic Interest shall be filed electronically with the City Clerk.
PASSED AND ADOPTED at a regular meeting of the City Council of the City of Cupertino this 1st day of September 2026, by the following vote.
Members of the City Council
AYES:
NOES:
ABSENT:
ABSTAIN:
SIGNED:
Kitty Moore, Mayor City
of Cupertino
Date
ATTEST:
Lauren Sapudar, City Clerk
Date
EXHIBIT A
CITY OF CUPERTINO CONFLICT OF INTEREST CODE
FOR OFFICIALS AND DESIGNATED EMPLOYEES
The Political Reform Act, Government Code section 81000 et seq. requires state and local government agencies to adopt and promulgate conflict of interest codes. The Fair Political Practices Commission has adopted a regulation, 2 Cal. Code Regs. section 18730, which contains the terms of a standard conflict of interest code. It can be incorporated by reference and may be amended by the Fair Political Practices Commission after public notice and hearings to conform to amendments to the Political Reform Act. Therefore, the terms of 2 Cal. Code Regs. section 18730 and any amendments to it duly adopted by the Fair Political Practices Commission are hereby incorporated by reference and, along with the attached Appendices A and B in which members, consultants, and employees are designated and disclosure categories are set forth shall constitute the conflict of interest code of the City of Cupertino.
Officials and designated employees under Government Code section 87200 shall file electronic statements of economic interests (Form 700) with the City Clerk who will make the statements available for public inspection and reproduction. (Gov.
Code, § 81008,)
Upon receipt of the statements (Form 700) of the City of Cupertino City Council, City Manager, City Attorney, City Treasurer, and Planning Commissioners, the agency shall electronically forward the original of these statements to the Fair Political Practices Commission. The City Clerk will electronically retain original statements for all other designated employees.
It has been determined that the positions listed below manage public investments and will file a statement of economic interests (Form 700) pursuant to Government Code section 87200:
City Treasurer (Director of Finance Administrative Services) Deputy City Treasurer (Finance Manager)
APPENDIX A
DESIGNATED POSITIONS AND
APPLICABLE REPORTABLE INTEREST CATEGORIES
Title Assigned Disclosure Category
ADMINISTRATIVE SERVICES, FINANCE & HUMAN RESOURCES
Director of Administrative Services 1 (Gov. Code § 87200 filer) (Treasurer) Finance Manager (Deputy City 1 (Gov. Code § 87200 filer) Treasurer) Human Resources Manager 2
Budget Manager 2
Purchasing Manager 2
Management Analyst
Senior Management Analyst 3
Human Resources Analyst I/II 3
Accountant I/II 3
Senior Accountant 3
Account Clerk I/II 3
Accounting Technician 3
APPOINTED OR ELECTED OFFICIALS & COMMISSIONS
Audit Committee 2
Bicycle Pedestrian Commission 1
Arts and Culture Commission 1
Economic Development Committee 1
Housing Commission 1
Library Commission 1
Parks and Recreation Commission 1
Planning Commission 1 (Gov. Code § 87200 filers)
Public Safety Commission 1
Sustainability Commission 1
Technology, Information, & 3
Communications Commission
CITY ATTORNEY’S OFFICE
City Attorney 1 (Gov. Code § 87200 filer)
Senior Assistant City Attorney 1
Assistant City Attorney 1
Senior Management Analyst 1
Legal Services Manager 1
CITY MANAGER’S OFFICE
City Manager 1 (Gov. Code § 87200 filer)
Assistant City Manager 1
Deputy City Manager 1
Administration
Assistant to the City Manager 1
Management Analyst 1
Senior Management Analyst 1
Executive Assistant to the City Manager 1
City Clerk’s Office
City Clerk 1
Deputy City Clerk 1
Communications & Public Information
Public Information Officer 3
Communications and Marketing 1
Coordinator
Emergency Management
Assistant to the City Manager 1
Emergency Services Coordinator 1
Management Analyst 1
Community Relations Coordinator 1
Economic Development
Economic Development Manager 1
Human Resources
Human Resources Manager 2
Human Resources Analyst I/II 3
Management Analyst 1
COMMUNITY DEVELOPMENT
Director of Community Development 1
Assistant Director of Community 1
Development
Planning
Planning Manager 1
Senior Planner 1
Associate Planner 1
Assistant Planner 1
Management Analyst 1
Permit Technician 1
Building
Building Official 1
Deputy Building Official 1
Senior Building Inspector 1
Building Inspector 1
Permit Technician 1
Plan Check Engineer 1
Housing
Housing Manager 1
Senior Housing Coordinator 1
Code Enforcement
Code Enforcement Supervisor 1
Senior Code Enforcement Officer 14
Code Enforcement Officer 14
Consultants
Consultants (see Appendix B As determined by City Manager definitions)
FINANCE
Director of Finance (Treasurer) 1 (Gov. Code § 87200 filer) Finance Manager (Deputy City Treasurer) 2
Budget Manager 2
Purchasing Manager 2
Management Analyst 1
Senior Management Analyst 3
Accountant I/II 3
Senior Accountant 3
Account Clerk I/II 3
Accounting Technician 3
INNOVATION & TECHNOLOGY
Chief Technology Officer 1
Innovation and Technology Manager 3
Senior Business Systems Analyst 3
Business Systems Analyst 3
Multimedia Communication Specialist 3
Management Analyst 1
PUBLIC WORKS
Director of Public Works 1
Assistant Director of Public Works 1
Capital Improvement Programs 1
Manager
Senior Public Works Project Manager 1
Public Works Projects Manager 1
Service Center Superintendent 3
Public Works Supervisor 1
City Engineer 1
Public Works Inspector 1
Senior Management Analyst 1
Management Analyst 1
Environmental Services & Environmental Affairs
Environmental Programs Manager 1
Environmental Programs Specialist 3
Environmental Programs Assistant 3
Environmental Compliance Technician 1
Traffic & Engineering
Senior Planner 1
(Transit and Transportation)
Assistant Engineer 1
Transportation Manager 1
Senior Civil Engineer 1
Associate Civil Engineer 1
Senior Engineering Technician 16
Engineering Technician 16
Environmental Programs Assistant (Safe 3
Routes to School)
PARKS AND RECREATION
Director of Parks and Recreation 1
Assistant Director of Parks and
Recreation 1
Recreation Manager 3
Senior Management Analyst 1
Management Analyst 1
Communications and Marketing
Coordinator 1
Appendix B
DISCLOSURE CATEGORIES AND DEFINITIONS
1. Category 1
What to report? All investments, positions in business entities, sources of income (including gifts, loans, and travel payments), and interests in real property.
What Form 700 schedules? All Schedules (A through E)
2. Category 2
What to report? All investments, positions in business entities, and sources of income (including gifts, loans, and travel payments).
What Form 700 schedules? A, C, D, E
3. Category 3
What to report? All investments, positions in business entities, and sources of income (including gifts, loans, and travel payments) from sources of the type that provide services, supplies, materials, machinery or equipment to the City.
What Form 700 schedules? A, C, D, E
Definitions
For the purposes of these disclosure categories, the definitions and regulations contained in the Political Reform Act, Government Code sections 81000 et seq., and the Fair Political Practices Commission regulations, 2 Cal. Code Regs. section 18730, shall apply.
RESOLUTION NO. 26-XXX
A RESOLUTION OF THE CUPERTINO CITY COUNCIL
RESCINDING RESOLUTION NO. 24-099 AND AMENDING THE
CITY OF CUPERTINO CONFLICT OF INTEREST CODE
FOR OFFICIALS AND DESIGNATED EMPLOYEES
WHEREAS, the Political Reform Act of 1974, Government Code section 81000 et seq. (the “Act” or “Political Reform Act”), governs the disclosure of political campaign contributions and spending by candidates and ballot measure committees, and sets ethics rules for state and local government officials that impose limits on decisions or votes that affect the official's financial interests; and
WHEREAS, the City Clerk is the local filing officer for all filings and statements required by the Political Reform Act including campaign contribution and expenditure reports from candidates for City Council, controlled committees, and independent expenditure committees, as well as Statements of Economic Interest from current City officials and designated employees, per the City's Conflict of Interest Code; and WHEREAS, the Political Reform Act requires every state or local government agency to adopt and promulgate a Conflict of Interest Code; and
WHEREAS, the City Council last updated the City’s Conflict of Interest Code on December 3, 2024 by adoption of Resolution No. 24-099; and
WHEREAS, the City Council now desires to amend the City’s Conflict of Interest Code to update the list of designated positions.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF CUPERTINO DOES HEREBY RESOLVE AS FOLLOWS:
1. That Resolution No. 24-099 is hereby rescinded; and
2. That the terms of Title 2 California Code of Regulations section 18730 and any amendments to it duly adopted by the FPPC shall, along with the Code entitled, “City of Cupertino Conflict of Interest Code for Officials and Designated Employees” as set forth in Exhibit A along with attached Appendices A and B, in which members, consultants, and employees are Resolution No. 26-
designated and disclosure categories are set forth, constitute the Conflict of Interest Code of the City of Cupertino; and
3. That all Statements of Economic Interest shall be filed electronically with the City Clerk.
PASSED AND ADOPTED at a regular meeting of the City Council of the City of Cupertino this 1st day of September 2026, by the following vote.
Members of the City Council
AYES:
NOES:
ABSENT:
ABSTAIN:
SIGNED:
Kitty Moore, Mayor
City of Cupertino
Date
ATTEST:
Lauren Sapudar, City Clerk
Date
EXHIBIT A
CITY OF CUPERTINO CONFLICT OF INTEREST CODE
FOR OFFICIALS AND DESIGNATED EMPLOYEES
The Political Reform Act, Government Code section 81000 et seq. requires state and local government agencies to adopt and promulgate conflict of interest codes. The Fair Political Practices Commission has adopted a regulation, 2 Cal. Code Regs. section 18730, which contains the terms of a standard conflict of interest code. It can be incorporated by reference and may be amended by the Fair Political Practices Commission after public notice and hearings to conform to amendments to the Political Reform Act. Therefore, the terms of 2 Cal. Code Regs. section 18730 and any amendments to it duly adopted by the Fair Political Practices Commission are hereby incorporated by reference and, along with the attached Appendices A and B in which members, consultants, and employees are designated and disclosure categories are set forth shall constitute the conflict of interest code of the City of Cupertino.
Officials and designated employees under Government Code section 87200 shall file electronic statements of economic interests (Form 700) with the City Clerk who will make the statements available for public inspection and reproduction. (Gov.
Code, § 81008,)
Upon receipt of the statements (Form 700) of the City of Cupertino City Council, City Manager, City Attorney, City Treasurer, and Planning Commissioners, the agency shall electronically forward the original of these statements to the Fair Political Practices Commission. The City Clerk will electronically retain original statements for all other designated employees.
It has been determined that the positions listed below manage public investments and will file a statement of economic interests (Form 700) pursuant to Government Code section 87200:
City Treasurer (Director of Finance)
APPENDIX A
DESIGNATED POSITIONS AND
APPLICABLE REPORTABLE INTEREST CATEGORIES
Title Assigned Disclosure Category
APPOINTED OR ELECTED OFFICIALS & COMMISSIONS
Audit Committee 2
Bicycle Pedestrian Commission 1
Arts and Culture Commission 1
Economic Development Committee 1
Housing Commission 1
Library Commission 1
Parks and Recreation Commission 1
Planning Commission 1 (Gov. Code § 87200 filers)
Public Safety Commission 1
Sustainability Commission 1
Technology, Information, & 3
Communications Commission
CITY ATTORNEY’S OFFICE
City Attorney 1 (Gov. Code § 87200 filer)
Senior Assistant City Attorney 1
Assistant City Attorney 1
Senior Management Analyst 1
Legal Services Manager 1
CITY MANAGER’S OFFICE
City Manager 1 (Gov. Code § 87200 filer)
Deputy City Manager 1
Assistant to the City Manager 1
Management Analyst 1
Senior Management Analyst 1
Executive Assistant to the City Manager 1
City Clerk’s Office
City Clerk 1
Deputy City Clerk 1
Communications & Public Information
Public Information Officer 3
Communications and Marketing 1
Coordinator
Emergency Management
Emergency Services Coordinator 1
Management Analyst 1
Community Relations Coordinator 1
Economic Development
Economic Development Manager 1
Human Resources
Human Resources Manager 2
Human Resources Analyst I/II 3
Management Analyst 1
COMMUNITY DEVELOPMENT
Director of Community Development 1
Assistant Director of Community 1
Development
Planning
Planning Manager 1
Senior Planner 1
Associate Planner 1
Assistant Planner 1
Management Analyst 1
Permit Technician 1
Building
Building Official 1
Deputy Building Official 1
Senior Building Inspector 1
Building Inspector 1
Permit Technician 1
Plan Check Engineer 1
Housing
Housing Manager 1
Senior Housing Coordinator 1
Code Enforcement
Code Enforcement Supervisor 1
Senior Code Enforcement Officer 1
Code Enforcement Officer 1
Consultants
Consultants (see Appendix B As determined by City Manager
definitions)
FINANCE
Director of Finance (Treasurer) 1 (Gov. Code § 87200 filer) Finance Manager (Deputy City Treasurer) 2
Budget Manager 2
Purchasing Manager 2
Management Analyst 1
Senior Management Analyst 3
Accountant I/II 3
Senior Accountant 3
Account Clerk I/II 3
Accounting Technician 3
INNOVATION & TECHNOLOGY
Chief Technology Officer 1
Innovation and Technology Manager 3
Senior Business Systems Analyst 3
Business Systems Analyst 3
Multimedia Communication Specialist 3
Management Analyst 1
PUBLIC WORKS
Director of Public Works 1
Assistant Director of Public Works 1
Capital Improvement Programs 1
Manager
Senior Public Works Project Manager 1
Public Works Projects Manager 1
Service Center Superintendent 3
Public Works Supervisor 1
City Engineer 1
Public Works Inspector 1
Senior Management Analyst 1
Management Analyst 1
Environmental Services & Environmental Affairs
Environmental Programs Manager 1
Environmental Programs Specialist 3
Environmental Programs Assistant 3
Environmental Compliance Technician 1
Traffic & Engineering
Senior Planner 1
(Transit and Transportation)
Assistant Engineer 1
Transportation Manager 1
Senior Civil Engineer 1
Associate Civil Engineer 1
Senior Engineering Technician 1
Engineering Technician 1
Environmental Programs Assistant (Safe 3
Routes to School)
PARKS AND RECREATION
Director of Parks and Recreation 1
Assistant Director of Parks and
Recreation 1
Recreation Manager 3
Senior Management Analyst 1
Management Analyst 1
Communications and Marketing
Coordinator 1
Appendix B
DISCLOSURE CATEGORIES AND DEFINITIONS
1. Category 1
What to report? All investments, positions in business entities, sources of income (including gifts, loans, and travel payments), and interests in real property.
What Form 700 schedules? All Schedules (A through E)
2. Category 2
What to report? All investments, positions in business entities, and sources of income (including gifts, loans, and travel payments).
What Form 700 schedules? A, C, D, E
3. Category 3
What to report? All investments, positions in business entities, and sources of income (including gifts, loans, and travel payments) from sources of the type that provide services, supplies, materials, machinery or equipment to the City.
What Form 700 schedules? A, C, D, E
Definitions
For the purposes of these disclosure categories, the definitions and regulations contained in the Political Reform Act, Government Code sections 81000 et seq., and the Fair Political Practices Commission regulations, 2 Cal. Code Regs. section 18730, shall apply.