Item No. 13.
TO:
HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM:
OFFICE OF THE CITY CLERK
ALICIA DUARTE, CITY CLERK
BY:
JOHN M. FUNK, CITY ATTORNEY
DATE:
AUGUST 11, 2026
DIRECTION TO CONDUCT BIENNIAL REVIEW OF THE CITY'S CONFLICT OF INTEREST SUBJECT:
CODE IDENTIFYING WHICH CITY OFFICIALS AND STAFF ARE REQUIRED TO FILE A
STATEMENT OF ECONOMIC INTERESTS
EXECUTIVE SUMMARY
Each even -numbered year, the City Clerk and City Attorney must conduct the biennial review of the City's Conflict of Interest Code identifying which City Officials and staff are required to file a Statement of Economic Interests (FPPC Form 700). The City's Conflict of Interest Code was last adopted in 2024 (Attachment A). 7x��7dil��il�l�l7_��[�P►
That the City Council:
Direct the City Clerk and City Attorney to conduct the biennial review of the City's Conflict of Interest Code.
BACKGROUND
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, if the code must be amended. A conflict of interest code tells public officials, governmental employees, and consultants what financial interests they must disclose on their Statement of Economic Interests (Form 700). An amendment may be required in order to include new positions and delete titles or positions that have been eliminated or to modify disclosure categories. Positions listed under the City's Conflict of Interest Code are required to file a Form 700 when assuming office, annually, and when leaving office.
ANALYSIS
The City's code designates all positions that make or participate in the making of governmental decisions. The disclosure assigned to those positions accurately requires that all investments, business positions, interests in real property, and sources of income that may foreseeably be affected materially by the decisions made by those holding designated positions are reported.
By or before October 1, 2026, the City Clerk will file with the City Council a biennial notice indicating whether the code requires amendments and the nature of the amendments. All revisions to the City's Conflict of Interest Code must be approved by the City Council by December 31, 2026.
CITY COUNCIL PRIORITIES
Fiscal Responsibility
Public Engagement
FISCAL IMPACT
There is no fiscal impact associated with item.
Attachments
RESOLUTION NO. 24-8282
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF DOWNEY
AMENDING THE CITY'S CONFLICT OF INTEREST CODE WHICH
l INCORPORATES BY REFERENCE THE FAIR POLITICAL PRACTICES
COMMISSION'S STANDARD MODEL CONFLICT OF INTEREST CODE
WHEREAS, the Political Reform Act, Government Code Section 81000, et seq., requires State and local government agencies to adopt and promulgate conflict of interest codes; and, WHEREAS, the Fair Political Practices Commission has adopted California Code of Regulations, Title 2, 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 hearing to conform to amendments in the Political Reform Act; 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 code must be updated; and,
WHEREAS, it has been determined that the City's Conflict of Interest Code needs to be updated with respect to adding new positions; revising disclosure categories; and, revising titles of existing positions; and
WHEREAS, the City Council has determined that the attached Appendices accurately set forth those designated positions and categories of reportable financial interests; and, WHEREAS, the City Council hereby amends the Conflict of Interest Code to include the following positions: Budget Analyst, Citywide System Network Engineer, Deputy Director of Community Development — Planning, Economic Development Director, Finance Manager, Homelessness Solutions Manager, Revenue Supervisor, Senior Code Enforcement Officer, Senior Management Analyst, System Network Engineer, and Senior Permit Technician.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF DOWNEY DOES HEREBY RESOLVE AS FOLLOWS:
SECTION 1. The terms of Title 2, California Code of Regulations, Section 18730, and any amendments to it duly adopted by the Fair Political Practices Commission, are hereby incorporated into the Conflict of Interest Code of the City of Downey by reference. This regulation and the attached Appendices designating officials and employees and establishing economic disclosure categories shall constitute the Conflict of Interest Code of the City of Downey.
SECTION 2. Appendix A to this Resolution identifies which officials and employees are designated to report economic interests with reference to the disclosure categories for that position. Appendix B to this Resolution describes each of the disclosure categories and the type of economic interests that must be disclosed. Persons holding designated positions shall file a Statement of Economic Interests (Form 700) and disclose those interests, if any, for their position.
SECTION 3. The City Council hereby designates the City Clerk as the person to whom all officials and employees are required to submit a Statement of Economic Interests (Form 700) pursuant to this Conflict of Interest Code. In the alternative, the City Clerk may require that all officials and employees file their Form 700 electronically pursuant to the Secretary of State's online portal. The City Clerk shall retain the originals of said statements, which shall be available for public inspection and reproduction pursuant to Government Code Section 81008.
RESOLUTION NO. 24-8282
PAGE 2
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mARib TRUJILLO, a or
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W"uKeffm
FUNK
Attorney
I HEREBY CERTIFY that the foregoing Resolution was adopted by the City Council of tw-.
City of Downey at a Regular meeting held on the 1 oth day of December, 2024, by the following vote, to wit:
AYES: Council Members: Ortiz, Pemberton, Sosa, Mayor Trujillo NOES: Council Member: None.
ABSENT: Council Member: Frometa
ABSTAIN: Council Member.- None.
MAqiKALI-CIA DUARTE,- CM
City Clerk
APPENDIX "A"
RESOLUTION NO. 24-8282
PAGE 3
APPENDIX A
DESIGNATION OF OFFICIALS AND EMPLOYEES
The following positions shall disclose those economic interests noted in the disclosure category for that position and as fully described in Appendix B as follows:
DEPARTMENT/DESIGNATED POSITION DISCLOSURE CATEGORY
ADMINISTRATION
City Clerk
1, 2, 3, 4, 5, 6, 7
Deputy City Clerk
1, 2, 3, 4, 5, 6, 7
Assistant City Manager
1, 2, 3, 4, 5, 6,7
Assistant to the City Manager
1, 2, 3, 4, 5, 6, 7
Senior Management Analyst
1, 2, 3, 4, 7
Management Analyst
1, 2, 3, 4, 7
Economic Development Director
1, 2, 3, 4, 5, 6,7
Homelessness Solutions Manager
1, 2, 3, 4, 5, 6,7
Information Technology & Systems Manager
1, 2, 3, 4, 5, 6, 7
Citywide System Network Engineer
1, 2, 3, 4, 7
System Network Engineer
1, 2, 3, 4, 7
HUMAN RESOURES
Human Resources Director 1, 2, 3, 4, 5, 6, 7
Human Resources Manager 1, 2, 3, 4, 5, 6, 7
Human Resources Analyst 2, 3, 4, 5, 7
Human Resources Specialist 3, 4, 5, 7
COLUMBIA MEMORIAL SPACE CENTER
Executive Director of the Columbia 1, 2, 3, 4, 5, 6, 7
Memorial Space Science Learning Center
Learning Center Supervisor 3, 4, 7
RESOLUTION NO. 24-8282
PAGE 4
CITY LIBRARY
Library Director 1, 2, 3, 4, 5, 6, 7
Library Administrator 3, 4, 7
FINANCE
Finance Director
1, 2, 3, 4, 5, 6, 7
Assistant Director of Finance
1, 2, 3, 4, 5, 6,7
Finance Manager
1, 2, 3, 4, 5, 6, 7
Revenue Supervisor
1, 2, 3, 4, 5, 6, 7
Senior Accountant
1, 2, 3, 4, 5, 6, 7
Purchasing Coordinator
1, 2, 3, 4, 5, 6, 7
Principal Accountant
1, 2, 3, 4, 5, 6, 7
Budget Analyst
1, 2, 3, 4, 5, 6, 7
Management Analyst
3, 4, 5, 7
COMMUNITY DEVELOPMENT, PLANNING, & CODE ENFORCEMENT
Community Development Director 1, 2, 3, 4, 5, 6, 7
Deputy Director of Community Development -Planning 1, 2, 3, 4, 5, 6, 7 Principal Planner
1, 2, 3, 4, 5, 6, 7
Senior Planner
1, 2, 3, 4, 5, 6, 7
Associate Planner
1, 2, 3, 4, 5, 6, 7
Assistant Planner
1, 2, 3, 4, 5, 6, 7
Building Official
1, 2, 3, 4, 5, 6, 7
Principal Building Inspector
1, 2, 3, 4, 5, 6, 7
Code Enforcement Supervisor
1, 2, 3, 4, 5, 6, 7
Senior Management Analyst
1, 2, 3, 4, 5, 6, 7
Senior Code Enforcement Officer
1, 2, 3, 4, 5, 6, 7
Senior Permit Technician 1, 2, 3, 4, 5, 6, 7
RESOLUTION NO. 24-8282
PAGE 5
PARKS & RECREATION
Parks & Recreation Director
Recreation Manager
Recreation Supervisor
Program Supervisor
Recreation Coordinator
Management Analyst
":2
1, 2, 3, 4, 5, 6, 7
4,6,7
4,6,7
4,6,7
4,6,7
4, 6, 7
Fire Chief 1, 2, 3, 4, 5, 6, 7
Assistant Fire Chief/Fire Marshall 1, 2, 3, 4, 5, 6, 7
Battalion Chief 1, 2, 3, 4, 5, 6, 7
Fire Inspector 1, 2, 3, 4, 5, 6, 7
Hazardous Materials Fire Inspector 1, 2, 3, 4, 5, 6, 7
Emergency Preparedness Program Manager 1, 2, 3, 4, 5, 6, 7 POLICE
Police Chief 1, 2, 3, 4, 5, 6, 7
Police Captain 1, 2, 3, 4, 5, 6, 7
Police Lieutenant 1, 2, 3, 4, 5, 6, 7
City Prosecutor 1, 2, 3, 4, 5, 6, 7
PUBLIC WORKS
Public Works Director/City Engineer
Deputy Director of Public Works
Deputy Director/Utilities Manager
Principal Civil Engineer
Associate Civil Engineer
Assistant Engineer
1, 2, 3, 4, 5, 6, 7
1, 2, 3, 4, 5, 6, 7
1, 2, 3, 4, 5, 6, 7
1, 2, 3, 4, 5, 6, 7
1, 2, 3, 4, 5, 6, 7
1, 2, 3, 4, 5, 6, 7
RESOLUTION NO. 24-8282
PAGE 6
GIS Manager
Superintendent of Maintenance & Facilities
Assistant Superintendent of Maintenance & Facilities
Superintendent of Utilities
Assistant Superintendent of Utilities
Management Analyst
ALL DEPARTMENTS
Consultants/Special Legal Counsel*
1, 2, 3, 4, 5, 6, 7
1, 2, 3, 4, 5, 6, 7
1, 2, 3, 4, 5, 6, 7
1, 2, 3, 4, 5, 6, 7
1, 2, 3, 4, 5, 6, 7
1, 2, 3, 4, 5, 6, 7
1, 2, 3, 4, 5, 6, 7
*Consultants/Special Legal Counsel shall disclose pursuant to the broadest disclosure category in the City's Conflict of Interest Code if:
(a) The Consultant/Special Legal Counsel serves in a staff capacity with the City and in that capacity performs the same or substantially the same duties for the City that would otherwise be performed by a person holding the position specified or that should be specified in the City's Conflict of Interest Code; or
(b) The Consultant/Special Counsel makes a government decision as set forth in 2 California Code of Regulations18700.
GOVERNMENT CODE SECTION 87200 POSITIONS
The following positions are subject to broadest disclosure pursuant to Government Code Section 87200:
City Council Member
City Council Candidate
City Manager
City Treasurer
City Attorney
Planning Commissioner
Other Local Agency Boards
• Successor Agency Board Member
• Housing Successor Agency Member
• Downey Public Financing Authority Board Member
RnARDS & COMMISSIONS
Board of Building Appeals 1, 2, 3, 4, 5, 6, 7
Public Facilities Financing Corporation 1, 2, 3, 4, 5, 6, 7 Recreation & Community Services Commission 1, 2, 3, 4, 5, 6, 7 Water Facilities Corporation 1, 2, 3, 4, 5, 6, 7
APPENDIX "B"
RESOLUTION NO. 24-8282
PAGE 7
APPENDIX B
ECONOMIC DISCLOSURE CATEGORIES
CATEGORYI:
Interests in Real Property. This category requires the disclosure of all interest in real property, including an ownership interest, deed of trust, easement, option or leasehold interest, within (in whole or in part) the City of Downey or not more than two miles outside the boundaries of the City of Downey if the real property interest has a value of two thousand dollars ($2,000) or more. Disclosure is not required for ownership of a principal residence. Note that this category also requires disclosure the filer's spouse's, registered domestic partner's or dependent children's interest in real property that meet the disclosure requirements in this category.
CATEGORY 2:
Investments. This category requires the disclosure of investments in any business entity (including a consulting business or other independent contracting business) that is located in, doing business in, planning to do business in or which has done business during the previous two years in the City of Downey in which the filer, the filer's spouse or registered domestic partner or filer's dependent children have a direct, indirect or beneficial interest totaling $2,000 or more at any time during the reporting period . Investment in this category means investments in a business entity by way of stock, securities, bonds, debt instrument, options, or investments in a sole proprietorship, corporations, partnerships, business trusts, and if the filer, the filer's spouse or registered domestic partner and dependent children together had a 10% or greater ownership in a business entity or trust.
CATEGORY 3
Sources of Income. This category requires the disclosure of all gross income exceeding $500.00 or more received from any source located in, doing business in, planning to do business in or has done business during the previous two years in the City of Downey. Income in this category includes salary, wages, per diem, expense reimbursement, profits, incentive compensation, income from investments, the filer's community property interest (50%) of his or her spouse's or registered domestic partner's income from such business, commission income and payments on loans made to others. Income also includes a pro rata share of any income of any business entity located in or doing business in the City of Downey in which the filer, and/or the filer's spouse or registered domestic partner owns, directly, indirectly or beneficially a 10% interest or greater. Income and reimbursement of expenses from a local, state or federal government agency need not be disclosed.
CATEGORY 4
Income and Investments from Certain Manufacturing Businesses. This category requires the disclosure of all income from and investments in businesses which manufacture or sell supplies, equipment or services of the type utilized by the Department, in which the person is employed or which is subject to the jurisdiction of an appointed Commission or Board.
RESOLUTION NO. 24-8282
PAGE 8
CATEGORY 5
Income and Investments from Financial Institutions. This category requires the disclosure of all investments in and income from all banks, savings and loan associations, insurance companies, investment companies, stockbrokers, title companies, financial consultants, data processing firms or consultants.
CATEGORY 6
Income and Investments in Construction Industry. This category requires the disclosure of all income from and investments in business entities in the construction or building industry located in, doing business in, planning to do business in or has done business during the previous two years in the City of Downey.
CATEGORY 7
Loans, Honoraria, Travel Payments and Gifts. This category requires the disclosure of any loans, honoraria, travel payments, advances and reimbursements in any amount from non- governmental sources, located in, doing business in, planning to do business in, or has done business during the previous two years in the City of Downey. Gifts are reportable if the fair market value is $50 or more from a single source or multiple gifts totaling $50 or more from a single source in the reporting period. Gifts are reportable regardless where the donor is located.