City Council
Staff Report
From: City Manager
Report Type: INFORMATION REPORTS
Lead Department: City Clerk
Meeting Date: September 28, 2026
Report #:2609-6756
TITLE
Conflict of Interest Code 2026 Local Agency Biennial Notice; CEQA Status – Not a Project
RECOMMENDATION
Receive the attached Conflict of Interest Code 2026 Local Agency Biennial Notice. No City Council action is required.
BACKGROUND / ANALYSIS
The Palo Alto Municipal Code 1 and the Political Reform Act 2 require the City to adopt a list of designated positions and disclosure responsibilities for each position subject to the Conflict of Interest Code for Designated Employees. The Conflict of Interest Code lists specific City positions other than those specified in Government Code section 87200 which involve making or participating in making decisions which have a reasonably foreseeable material effect on an economic interest, and to designate for each position the specific types of investments, business positions, interests in real property and sources of income which are reportable based on the scope of the decision-making authority of the position. The City Council adopts the Conflict of Interest Code by resolution.
The Political Reform Act requires the City to review its Conflict of Interest Code every two years, typically in even-numbered years. The City Council most recently reviewed and adopted the Conflict of Interest Code in February 2025. While the City is in compliance with the 2-year requirement, potential updates have been identified and staff recommends proceeding with these updates to stay consistent with the even-numbered year cycle.
In accordance with these requirements, the attached notice must be submitted to the City Council by October 1, 2026. As stated in the notice, code updates have been identified and are 1 City of Palo Alto Municipal Code, Chapter 2.09:
https://codelibrary.amlegal.com/codes/paloalto/latest/paloalto_ca/0-0-0-60594 2 Government Code, Title 9, Chapter 7, Article 3:
https://www.leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=GOV&division=&title=9.&part=&c hapter=7.&article=3
being prepared by staff. Staff anticipates presenting the recommended code updates to Council by the end of calendar year 2026.
FISCAL/RESOURCE IMPACT
There are no significant fiscal/resource impacts related to this item. The costs related to processing/managing the Conflict of Interest Code and Statements of Economic Interest are part of the City Clerk Department budget.
STAKEHOLDER ENGAGEMENT
City Clerk’s Office staff is collaborating with the Human Resources Department, as well as the City Attorney’s Office and all City department heads to identify and review potential updates to the Conflict of Interest Code.
ENVIRONMENTAL REVIEW
This report is for informational purposes only with no action required by the Council and is therefore not a project subject to CEQA review.
ATTACHMENTS
Attachment A: 2026 Local Agency Biennial Notice
APPROVED BY:
Mahealani Ah Yun, City Clerk