City of Piedmont
COUNCIL AGENDA REPORT
DATE: August 17, 2026
TO: Mayor and Council
FROM: Rosanna Bayon Moore, City Administrator
SUBJECT: Consideration of a Resolution Updating City Council Policy No. 24 - Conflict of Interest Code
RECOMMENDATION
Approve the attached update to City Council Policy No. 24 – Conflict of Interest Code.
BACKGROUND
The Political Reform Act (PRA) requires that each city in the State of California has a Conflict of Interest Code which prohibits certain actions considered conflicts of interest and defines which officers and employees of the City must disclose certain financial details to the public. State law requires that each local agency must review the Conflict of Interest Code biennially and make changes when necessary.
City Councilmembers, Planning Commissioners, City Attorney, Finance Director, Police and Fire Pension Board, the City Administrator and other public officials and employees who manage public investments file their Form 700 pursuant to Government Code section 87200, rather than the disclosure categories identified in the Conflict of Interest Code.
There are three components to a Conflict of Interest Code:
1) Terms of the Code, which should incorporate Regulation 18730; 2) List of designated positions that would file a Statement of Economic Interest (Form 700); and
3) Disclosure categories, which identify the specific interests to be reported on a Form 700.
The City first adopted its Conflict of Interest Code in 1980 and revised it in 1988, 2014 and 2018.
The City Clerk and the City Attorney’s office reviewed the current Conflict of Interest Code and have determined that updates need to be made to include new positions and modify titles of existing positions.
Proposed revisions to the Conflict of Interest Code are indicated in red. The proposed revisions to the Policy section are to change the location of the filing of the Form 700 to be in the manner specified by the State of California Fair Political Practices Commission and the retention of the form and notifications in a manner consistent with the City’s retention schedule.
Proposed revisions to the designated positions in Appendix A include adding the positions of Administrative Analyst, Building Inspector, Communications Officer, Human Resources Manager, Police Sergeant, Sustainability Program Manager, and deleting the Assistant City Administrator position. Additionally, designations for consultants/new positions and retired annuitants are also being proposed to be added. Disclosure is based on a position’s level of decision making and disclosure categories include income, gifts, investments, real property, income, etc.
The City Attorney has reviewed and approved the attached amendments to the Conflict of Interest Code.
ATTACHMENT
City Council Policy No. 24 – Conflict of Interest Code redline By: Anna M. Brown, City Clerk
Agenda Report Page 2
CITY OF PIEDMONT
Policy & Procedure
Policy No. 24
Section: City Council
SUBJECT: Conflict of Interest Code
Policy
It is the intent of the City Council of the City of Piedmont to comply with the requirements of the Political Reform Act of 1974, G.C. Sec. 81000 et seq. and 87300 et seq. requiring certain city employees to file a Statement of Economic Interests form. This policy is adopted to further the City’s compliance with the disclosure requirements of the Political Reform Act.
1. The terms of 2 Cal. Adm. Code Section 18730 and any amendments to it duly adopted by the Fair Political Practices Commission are hereby incorporated by reference and included as part of the Conflict of Interest Code of the City of Piedmont.
2. Persons holding positions designated in Appendix A and persons required to do so by statute shall file Statement of Economic Interests forms with the City of Piedmont on Fair Political Practices Commission forms, in conformance with the individual disclosure categories and State guidelines as identified in Appendix B. Persons holding designated positions and persons required by statute to file a Statement of Economic Interests form shall also report interests for any other related agency positions. The City Clerk will retain custody of the statements and make the statements available for public inspection and reproduction.
3. All designated employees shall be required to file Assuming Office Statements, Annual Statements and Leaving Office Statements within the timeframes specified in state law.
4. Statement of Economic Interests forms will be filed in the City Clerk’s office in the manner and at such time as required by the State of California Fair Political Practices Commission.
5. The City Clerk’s office shall be responsible for providing appropriate filing forms and notification of filing deadlines and shall maintain a permanent record of all reports received shall maintain the records in accordance with the records retention schedule approved by City Council Resolution.
Date: July 16, 1980
March 21, 1986 (Revised)
November 17, 2014 (Revised by Resolution 136-14)
October 1, 2018 (Revised by Resolution 70-18)
August 17, 2026 (Revised by Resolution XX-26)
Attachment Agenda Report Page 3
City Council Policy #24 – Conflict of Interest Code
2 Appendix A
Designated Positions
Designated employees for the City of Piedmont shall be the following:
Designated Employee Disclosure Categories
City Council Files under G.C. § 87200
City Administrator Files under G.C. § 87200
City Attorney Files under G.C. § 87200
Finance Director Files under G.C. § 87200
Planning Commission Files under G.C. § 87200
Police & Fire Pension Board Files under G.C. § 87200
Administrative Analyst 1,2,3,4
Building Inspector 1,2,3,4
Building Official 1,2,3,4
Asst. City Administrator / City Clerk 1,2,3,4
City Engineer 1,2,3,4
Communications Officer 1,2,3,4
Deputy City Attorney (General Legal Matters) 1,2,3,4
Director of Public Works 1,2,3,4
Fire Chief 1,2,3,4
Fire Captain 1,2,3,4
Human Resources Manager 1,2,3,4
Maintenance Supervisor 1,2,3,4
Parks & Project Manager 1,2,3,4
Planning Director 1,2,3,4
Police Chief 1,2,3,4
Police Captain 1,2,3,4
Police Sergeant 1,2,3,4
Police Support Services Commander 1,2,3,4
Recreation Director 1,2,3,4
Recreation Supervisor 1,2,3,4
Senior Planner 1,2,3,4
Sustainability Program Manager 1,2,3,4
Consultants/New Positions11,2,3,4
Retired Annuitants21,2,3,4
____________________
1. Consultants/New Positions are included in the list of designated positions and shall disclose pursuant to the broadest disclosure category in the code, subject to the following limitation: The City Administrator may determine in writing that a particular consultant or new position, although a "designated position," is hired to perform a range of duties that is limited in scope and thus is not required to fully comply with the disclosure requirements in this section. Such written determination shall include a description of the consultant's or Attachment Agenda Report Page 4
City Council Policy #24 – Conflict of Interest Code
3 new position’s duties and, based upon that description, a statement of the extent of disclosure requirements. The City Administrator’s or his/her designee’s determination is a public record and shall be retained for public inspection in the same manner and location as this conflict of interest code. (Gov. Code Section 81008.)
2. Retired annuitants may be included in the list of designated employees when the City Administrator determines that they are performing work that is the functional equivalent of a designated position. If such a determination is made, then disclosure shall be pursuant to the disclosure category required by this Code for the comparable designated staff position.
Attachment Agenda Report Page 5
City Council Policy #24 – Conflict of Interest Code
4 Appendix B
Disclosure Categories
The City Conflict of Interest Code hereby includes the following disclosure categories to achieve consistency with State Law and reflect the required disclosure categories of this Conflict of Interest Code.
Category 1:
Must Report: All investments, interest in real property, income, including gifts, loans, and travel payments, and any business entity in which the person is a director, officer, partner, trustee, employee, or holds any position of management. Financial interests are reportable only if located within or subject to the jurisdiction of the City or if the business entity is doing business or planning to do business in the jurisdiction or has done business within the jurisdiction at any time during the two years prior to filing the statement.
Category 2:
Must Report:
A. Investments in any business entity located outside the jurisdiction of the City of Piedmont if the business entity does business with the City on a regular basis and if the designated person occupies a position that has any discretion in recommending with whom such business shall be placed or conducted.
B. Each source of income that has contracted or in the foreseeable future may contract with the City to provide services, supplies, materials, machinery, or equipment to the City.
C. His or her status as a director, officer, partner, trustee, employee or any position of management in any business entity defined in subsection A above.
Category 3:
Must Report:
A. Investments in any business entity which within the last two years, has contracted or in the foreseeable future may contract with the City to provide services, supplies, materials, machinery, or equipment to the City.
B. Income including gifts, loans, and travel payments from any source which within the last two years, has contracted or in the foreseeable future may contract with the City to provide services, supplies, materials, machinery, or equipment to the City.
C. His or her status as a director, officer, partner, trustee, employee or any position of management in any business entity which within the last two years has contracted or in the foreseeable future may contract with the City to provide services, supplies, materials, machinery, or equipment to the City.
Attachment Agenda Report Page 6
City Council Policy #24 – Conflict of Interest Code
5 Category 4:
Must Report: Income including gifts, loans, and travel payments received by a designated employee from any labor organization or employee organization which represents employees employed by the City and which organization negotiates with the City as a representative of the employees of the City regarding wages, compensation, hours of work, working conditions, or other terms and conditions of employment.
Attachment Agenda Report Page 7