CITY COUNCIL STAFF REPORT
Meeting Date: February 23, 2026
TO: THE HONORABLE MAYOR AND CITY COUNCILMEMBERS
TITLE: ADOPT RESOLUTION NO. ___-26 AMENDING THE CONFLICT OF INTEREST CODE AND RESCINDING RESOLUTION NO. 8-24
SYNOPSIS
State law requires all public agencies to adopt a Conflict of Interest Code to identify the positions required to file Statements of Economic Interests to disclose certain economic interests. Staff has completed the biennial review of the City’s adopted Conflict of Interest Code and determined that it needs to be amended in order to update the list of designated positions.
DISCUSSION
Background
The Political Reform Act (PRA – Government Code § 81000, et seq.) requires every government agency to review its Conflict of Interest Code biennially to determine if it is accurate, and if necessary, amend the code. The City of Pleasant Hill’s Conflict of Interest Code was most recently amended by Resolution No. 8-24 in February 2024, and designates the positions required to file a Statement of Economic Interests (Form 700) and the categories of interests that must be reported.
The Form 700 is a public document intended to alert public officials and members of the public to the types of financial interests that may create conflicts of interests.
The Fair Political Practices Commission (FPPC) is the body charged with, among other duties, adopting and amending regulations pertaining to the Political Reform Act. Section 18730 of Title 2, Division 6, of the California Code of Regulations provides the FPPC’s Provisions of Conflict of Interest Codes to which the City must adhere in order to comply with the PRA. The Conflict of Interest Code provided for the Council’s consideration meets the requirements of this section.
Analysis
The PRA requires that all conflict of interest codes include three components: the terms of the FPPC’s regulation, the designated positions, and the disclosure categories. The Conflict of Interest Code (Exhibit A to the proposed resolution) that is recommended for Council adoption, satisfies these elements as follows:
Terms: Given the complexity of the subject matter, the FPPC advises agencies to wholly incorporate FPPC Regulation 18730 by reference in order to ensure adherence to all of its provisions. The City has historically incorporated Regulation 18730 as Appendix A to its Conflict of Interest Code and the practice is continued as Appendix A of Exhibit A of the proposed resolution.
Designated Positions. In accordance with Regulation 18730, a conflict of interest code must specifically list the positions that make or participate in making decisions and thus are subject to the code. Although the positions listed in Government Code § 87200 (such as City Councilmembers and Planning Commissioners) are not required to be included, given that those positions are separately required by the Government Code to file Form 700, the City has historically included all of these positions within the Conflict of Interest Code; Appendix B of Exhibit A continues that tradition.
The proposed Conflict of Interest Code amendments as shown in Appendix B – Conflict of Interest Code Designated Positions:
Disclosure Categories: The FPPC states that “[a] primary purpose of the code is to require disclosure of those types of investments, interests in real property, sources of income and business positions that designated positions may affect in their decision-making.” Thus, it is necessary to identify the categories of information that each position subject to the code must disclose. These disclosure categories are included in Exhibit A as Appendix C as in previous years.
FISCAL IMPACT
None
PUBLIC CONTACT
Public Contact was made through posting of the City Council agenda on the City’s official notice bulletin board, at the Pleasant Hill Senior Center, and at the Pleasant Hill Police Department. The agenda and staff report are posted on the City’s web page.
RECOMMENDED CITY COUNCIL ACTION
Adopt the proposed resolution amending the City’s Conflict of Interest Code and rescinding Resolution 8-24.
ALTERNATIVES TO RECOMMENDED ACTION
1. The Council may choose not to adopt the resolution.
2. The Council may direct staff to make amendments to the resolution and/or the Conflict of Interest Code.
ATTACHMENT(S)
Proposed Resolution
Exhibit A – Conflict of Interest Code
Appendix A – Regulation 18730
Appendix B - Conflict of Interest Code Disclosure Categories Appendix C – Conflict of Interest Code Designated Position and Appendices – Redlined Appendix C – Conflict of Interest Code Designated Position and Appendices – Clean Prepared by: Lyone P. Conner, City Clerk
Approved by: Ethan Bindernagel, City Manager