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LAW OFFICES OF
BEST BEST & KRIEGER LLP
BBK – October 2024
CONFLICT OF INTEREST CODE
OF THE
CITY OF SAN BERNARDINO
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LAW OFFICES OF
BEST BEST & KRIEGER LLP
CONFLICT OF INTEREST CODE
OF THE
CITY OF SAN BERNARDINO
(Amended November 6, 2024)
The Political Reform Act (Gov. Code § 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, (tit. 2 Cal. Code of Regs, § 18730), that contains the terms of a standard conflict of interest code which can be incorporated by reference in an agency’s code. After public notice and hearing, Regulation 18730 may be amended by the Fair Political Practices Commission to conform to amendments in the Political Reform Act. Therefore, the terms of 2 California Code of Regulations section 18730 and any amendments to it duly adopted by the Fair Political Practices Commission are hereby incorporated by reference. This incorporation page, Regulation 18730 and the attached Appendix designating positions and establishing disclosure categories, shall constitute the Conflict of Interest Code of the City of San Bernardino (“City").
The Mayor, Members of the City Council and Planning Commission, the City Manager, the City Attorney and the City Treasurer, shall electronically file their annual statements of economic interests directly with the Fair Political Practices Commission. All other officials and designated positions required to submit a statement of economic interests shall file their statements with the City Clerk as the City’s Filing Officer. All officials and designated positions required to submit a statement of economic Interests shall file their statements with the City Clerk as the Town’s Filing Officer. The City Clerk shall make and retain a copy of all statements filed by the Mayor, members of the City Council, the City Manager, the City Attorney and the City Treasurer, and forward the originals of these statements to the Fair Political Practices Commission. The City Clerk shall retain the original statements filed by all other officials and designated positions and will make all retained statements available for public inspection and reproduction during regular business hours. (Gov. Code § 81008)
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LAW OFFICES OF
BEST BEST & KRIEGER LLP
App. A-1BBK – October 2024
APPENDIX
CONFLICT OF INTEREST CODE
OF THE
CITY OF SAN BERNARDINO
(Amended November 6, 2024)
PART “A”
The Mayor, Members of the City Council and Planning Commission, the City Manager, the City Attorney, the City Treasurer, and all Other City Officials who manage public investments as defined by 2 Cal. Code of Regs. § 18700.3(b), are NOT subject to the City’s Code but must file disclosure statements under Government Code Section 87200 et seq. [Regs. § 18730(b)(3)]
OFFICIALS WHO MANAGE PUBLIC INVESTMENTS
It has been determined that the positions listed below are Other City Officials who manage public investments. 1 These positions are listed here for informational purposes only.
Investment Consultants
1 Individuals holding one of the above-listed positions may contact the Fair Political Practices Commission for assistance or written advice regarding their filing obligations if they believe that their position has been categorized incorrectly. The Fair Political Practices Commission makes the final determination whether a position is covered by § 87200. 55600.00100\42657175.3
LAW OFFICES OF
BEST BEST & KRIEGER LLP
App. A-2BBK – October 2024
DESIGNATED POSITIONS
GOVERNED BY THE CONFLICT OF INTEREST CODE
Accountant III 5
Accounting Division Manager 5
Administrative Analyst (ALL) 5
Administrative Division Manager 5
Administrative Services Supervisor 5
Administrative Supervisor and Executive Assistant to the City Manager 5 Animal Services Manager 5
Animal Services Supervisor 5
Aquatics Supervisor 5
Assistant Building Official 3, 5, 6
Assistant Buyer 5
Assistant Chief of Police 5
Assistant City Manager 1, 2
Assistant Planner 3, 5, 6
Assistant to the City Manager 5
Assistant to the Mayor 5
Assistant to the Mayor III 5
Associate Planner 3, 5, 6
Auditor (ALL) 5
Budget Division Manager 4
Budget Officer 4
Building Inspector (ALL) 3, 5, 6
Building Maintenance Division Manager 3, 5
DESIGNATED POSITIONS’
TITLE OR FUNCTION
DISCLOSURE CATEGORIES
ASSIGNED
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LAW OFFICES OF
BEST BEST & KRIEGER LLP
App. A-3BBK – October 2024
DESIGNATED POSITIONS’
TITLE OR FUNCTION
DISCLOSURE CATEGORIES
ASSIGNED
Building Official 3, 5, 6
Business Registration Manager 5, 6
Buyer 4
Capital Improvement Project Manager 2, 3, 5, 7
CATV Broadcast Engineering Coordinator 5
Chief Assistant City Attorney 1, 2
Chief Building Official and Safety Division Manager 3, 5, 6 Chief Deputy City Clerk 1, 2
Chief of Police 5
Chief of Staff 5
City Clerk 5
City Engineer 1, 2
City Planner 1, 2
Civil Engineering Division Manager 1, 2
Code Enforcement Division Manager 5
Code Enforcement Officer (ALL) 5
Community Development Block Grant (CBDG) Coordinator 5, 7 Community Intervention Program Manager 5, 7
Community Policing Specialist 5
Community Recreation Center Supervisor 5
Community Recreation Manager 5
Community Recreation Program Coordinator 5
Community Recreation Program Supervisor (Soccer) 5
Community Relations Supervisor Assistant to the City Manager 5 Community Services Center Supervisor 5
Community Services Officer Supervisor 5
Community Services Program Coordinator 5
Construction Inspector (ALL) 3, 6
Construction/Survey Manager 2, 5
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LAW OFFICES OF
BEST BEST & KRIEGER LLP
App. A-4BBK – October 2024
DESIGNATED POSITIONS’
TITLE OR FUNCTION
DISCLOSURE CATEGORIES
ASSIGNED
Council Administrative Supervisor 5
Custodial Supervisor 5
Deputy City Attorney (ALL) 1, 2
Deputy City Clerk I 5
Deputy City Clerk II 5
Deputy City Manager 1, 2
Deputy Director City Engineer 1, 2
Deputy Director of Animal Services 5
Deputy Director of Economic Development 1, 2
Deputy Director of Finance and Management Services 4
Deputy Director of Housing and Homelessness 5, 7
Deputy Director of Human Resources and Risk Management 5 Deputy Director of Information Technology 5
Deputy Director of Operations 5
Deputy Director of Parks, Recreation & Community 1, 2
Deputy Director of Public Works-City Engineer 1, 2
Deputy Engineer 1, 2
Deputy General Manager 1, 2
Deputy Library Director 5
Development Services Technician 5
Director of Animal Services 5
Director of Community & Economic Development 1, 2
Director of Community Development and Housing 1, 2
Director of Economic Development 1, 2
Director of Finance 4
Director of Finance and Management Services 4
Director of Human Resources 5
Director of IT 5
Director of Parks, Recreation & Community Services 1, 2 55600.00100\42657175.3
LAW OFFICES OF
BEST BEST & KRIEGER LLP
App. A-5BBK – October 2024
DESIGNATED POSITIONS’
TITLE OR FUNCTION
DISCLOSURE CATEGORIES
ASSIGNED
Director of Public Works 1, 2
Director of Public Works, Operations and Maintenance 1, 2 Director, Water Reclamation 3, 5, 6
Director, Water Utility 3, 5, 6
Disadvantaged Business Enterprise (DBE) Specialist 5
Diversity, Equity, & Inclusion Officer 5
Economic Development Division Manager 1, 2
Economic Development Manager 5
Economic Development Project Manager 1, 2
Electrical, Instrumentation, and SCADA Superintendent 5 Emergency Operations Manager 5
Engineering Assistant (ALL) 2, 3, 6
Engineering Associate 2, 5
Engineering Manager 2, 3, 5
Engineering Project Manager 2, 3, 5
Engineering Technician 5, 6
Environmental Programs Coordinator 2, 5
Environmental Control Supervisor 2, 5
Equipment Maintenance Manager 5
Equipment Maintenance Supervisor 5
Executive Staff Assistant to the City Council 5
Facilities & Fleet Maintenance Division Manager 5
Facilities Maintenance Supervisor 5
Financial Analyst 5
Fleet Parts Storekeeper 5
Fleet/Warehouse Supervisor 4
Forensic Supervisor 5
Forestry Supervisor 5
General Manager – Water 1, 2
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LAW OFFICES OF
BEST BEST & KRIEGER LLP
App. A-6BBK – October 2024
DESIGNATED POSITIONS’
TITLE OR FUNCTION
DISCLOSURE CATEGORIES
ASSIGNED
GIS Administrator 5
Grant Analyst 5, 7
Grant Division Manager 5, 7
Grant Manager 5, 7
Grants Assistant 5, 7
Homeless Services Coordinator 5, 7
Homeless Solutions Manager 5, 7
Housing Compliance Officer 5
Housing Division Manager 5, 7
Housing Manager 1, 2
HR Analyst (ALL) 5
Human Resources Division Manager 5
Human Resources Generalist 5
HVAC Supervisor 5
IEMG Broadcast Engineering Coordinator 5
Information Technology Manager 5
Information Technology Manager 5
Information Technology Operations Supervisor 5
IT Operations Supervisor 5
Land Development Engineer 2, 3 ,5
Landscape and Irrigation Inspector (ALL) 3, 5
Landscape Inspector (ALL) 3, 5
Landscape Maintenance District Supervisor 3, 5
Lead Building Inspector 3, 5
Lead Code Enforcement Officer 5
Legislative & Governmental Affairs Manager 5
Library Administrative Supervisor 5
Library Circulation Supervisor 5
Library Director 5
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LAW OFFICES OF
BEST BEST & KRIEGER LLP
App. A-7BBK – October 2024
DESIGNATED POSITIONS’
TITLE OR FUNCTION
DISCLOSURE CATEGORIES
ASSIGNED
Library IT Manager 5
Library Network Administrator 5
Library Program Coordinator 5
Maintenance Supervisor 5
Management Analyst II 5, 7
Manager of Communications 5
Marketing and Public Relations Specialist 5
Neighborhood & Customer Service Manager 5
Network Systems Administrator 5
NPDES Inspector II 3, 5, 6
NPDES Manager 3, 5, 6
Operations & Maintenance Division Manager 2, 5
Parks and Landscape Maintenance Supervisor 5
Parks and Landscape Supervisor 5
Parks Construction Lead Worker 5
Parks Maintenance Division Manager 5
Parks Ranger Supervisor 5
Parks Superintendent 3, 5
Permit Services Supervisor 5, 6
Planning Division Manager 2, 3, 5, 6
Plans Examiner (ALL) 2, 3, 5, 6
Police Captain 5
Police Dispatch Manager 5
Police Dispatch Supervisor 5
Police Lieutenant 5
Principal Civil Engineer 2, 3, 5, 6
Principal Engineer, Public Works Dept. 2, 5
Principal Engineer, Water Dept. 2, 3, 5
Principal Planner 2, 3, 5, 6
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LAW OFFICES OF
BEST BEST & KRIEGER LLP
App. A-8BBK – October 2024
DESIGNATED POSITIONS’
TITLE OR FUNCTION
DISCLOSURE CATEGORIES
ASSIGNED
Project Manager 2, 3, 5
Project Manager of Community Development Programs 5
Project Manager of Housing Programs 3, 5
Public Information Officer 5
Public Safety and Training Officer 5
Public Safety IT Manager 5
Public Works Inspector III 3, 5
Purchasing Division Manager 5
Rangemaster 5
Real Property Manager 1, 2
Real Property Specialist 1, 2
Recreation Therapist 5
Retired & Senior Volunteer Program Manager 5
Risk Division Manager 5, 8
Senior Civil Engineer 2, 3, 5, 6
Senior Civil Engineer/Division Manager 2, 3, 5, 6
Senior Code Enforcement Officer 5
Senior Companion Program Manager 5
Senior GIS Analyst 5
Senior HR/Risk Analyst 5
Senior Human Resources Technician 5
Senior IT Analyst 5
Senior Librarian 5
Senior Management Analyst 5
Senior Network Administrator 5
Senior Network Specialist 5
Senior Network System Administrator 5
Senior Nutrition Food Services Supervisor 5
Senior Planner 2, 3, 5
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LAW OFFICES OF
BEST BEST & KRIEGER LLP
App. A-9BBK – October 2024
DESIGNATED POSITIONS’
TITLE OR FUNCTION
DISCLOSURE CATEGORIES
ASSIGNED
Senior Plans Examiner 2, 3, 5, 6
Station Manager 5
Street Signal/Lighting Supervisor 5
Supervising Human Resources Analyst 5
Technology Librarian 5
Traffic Engineer 2, 3, 5
Traffic Engineering Associate 2, 3, 5
Traffic Operations Systems Analyst 2, 3, 5
Traffic Signal and Lighting Supervisor 3, 5
Treasury Manager 5
Treasury Supervisor 1, 2
Water Quality Control Officer 5
Water Reclamation Maintenance Superintendent 5
Water Reclamation Operations Superintendent 5
Water Utility Distribution Superintendent 5
Water Utility Operations Superintendent 5
DESIGNATED BOARDS/COMMITTEES/COMMISSIONS
Successor Agency to the Redevelopment Agency of the City of San Bernardino 1, 2
Board of Building Commissioners/ Building Appeals Board 1, 2 Personnel Commission 1, 2
Board of Library Trustees 1, 2
Board of Water Commissioners 1, 2
Consultants and New Positions2
2 Individuals serving as a consultant as defined in FPPC Reg. 18700.3(a) or in a new position must file under the broadest disclosure category set forth in this Code subject to the following limitation:
The City Manager may determine that, due to the range of duties or contractual obligations, it is more appropriate to designate a limited disclosure requirement. A clear explanation of the duties and a statement of the extent of the disclosure requirements must be in a written document. The City Manager’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. 55600.00100\42657175.3
LAW OFFICES OF
BEST BEST & KRIEGER LLP
App. B-1BBK – October 2024
PART “B"
DISCLOSURE CATEGORIES
The disclosure categories listed below identify the types of economic interests that the designated position must disclose for each disclosure category to which the designated is assigned. 3 “Investment” means financial interest in any business entity (including a consulting business or other independent contracting business) and are reportable if they are either located in, doing business in, planning to do business in, or have done business during the previous two years in the jurisdiction of the City.
Category 1: All investments and business positions and sources of income, including gifts loans and travel payments, that are located in, do business in, or own real property within the jurisdiction of the City.
Category 2: All interests in real property which is located in whole or in part within, or not more than two (2) miles outside, the boundaries of the City, including any leasehold, beneficial or ownership interest or option to acquire property.
Category 3: All investments and business positions in, business entities, and sources of income, including gifts, loans and travel payments, that are engaged in land development, construction or the acquisition or sale of real property within the jurisdiction of the City.
Category 4: All investments, business positions and income from business entities and sources of income, including gifts, loans and travel payments, that provide services, products, materials, machinery, vehicles or equipment of a type purchased or leased by the City.
Category 5: All investments, business positions and income, including gifts, loans and travel payments, that provide services, products, materials, machinery, vehicles or equipment of a type purchased or leased by the designated position’s department, unit or division.
Category 6: All investment and business positions in business entities and sources of income, including gifts, loans and travel payments, subject to the regulatory, permit, licensing authority of the designated employee’s department, unit or division.
Category 7: All investments and business positions in business entities, and sources of income, including gifts, loans and travel payments, or income from a nonprofit organization, if the source is of the type to receive grants or other monies from or through the City or its subdivisions.
3 This Conflict of Interest Code does not require the reporting of gifts from outside this agency’s jurisdiction if the source does not have some connection with or bearing upon the functions or duties of the position. (Reg. 18730.1) 55600.00100\42657175.3
LAW OFFICES OF
BEST BEST & KRIEGER LLP
App. B-2BBK – October 2024
Category 8: All investments and business positions in business entities, and sources of income, including gifts, loans, and travel payments, if such entities or sources have filed claims against the agency in the past 2 years, or have a claim pending before the agency.