Updated: September 1, 2026
Exhibit A
City of San Marino
CONFLICT OF INTEREST CODE
Updated: September 1, 2026
The Political Reform Act (Government Code Section 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 (2 California Code of Regulations Section 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, the standard code 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. The regulation and the attached Appendix designating positions, and establishing disclosure requirements, shall constitute the conflict-of-interest code of the City of San Marino.
Individuals holding designated positions shall file their statements of economic interest with the Office of the City Clerk which will retain the statements and make the statements available for public inspection and reproduction. (Government Code Section 81008) Updated: September 1, 2026
Updated: September 1, 2026
APPENDIX A
SCHEDULE OF DESIGNATED EMPLOYEES
DESIGNATED EMPLOYEES DISCLOSURE CATEGORIES
(See Appendix B for Description)
City Manager’s Office
Assistant to the City Manager 1
City Clerk 2
Finance
Finance Director 2
Accounting Manager/Controller 2
Human Resources
Human Resources Director 2
Human Resources Analyst 2
Community Development Department
Community Development Director 2,3,4
Senior Planner 3,4
Assistant Planner 3,4
Associate Planner 3,4
Plan Checker 3,4
Building Inspector I / II 3,4
Permit Technician I / II 3,4
Code Enforcement Manager 3,4
Management Analyst 3,4
Parks and Public Works Department
Parks & Public Works Director / City Engineer 2,3,4
Public Works Manager 2,3,4
Street Foreman 2
Parks Foreman 2
Shop Foreman 2
Urban Forester 2
Management Analyst 2
Police Department
Police Chief 1
Commander 1
Administrative Sergeant 2,3
Management Analyst 2
Administrative Assistant 2
Updated: September 1, 2026
DESIGNATED EMPLOYEES DISCLOSURE CATEGORIES
Fire Department
Fire Chief 1
Division Chief 1
Management Analyst 2
Community Services Department
Community Services Director 2,3,4
Library Manager 2
Librarian I / II 2
Recreation Manager 2
Recreation Supervisor 2
Management Analyst 2
Advisory Bodies
Design Review Committee Members 3,4
Consultants as defined in Title 2 California Code of Regulations Section 18700 (a)(2) (see Appendix C)
Note: The Mayor, City Council, City Manager, City Attorney, City Treasurer, and Planning Commissioners are not covered by this code because they must file under Government Code Section 87200.
Updated: September 1, 2026
Updated: September 1, 2026
APPENDIX B
DISCLOSURE CATEGORIES
DISCLOSURE CATEGORY 1 (full disclosure – broad and indefinable duties) Designated employees in this category shall disclose all reportable interests in real property.
Designated employees in this category shall also disclose all reportable investments, business positions, and income.
DISCLOSURE CATEGORY 2 (disclosure relating to services and supplies associated with job assignment only)
Designated employees in this category shall disclose all reportable investments and business positions in business entities and sources of income of the type which:
Provide services, supplies, materials, machinery or equipment of the type utilized by the Designated Employee’s Department.
DISCLOSURE CATEGORY 3 (disclosure for those approving, issuing, or regulating permits or licenses)
Designated employees in this category shall disclose all reportable investments and business positions in business entities and sources of income of the type which:
Are subject to the regulatory, permit, or licensing authority of the Designated Employee’s Department.
DISCLOSURE CATEGORY 4 (disclosure for those who make decisions affecting real property interests)
Designated employees in this category shall disclose all reportable interests in real property.
Designated employees in this category shall also disclose all reportable investments and business positions in business entities and sources of income of the type which:
Engage in land development, construction, or the acquisition or sale of real property in the jurisdiction of the City.
Updated: September 1, 2026
Updated: September 1, 2026
APPENDIX C
CONSULTANTS
With respect to Consultants performing work for the City of San Marino, the City Manager (or their designee) may determine in writing that a particular consultant, 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 duties and, based upon that description, a statement of the extent of disclosure requirements under this Conflict of Interest Code. The City Manager’s (or their 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. (Government Code Section 81008.) Commission Regulation 18700 states that “a public official at any level of state or local government has a prohibited conflict of interest and may not make, participate in making, or in any way use or attempt to use his or her official position to influence a governmental decisions when he or she knows or has reason to know he or she has a disqualifying financial interest.” The Regulation further defines "Public Official" as “every member, officer, employee, or consultant of a state or local government agency,” and “Governmental decision” as “any action taken by a government agency that has a financial effect on any person other than the governmental agency making the decision.”