CITY OF SAN MATEO
CITY OF SAN MATEO
Agenda Report
City Hall
330 W. 20th Avenue
San Mateo CA 94403
www.cityofsanmateo.org
Agenda Number: 4 Section Name: CONSENT CALENDAR Account Number: 10-1511 File ID: 26-11590 TO: City Council
FROM: Alex Khojikian, City Manager
PREPARED BY: City Clerk's Office
MEETING DATE: September 08, 2026
SUBJECT:
City of San Mateo Conflict of Interest Code – 2026 Biennial Update RECOMMENDATION:
Adopt a Resolution to update the City of San Mateo’s conflict of interest code to account for the addition, deletion, and modification of positions listed as “designated employees" and to make other revisions.
BACKGROUND:
The Political Reform Act of 1974 requires, among other things, that local government agencies adopt and maintain a conflict of interest code. Like most cities, the City of San Mateo many years ago adopted a “model” conflict of interest code prepared by the Fair Political Practices Commission. The model code establishes the substantive requirements relating to the disclosure of financial interests and the requirements for disqualification from participation in decisions in which City employees and other officials might have a private, financial interest. Cities adopting the model code need only adopt a list designating those employees subject to the conflict of interest code’s financial interest disclosure requirements and specifying the scope of interests those designated employees must disclose.
In addition to imposing the requirement to adopt a local code including the listing of designated employees, the Political Reform Act requires cities to review their codes on at least a biennial basis (to be conducted each even numbered year) to ensure that the code reflects the organization’s current staffing.
A review of the City of San Mateo’s conflict of interest code revealed that revisions were required due to the addition of positions not previously listed, and the deletion of positions that have been eliminated or which do not meet the decision- making threshold to necessitate the need to file. The exhibit attached to the resolution included with this report reflects these changes.
The list of designated employees and officials does not include Council Members, Planning Commissioners, the City Manager, the City Attorney, and the Finance Director. These positions are not included in the local code because they are already required by state law (Government Code Section 87200) to disclose their financial interests.
Effective January 1, 2026, the Senior Management Analyst position within the Finance Department was also added as a designated position under SB 852, which amended the Political Reform Act to clarify that individuals who manage or participate in the management of public investments on behalf of a local agency are considered "public officials" for purposes of financial disclosure.
Additionally, the conflict of interest code has been revised to include members of the City of San Mateo Joint Powers Financing Authority, or “Financing JPA.” The Financing JPA was formed in 1993, and its governing board is comprised of members of the San Mateo City Council. The Financing JPA adopted bylaws that require the adoption of a conflict of
CITY OF SAN MATEO
interest code as well as a resolution that incorporates the City’s conflict of interest code by reference. However, the code was never amended to include members of the Financing JPA governing board. That oversight has now been corrected in this year’s version.
BUDGET IMPACT:
There is no budgetary impact associated with this item.
ENVIRONMENTAL DETERMINATION:
This Resolution is not a project subject to CEQA, because it is an organizational or administrative activity that will not result in direct or indirect physical changes in the environment. (CEQA Guidelines Section 15378(b)(5).)
STRATEGIC PLAN ALIGNMENT
This staff report supports the Organizational Health and Good Governance initiative.
NOTICE PROVIDED
All meeting noticing requirements were met.
ATTACHMENTS
Att 1 – Proposed Resolution
Att 2 – Conflict of Interest Code Track Changes, Post 2024 Biennial Review to Current 2026 Biennial Review
STAFF CONTACT
Erin Fellers, Management Analyst I
[email protected]
(650) 522-7066