Governance &
Ethics Committee
Consideration and Possible
Action on a Proposed New
Council Policy for Ticket
Distribution to City Officials
Maria Le, Assistant to the City Manager
Agenda Item No. 2 (#25-1543)
October 30, 2025
Overview
• Background
• Purpose
• Proposed Policy Guidelines & Procedures
• Recommendation
2 Background
• The City does not have an official ticket distribution policy, staff brings forth this proposed policy for
consideration.
• Preparation for 2026 events & Beyond:
Purpose is to establish formal procedures for the
acceptance and distribution of tickets or passes
provided to the City.
• Compliance with California Fair Political
Practices Commission (FPPC): Ensure reporting of
tickets received by public agencies.
3 Purpose
Establishes guidelines for the acceptance and
distribution of tickets or passes received by the City
for use by City officials, including Councilmembers,
other elected officials, and employees designated by
the City Manager, in compliance with FPPC
regulations.
4 Policies – Other Cities
5 • Los Angeles
• Mountain View
• Oakland
• San Diego
• San Jose
Types of Tickets or Passes
6 City Purchases
tickets or table
Complimentary
tickets to events,
concerts, festivals,
from partners
Tickets provided
thru City venues
Convention Center,
Levi’s Stadium
(excluding NFL games)
Admission for
recognition events
for residents,
businesses,
volunteers
Tickets received as
part of sponsorship
or partnership
agreements
Invitations to
regional
intergovernmental
functions
City-Related Public Purpose
7 • Attendance at Ceremonial occasions
• Promotion of cultural, educational, recreational &
community events
• Official events for foreign officials or dignitaries
• Promotion of Intergovernmental Relations
• Economic Development outreach or planning
• Recognition Events for community, businesses,
volunteers, students, etc.
• Redistribution to the public and City staff
8 General
Provisions
The use of City distributed Tickets is a privilege, not a right Tickets not accepted by a City official may be redistributed by the Ticket Administrator, with priority to City officials; family members
Recipients shall not sell, barter, exchange or transfer Tickets themselves for consideration
Any benefits not associated with the Tickets (e.g., food, drinks, souvenirs, VIP areas, parking) are not covered by this policy & may require Form 700 reporting Outside sources may not earmark Tickets to specific individuals This policy explicitly excludes tickets received from the San Francisco 49ers for NFL games. Any officials choosing to accept such tickets, shall comply with FPPC reporting Complimentary tickets to special events or to the 49ers Museum at Levi’s Stadium are permissible
Distribution & Administration
9 Ticket Administrator: City Manager or their designee shall manage the receipt and distribution of all tickets subject to this policy Ensures tickets distributed serve a City-related public purpose FPPC: Ensures tickets distributed are disclosed on FPPC Form 802, submitted to City Clerk and posted to City website
Recommendation
• Approve for presentation to the City Council the
proposed Council Policy for Ticket Distribution to
City Officials, in the form presented, with such
modifications as the Committee may authorize or
direct.
10 Governance &
Ethics Committee
Consideration and Possible
Action on a Proposed New
Council Policy for Ticket
Distribution to City Officials
Maria Le, Assistant to the City Manager
Agenda Item No. 2 (#25-1543)
October 30, 2025
Governance &
Ethics Committee
Discussion on Council Policy
050 (Gifts to Elected and
Appointed Officials)
Glen Googins, City Attorney
Agenda Item No. 3 (#25-1576)
October 30, 2025
Overview
• Seeking initial feedback
• Background of policy
• Key Questions/Factors to Consider
• Discussion and Direction
2 Background
• Council Policy Council Policy 050 [Gifts to Elected and Appointed Officials] (“Gift Policy”) was identified for review and possible revision as part of Committee workplan.
• Most recent Gift Policy update in 2018:
1. Focused policy on direct donations to officials (as opposed to the City itself);
2. Added a list of factors to be considered by City officials in deciding whether to accept gifts;
3. Prohibited gifts from lobbyists; and
4. Required that any gift accepted of less than $50 be disclosed at a public meeting.
3 Process/Results Disjointed
• The original proposal was for updates to a policy that covered donations to the City and gifts to individual City officials; Council directed that two separate policies be created.
• The policy for donations to the City was tabled to be taken up separately (Policy 051 [Donations to City]); the updated to the Gift policy was brought back. • At that meeting, the “redline” of changes presented to Council was not accurate • A number of changes proposed that would have been helpful (e.g., provisions that indicated State law references would be updated as State law changed), were ultimately excluded from the final adopted version • Results a little confusing; a combination of references to state law and local rules where it was not clear which was which.
4 Discussion Question #1
5 Does the City need its own local Gift Policy
for elected and appointed officials, or should
it instead refer to applicable state laws and
other local policies?
Factors to Consider
6 • Most terms of the City’s existing Gift policy are restatements of applicable state law.
• These rules are detailed and complex and hard to summarize • There are good summaries out there: see the FPPC Fact Sheet attached to your RTC, or your AB 1234 Training Materials.
• Approaches vary among other jurisdictions, ranging from with mere referral to State laws, attempts to summarize the State law and/or the addition of more stringent local rules
• There are other existing City rules that apply (e.g.,City Code of Ethics & Values) • Alignment of rules for elected officials with those applicable to employees (See CMD 67)
• Public expectations and perception.
Other Jurisdictions
7 • Palo Alto. No specific local rules. Defers to state law. • Sunnyvale. Hybrid. Formal gift policy largely a restatement of State law. Code of Ethics and Conduct provides statement that elected officials should not take advantage of their positions to access benefits not available to the public and should refrain from accepting gifts that would compromise or appear to compromise their judgement.
• San Jose. Hybrid. No gifts or consideration of duties performed in “regular course;” of their duties; no gifts, gratuities, or favors of any kind which might be perceived or interpreted as an attempt to influence their actions with respect to City business. “Gift” defined by state law. No gifts from “Restricted Sources” (within 2 years of business with the source), except gifts less than $50 allowed.
Standard exceptions.
City’s Existing Policies
8 • City of Santa Clara Cod of Ethics and Values:
--All elected and appointed officials required to “subscribe to this Code.”
--Includes eight “core values”
--One of these is “ I will be ethical”
--One relevant example of how this looks “in practice”
“I will make impartial decisions, free of bribes, unlawful gifts, narrow political interests, and financial or other personal interests that impair my independence of judgement or action.”
• Existing CMD 67 imposes very strict limits on City employees.
Discussion Question #2
9 If the City retains its own Gift Policy,
how should it be modified?
Discussion Question #2
10 At a minimum:
1. Should clarify if the policy applies to the City Manager and the City Attorney
2. Should clarify if state law references are intended to change with state law (e.g., annual gift limits); should also consider giving City staff the authority to update the policy as needed to reflect changes in state law.
3. Clean up/modify ambiguous/duplicative language
4. Consider modifying current public meeting disclosure requirement for gifts below $50.
5. CMO to consider changes to CMD 67 to align
Recommendation
• Provide input to staff on the existing Gift Policy
and direct staff to return with specific proposed
changes consistent with this direction for
Committee review and consideration
11 Governance &
Ethics Committee
Discussion on Council Policy
050 (Gifts to Elected and
Appointed Officials)
Glen Googins, City Attorney
Agenda Item No. 3 (#25-1576)
October 30, 2025