Cities Index.
Conflict of Interest Code List Updates-Redlines

Sunnyvale City Council
March 10, 2026

Document
Conflict of Interest Code List Updates-Redlines
Meeting
March 10, 2026
Body
Sunnyvale City Council
Pages
6
Original file
1.0 MB
Text extracted from the city's file for reading and search. Open the original on legistar.granicus.com. That file is the official record.

1 CITY OF SUNNYVALE – CONFLICT OF INTEREST CODE

DESIGNATED CITY POSITIONS REQUIRED TO FILE

Position Disclosure Category
Accountant 1
Accounting Division Manager 1
Administrative Analyst 1
Administrative Librarian 1
Administrative Services Manager 1
Affordable Housing Manager 1
Assistant City Attorney 1
Assistant City Engineer 1
Assistant City Manager 1
Assistant Director of Community Development 1
Assistant Director of Environmental Services 1
Assistant Director of Finance 1
Assistant Director of Public Works/City Engineer 1
Assistant to the City Manager 1
Assistant Planner 1
Associate Planner 1
Budget Analyst I/II 1
Budget Division Manager 1
Building Inspector I/II 1
Business Operations Manager 2
Business Systems Analyst 1
Business Systems Analyst - Confidential 1
Buyer I/II 1
Chief Building Official 1
Chief Information Officer 1
Chief Public Information Officer 1
City Clerk 1
City Property Administrator 1
Civil Engineer DPW 1
Civil Engineer ESD 1
Civilian Assistant Fire Marshal 1
Civilian Fire Marshal 1
Community Resources Manager 1
Deputy Chief Public Safety 1
Deputy City Attorney 1
Deputy City Clerk 1
Deputy City Manager 1
Deputy Director of DPW - Parks, Golf, and Urban Landscape 1 Deputy Director of DPW - Public Works Operations 1
Deputy Director of Environmental Services - Wastewater Treatment 1 Deputy Director of ESD - Water Distribution/Sewer Collection 1 Deputy Director of LRS - Library Services 1
Deputy Director of LRS - Recreation Services 1
Deputy Public Information Officer 1
Attachment 2

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2 Director of Community Development 1
Director of Environmental Services 1
Director of Human Resources 1
Director of Library and Recreation Services 1
Director of NOVA Workforce Services 1
Director of Public Safety 1
Director of Public Works 1
Economic Development Manager 1
Economic Development Specialist 1
Employment Training Manager 1
Engineering Manager 1
Environmental Compliance Inspector 3
Environmental Engineering Coordinator 2
Environmental Programs Manager 1
Equity, Access, and Inclusion Manager 1
Finance Manager 1
Fire Protection Engineer I/II 3
Fire Protection Inspector 3
Fleet Manager 2
Golf Operations Manager 2
Hazardous Materials Inspector 3
Homeless Human Services Manager 1
Housing Officer 1
Housing Programs Analyst 1
Housing Programs Technician 1
Housing Specialist I/II 1
Human Resources Analyst 1
Human Resources Manager 1
Information Technology Coordinator 1
Information Technology Manager 1
Laboratory/Pretreatment Manager 1
Library Circulation Manager 1
Library Services Manager 1
Management Analyst 1
Neighborhood Preservation Manager 1
Operations Manager: Facilities 3
Parks Manager 2
Payroll Supervisor 1
Permit Center Coordinator 1
Permit Center Manager 1
Permit Technician 1
Plan Check Engineer 1
Plan Checker I/II 1
Planning Officer 1
Principal Accountant 1
Principal Applications Analyst/Project Manager 1
Principal Assistant City Attorney 1
Principal Buyer 1
Principal Client Support Specialist 1
Attachment 2

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3 Principal Human Resources Analyst 1
Principal Network & Systems Engineer 1
Principal Payroll Analyst 1
Principal Planner 1
Principal Storekeeper 1
Principal Transportation Engineer/Planner 1
Public Safety Captain 1
Public Safety Communications Manager 1
Public Safety Media and Engagement Manager 1
Public Safety Records Manager 1
Public Works Construction Inspector 3
Public Works Supervisor 2
Purchasing Officer 1
Recreation Services Manager 1
Regulatory Programs Division Manager 1
Risk Manager 1
Senior Accountant 1
Senior Assistant City Attorney 1
Senior Building Inspector 1
Senior Buyer 1
Senior Construction Inspector/Coordinator 1
Senior Engineer 1
Senior Engineer ESD 1
Senior Environmental Compliance Inspector 1
Senior Environmental Engineer 1
Senior Hazardous Materials Inspector 1
Senior Housing Rehabilitation Specialist 1
Senior Human Resources Analyst 1
Senior Management Analyst 1
Senior Manager of Workforce DevelopmentNo 1
Senior Plan Check Engineer 1
Senior Planner 1
Senior Traffic Engineer 1
Senior Transportation Engineer 1
Senior Transportation Planner 2
Solid Waste Contract Administrator 2
Solid Waste Programs Division Manager 1
Storekeeper I/II 1
Storekeeper/Buyer 1
Street Operations Manager 1
Superintendent of Facilities Maintenance 1
Superintendent of Libraries 1
Superintendent of Parks and Golf 1
Superintendent of Public Works Operations 1
Superintendent of Recreation Services 1
Supervising Librarian 1
Transportation and Traffic Manager 1
Urban Landscape Manager 1
Utility Billing Division Manager 1
Commented [A1]: Updated position title: Workforce
Development Manager (Grant Funded)
Commented [A2]: Superintendent positions retitled as Deputy Director positions.

Commented [A3]: Updated position title: Library Services Manager
Attachment 2

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4 Wastewater Operations Manager 1
Water and Sewer Systems Division Manager 1
Water Operations Manager 1
Wastewater Treatment Facilities and Water Pollution Control Maintenance 1 Wastewater Treatment Plant Water Pollution Control Operations Manager 1 Water Pollution Control Plant Division Manager 1
Workforce Development Manager (Grant Funded) 1
Youth and Family Resources Manager 1

Newly created positions between conflict code amendments As applicable* Consultants As applicable**
Retired Annuitants As applicable***
Casual Employees performing work similar to a designated position As applicable*** Designated appointees:

Member, Arts Commission 1
Member, Heritage Preservation Commission 1
Member, Housing and Human Services Commission 1
Member, Executive Director, Successor Agency Attorney, Secretary and Treasurer to Successor Agency to the Former Sunnyvale Redevelopment Successor Agency
1 Member, Executive Director, Authority Attorney, Secretary and Treasurer to Sunnyvale Financing Authority
1 Member, Executive Director, Secretary and Treasurer to Sunnyvale Industrial Development Authority
1 State Required Filers:

The following positions are NOT covered by the code because they must file under Government Code Section 87200 and are listed for informational purposes only:

Mayor
Councilmember
City Attorney
City Manager
Director of Finance
Member, Planning Commission

An individual holding one of the above listed positions (State Required Filers) 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 Section 87200.

Commented [A4]: Updated position title Deputy Director of ESD - Water Distribution/Sewer Collection
Commented [A5]: Updated position title: Deputy Director of Environmental Services - Wastewater Treatment
Attachment 2

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5 CITY’S CONFLICT OF INTEREST CODE

DISCLOSURE CATEGORIES

Category 1
A designated employee in this category must report all investments, interests in real property owned in the City of Sunnyvale, sources of income including gifts, loans and travel payments, and business entities in which he or she is a director, officer, partner, trustee, employee or holds any position of management.

Category 2
A designated employee in this category must report sources of income including gifts, loans and travel payments, and business entities in which he or she has an investment or is a director, officer, partner, trustee, employee or holds any position of management, if the business entity or source of income is of the type which has done business with the City of Sunnyvale within the previous two years.

Category 3
A designated employee in this category must report sources of income including gifts, loans and travel payments, and business entities in
which he or she has an investment or is a director,
officer, partner, trustee, employee or holds any position of management, if the business entity or source of income is of the type which within the previous two years has provided services, equipment, lease space, materials or supplies to the City.

* City Clerk to work with appropriate department and City Attorney to determine appropriate disclosure category for any newly created position.

** Consultants who serve in a capacity that is the functional equivalent of a designated position shall disclose pursuant to the disclosure category required by this Code for the comparable designated staff position. The City Manager may determine in writing that a particular consultant, although serving in a capacity that is the functional equivalent of 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. 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. (Government Code Section 81008)

Consultants who serve in a capacity for which there is no equivalent designated position, and whose consulting position entails the making of governmental decisions that may foreseeably have a material effect on any financial interest of the consultant, shall disclose pursuant to Category 1.

For purposes of this Code, “making a governmental decision” means to make a decision whether to: (a) approve a rate, rule, or regulation, (b) adopt or enforce a law, (c) issue, deny, suspend, or revoke any permit, license, application, certificate, approval, order, or similar authorization or entitlement, (d) authorize the City to enter into, modify, or renew a contract, (e) grant City approval to a contract or to the specifications for such a contract, (f) grant City approval to a plan, design, report, study, or similar item, or (g) adopt, or grant agency approval of, policies, standards, or guidelines for the City. (FPPC Regulation 18700.3)

Attachment 2

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6 *** Retired annuitants and Casual employees may be included in the list of designated employees when the City Manager, or his or her designee, determines that they are performing work that is the functional equivalent of a designated position. If such a determination is made, then disclosure shall be pursuant to the disclosure category required by this Code for the comparable designated staff position.

Attachment 2

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