City Council Agenda Report
Meeting Date: November 18, 2025
From: Genoveva Rocha, City Clerk
Department: City Clerk
Submitted by: Sandra Dolson, Deputy City Clerk
Subject
Conflict of Interest Code (Statement of Economic Interests) Recommendation
Adopt Resolution No. 2025-034 approving and adopting the amended Conflict of Interest Code pursuant to the Political Reform Act of 1974 and repealing Resolution No. 2024-019.
Background
The Political Reform Act of 1974 is a California law designed to promote transparency in government and establishes guidelines for disclosure of financial interests. Government Code Section 8100 et seq. (the “Act”), requires all public agencies to adopt and maintain a Conflict-ofInterest Code. The Act further requires that agencies regularly review and update their Codes as necessary, as directed by the code-reviewing body, the City Council is the City’s code-reviewing body, or when change is necessitated by changed circumstances (Sections 87306 and 87306.5).
During this review, staff found that amendments to the Code are necessary. A Conflict-of-Interest Code requires certain employees who are most likely to be in a governmental decision-making capacity and where potential conflicts may occur to file an annual disclosure form. The Statement of Economic Interest Form, also known as the Form 700, provides transparency and ensures accountability in two ways:
• It provides necessary information to the public about an official’s personal financial interests to ensure that officials are making decisions in the best interest of the public and not enhancing their personal finances; and
• It serves as a reminder to the public official of potential conflicts of interest so the official can abstain from making or participating in governmental decisions that are deemed conflicts of interest
The Code was last amended on September 17, 2024, when the Vernon City Council adopted Resolution No. 2024-019. Updates to the current code are necessary due to changes in job titles, as well as the addition and removal of certain positions, and the designation of filing categories. Designated positions can only be required to disclose interests that they may effect in the course of performing the position’s duties. The proposed amended Conflict of Interest Code outlines these recommended changes.
Attachment No. 2 outlines the changes to Code, showing both the current positions and the updates. Attachment No. 3 is the proposed amended Conflict of Interest Code which includes all designated positions and the disclosure filing categories. The disclosure categories listed identify the types of economic interests that the designated position must disclose for each disclosure category to which the designated position is assigned. “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.
Individuals in positions designated by the Conflict-of-Interest Code are required to file an annual Statement of Economic Interests (Form 700). This statement must reflect activities from the previous calendar year and be submitted using the City’s electronic filing system.
Officials who are specified in Government Code section 87200 (including officials who manage public investments, as defined by 2 Cal. Code of Regs. § 18701 (b), are not subject to the Agency’s Conflict of Interest Code, but are subject to the disclosure requirements of the Political Reform Act, Government Code section 87100, et seq. Gov’t Code § 87203. These positions are listed here for informational purposes only. The positions listed below are officials who are specified in Government Code section 87200:
• Mayor and Member of the Council
• City Manager
• City Attorney
• City Treasurer
Fiscal Impact
There is no fiscal impact associated with this report.
Attachments
1. Resolution No. 2025-034
2. Conflict of Interest Code Positions Redline
3. 2025 Amended Conflict of Interest
4. Public Notice
5. Provisions of Conflict of Interest Code