2026 Biennial City Conflict of Interest Code

Adopt a Resolution approving the 2026 Conflict of Interest Code as amended, authorizing future updates by Resolution, and authorizing the City Clerk to complete and file the 2026 Local Biennial Notice.

Taresa Geilfuss, CMC, City Clerk

The Political Reform Act requires local agencies to adopt and periodically review a Conflict of Interest Code identifying positions that make or participate in governmental decisions and establishing the financial disclosure requirements applicable to those positions. As part of the 2026 biennial review, staff evaluated the City’s existing Conflict of Interest Code to ensure that it accurately reflects the City’s current organizational structure, position responsibilities, and decision-making authority.

The proposed 2026 update comprehensively revises the City’s designated-position and disclosure-category structure. The update separately identifies statutory filers subject to Government Code section 87200; adds City advisory commissions and newly created or previously unlisted positions; updates or removes outdated position titles; reorganizes designated positions by department and functional group; and revises disclosure assignments based on the decision-making responsibilities associated with each position.

The disclosure categories have also been rewritten and consolidated from six categories to five more clearly defined categories. The revised categories address full disclosure, land use and real property, Citywide contracting and purchasing, departmental regulatory and operational authority, and department-specific purchasing and contracting. This approach is intended to more clearly align required financial disclosures with the types of governmental decisions each designated position may make or participate in.

The update also establishes a duty-based approach for Management Analysts, consultants, temporary and provisional employees, volunteers, retired annuitants, and newly created positions so that disclosure requirements may be assigned based on the actual responsibilities of the individual or position.

Collectively, these revisions are intended to improve the clarity and administration of the City’s Conflict of Interest Code while ensuring that designated employees disclose financial interests that are reasonably related to the governmental decisions they may make or participate in.

The recommended action will have no financial impact.