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Amend the Dublin Municipal Code Pertaining to the City’s Conflict of Interest Code
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TO: Honorable Mayor and City Councilmembers
FROM: Colleen Tribby, City Manager
Prepared By: Sarah Monnastes, Human Resources Director & Marsha Moore, City Clerk
EXECUTIVE SUMMARY:
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At the June 16, 2026 City Council meeting, the Dublin City Council directed Staff to review the City’s Conflict of Interest Code and determine if it needs to be updated. Staff conducted a review of the Code and determined that several positions should be added and several position titles that should be revised. The City Council will consider introducing an ordinance to update the list of designated positions that must file a Statement of Economic Interests (Form 750).
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STAFF RECOMMENDATION:
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recommendation text
Waive the reading and introduce an Ordinance Amending Chapter 2.24.020 of the Dublin Municipal Code Relating to the City’s Conflict of Interest Code, and direct Staff to file the 2026 Local Agency Biennial Notice.
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FINANCIAL IMPACT:
None.
DESCRIPTION:
The Political Reform Act prohibits a public official from using their official position to influence a governmental decision in which they have a financial interest. The City must maintain a Conflict of Interest Code that identifies all officials and employees who make governmental decisions based on the positions they hold. The individuals identified in the Conflict of Interest Code must publicly disclose their designated financial interests by filing a Statement of Economic Interests (Form 700).
The City’s Conflict of Interest Code, Chapter 2.24 of the Dublin Municipal Code, identifies all positions within the City that participate in the making of governmental decisions. These designated positions are required to disclose certain financial interests under state law. A local agency’s conflict of interest code is not applicable to mayors, city councilmembers, planning commissioners, city managers, or city attorneys, as Government Code Section 87200 requires full Form 700 disclosure for individuals holding these positions.
At the June 16, 2026, City Council meeting, the City Council directed Staff to review the City’s Conflict of Interest Code and determine if it needs to be updated. Additionally, the Political Reform Act requires the City to biennially review and determine whether amendments to the Code are required (Gov. Code § 87306.5). The last biennial revision to the City’s Code was approved on October 1, 2024.
The City Council is the code reviewing body for City agencies. Pursuant to Government Code Section 87306.5, City departments must determine whether amendments to the Code are necessary and notify the City Council if such amendments are required. (Gov. Code §§ 82011(c), 87306.5.)
Staff completed a thorough review of the Conflict of Interest Code, the job specifications for all City employment positions, as well as the FPPC regulations governing the update process. Based on this review Staff recommends the following changes to Chapter 2.24.020 of the Conflict of Interest Code entitled, “Designated Positions”:
1. Add two City positions determined by Staff to “make or participate in the making of governmental decisions.” These positions (and accompanying disclosure categories) are:
• Environmental Technician (disclosure category 1).
• Senior Digital Engagement Specialist (disclosure category 1).
2. Revise the title of seven City positions already designated in the Code. Those positions, and accompanying disclosure category and revisions, are:
a. Communications Manager (disclosure category 1). Revised to Community Engagement Manager (disclosure category 1).
b. Environmental Coordinator (disclosure category 1). Revised to Environmental Specialist (disclosure category 1).
c. Finance Analyst (disclosure category 1). Revised to Financial Analyst (disclosure category 1).
d. Information Services Manager (disclosure category 3). Revised to Information Systems Manager (disclosure category 3).
e. Public Works Director/Assistant City Engineer (disclosure category 1). Revised to Public Works Director (disclosure category 1).
f. Public Works Manager (disclosure category 1). Revised to Public Works Maintenance Manager (disclosure category 1).
g. Public Works Transportation and Operations Manager (disclosure category 1). Revised to Transportation and Operations Manager (disclosure category 1).
The City’s amended Code will not be effective until it has been adopted by the City Council (Gov. Code § 87303). Staff recommends that the City Council waive the reading and introduce the ordinance amending the Conflict of Interest Code consistent with the changes described above, and direct Staff to file the 2026 Local Agency Biennial Notice.
STRATEGIC PLAN INITIATIVE:
None.
NOTICING REQUIREMENTS/PUBLIC OUTREACH:
The City Council Agenda was posted.
ATTACHMENTS:
1) Ordinance Amending Chapter 2.24.020 of the Dublin Municipal Code Relating to the City’s Conflict of Interest Code
2) 2026 Local Agency Biennial Notice