Title
Approve 38 Conflict of Interest Codes Submitted by County Departments and Local Agencies for the Required Biennial Review (Districts: All)
End
Overview
The Board of Supervisors (Board) reviews and approves rules about financial conflicts of interests for local agencies in the County, except for cities, as required by state law. These are called Conflict of Interest Codes. A Conflict of Interest Code designates positions that are required to file Statements of Economic Interests (or Form 700). Every two years, the Clerk of the Board of Supervisors organizes reviews of the codes for agencies and County departments. The Board is being asked to approve updated and new Conflicts of Interest Codes that were submitted by certain County departments and agencies.
Body
Recommendation by Chief Administrative Officer:
1) Approve the amended Conflict of Interest Codes adopted by the following County departments (Attachment A):
o Agriculture, Weights and Measures
o Assessor/Recorder/County Clerk
o Animal Services
o Board of Supervisors District Staff
o Chief Administrative Office
o Citizens’ Law Enforcement Review Board
o County Communications Office
o County Counsel
o County Library
o District Attorney
o Environmental Health and Quality
o Finance & General Government Group - Executive Office
o General Services
o Health and Human Services Agency
o Human Resources
o Land Use Environment Group - Executive Office
o Medical Examiner
o Office of Emergency Services
o Parks and Recreation
o Public Safety Group - Executive Office
o Public Works
o Purchasing & Contracting
o Registrar of Voters
o San Diego County Fire Authority
o Sheriff
o Treasurer-Tax Collector
2) Approve the amended Conflict of Interest Codes adopted by the following agencies
(Attachment B):
o Altus Schools San Diego
o Fallbrook Union High School District
o Leucadia Wastewater District
o Lower Sweetwater Fire Protection District (prior code is being replaced in its entirety)
o North County Dispatch Joint Powers Authority
o Olivenhain Municipal Water District
o Resource Conservation District of Greater San Diego County
o San Marcos Unified School District
o South Bay Union School District
o Water Conservation Garden Authority
3) Approve the new Conflict of Interest Code adopted by the following department/agency:
(Attachment C):
o Behavioral Health Services
o Palomar UCSD Health Authority
End
Equity Impact Statement
County government includes standing and special boards, commissions, committees and task forces formed to advise the Board of Supervisors and County staff on issues and policies and to serve as links to the community. Boards, commissions and committees provide an inter-relationship between the residents and the government of the County and as such must provide transparent, bias-free decision-making. The Board of Supervisors serves as the Code Reviewing Body for any local agency, other than cities, with jurisdiction wholly within the County, pursuant to Government Code Section 82011. Under the California Political Reform Act, a public official has a disqualifying conflict of interest in a governmental decision if it is foreseeable that the decision will have a financial impact on their personal finances or other financial interests. In such cases, there is a risk of biased decision-making that could sacrifice the public’s interest in favor of the official’s private financial interests. To avoid actual bias or the appearance of possible improprieties, the public official is prohibited from participating in the decision.
The recommended actions would approve the new and amended Conflict of Interest codes. The Conflict of Interest codes in this Board Letter enable the County of San Diego to provide transparency and accountability to individual residents, ensuring equitable operations of the government that are free from undue influence.
Sustainability Impact Statement
Under the Political Reform Act, all public agencies are required to adopt a Conflict of Interest code that designates positions that are required to file the Statement of Economic Interests (Form 700). Conflict of Interest codes must be maintained as updated and accurate to ensure that necessary public officials report their personal financial interests. These required filings provide public transparency about possible conflicts of interest and to ensure governmental decisions are made in the best interest of the public. This Board Letter supports the County of San Diego’s sustainability goal of, “Engaging the community to partner and participate in decisions that impact their lives and communities and transparently share results of outcomes.”
Fiscal Impact
There is no fiscal impact associated with this recommendation. There will be no change in General Fund cost and no additional staff years.
Business Impact Statement
N/A
Advisory Board Statement
N/A
Background
The Board of Supervisors (Board) serves as the Code Reviewing Board for all County departments and some local agencies. Pursuant to Government Code Section 87306.5, the Clerk of the Board coordinated, on behalf of the Board of Supervisors, the Biennial Review of Conflict of Interest Codes for all County Departments and local agencies.
On October 31, 2006 (21), the Board adopted Ordinance No. 9803 (N.S.), “County of San Diego Conflict of Interest Code.” This “global” County Conflict of Interest Code replaces each County department’s Conflict of Interest Code and serves as the County’s single official document representing the County of San Diego Conflict of Interest Code applicable to all County departments.
County departments and local agencies were required to review their Conflict of Interest Codes, including designated employees and disclosure categories. These departments and agencies were required to complete the Biennial Review Reply Form indicating if any amendments were necessary and return it to the Clerk of the Board by June 30, 2026 for County departments and by September 1, 2026 for local agencies. If amendments were required, the department/agency was to submit the necessary amendment documentation to the Clerk of the Board by July 31, 2026, for County departments and by September 15, 2026 for local agencies.
The recommendations above involve 38 agencies/departments that indicated amendments were required to their Codes, such as the addition of newly designated positions, changes to the reportable sources of income, investments, business position or real property, changes or additional provisions required by Section 87302, or adoption of the standard Conflict of Interest Code. Additional Conflict of Interest Codes will be submitted to the Board for consideration in batches through December 2026.
Linkage to the County of San Diego Strategic Plan
Today’s proposed action to approve the Conflict of Interest Codes supports the Transparency and Accountability Strategic Initiative in the County of San Diego’s 2026-2031 Strategic Plan by promoting a culture of ethical leadership and decision making across the enterprise.
Respectfully submitted,
Ebony N. Shelton
Chief Administrative Officer
Attachment(s)
Attachment A: Amended Conflict of Interest Code (County Departments)- Clean
Attachment B: Amended Conflict of Interest Code (Local Agencies)- Clean
Attachment C: New Conflict of Interest Code (County Department and Local Agency)- Clean
Attachment D: Conflict of Interest Code (County Departments) - Supporting Documents
Attachment E: Conflict of Interest Code (Local Agencies) - Supporting Documents