HomeMy WebLinkAboutItem 5.5 Amend the Dublin Municipal Code Pertaining to the City’s Conflict of Interest Code Agenda Item 5.5
STAFF REPORT
CITY COUNCIL
Page 1 of 3
DATE: October 6, 2026
TO: Honorable Mayor and City Councilmembers
FROM: Colleen Tribby, City Manager
SUBJECT:
Amend the Dublin Municipal Code Pertaining to the City’s Conflict of
Interest Code
Prepared by: Sarah Monnastes, Human Resources Director and Marsha
Moore, City Clerk
EXECUTIVE SUMMARY:
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. Staff conducted a review of
the Code and determined that several positions should be added and several position titles
should be revised. The City Council will consider adopting an ordinance to update the list of
designated positions that must file a Statement of Economic Interests (Form 700). The
ordinance was introduced on September 15, 2026 with an amendment to remove the Human
Services Commission and is now ready for adoption.
STAFF RECOMMENDATION:
Waive the reading and adopt the Ordinance Amending Chapter 2.24.020 of the Dublin
Municipal Code Relating to the City’s Conflict of Interest Code.
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).
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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.
On June 16, 2026, 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 Cod e
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 Fair Political Practices Commission (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 categories and revisions, are:
Communications Manager (disclosure category 1). Revised to Community
Engagement Manager (disclosure category 1).
Environmental Coordinator (disclosure category 1). Revised to Environmental
Specialist (disclosure category 1).
Finance Analyst (disclosure category 1). Revised to Financial Analyst (disclosure
category 1).
Information Services Manager (disclosure category 3). Revised to Information
Systems Manager (disclosure category 3).
Public Works Director/Assistant City Engineer (disclosure category 1). Revised to
Public Works Director (disclosure category 1).
Public Works Manager (disclosure category 1). Revised to Public Works
Maintenance Manager (disclosure category 1).
Public Works Transportation and Operations Manager (disclosure category 1).
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Revised to Transportation and Operations Manager (disclosure category 1).
On September 15, 2026, the City Council introduced an ordinance amending the Conflict of
Interest Code. As part of that deliberation, the City Council also directed Staff to modify the
Ordinance to remove the Human Services Commission, consistent with City Council actions
that same night to consolidate the Human Services Commission with the Parks and
Community Services Commission. The City Council will now consider adopting the Ordinance
amending the Conflict of Interest Code consistent with the changes described above.
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
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Attachment 1
Ord. No. XX-26, Item X.X, Adopted XX/XX/26 Page 1 of 4
ORDINANCE NO. XX – 26
AN ORDINANCE OF THE CITY COUNCIL
OF THE CITY OF DUBLIN
AMENDING CHAPTER 2.24.020 OF THE DUBLIN MUNICIPAL CODE RELATING TO THE
CITY’S CONFLICT OF INTEREST CODE
WHEREAS, the Political Reform Act codified at Government Code Section 81000 et seq.,
requires every local government agency to review its Conflict of Interest Code biennially to
determine whether amendments to the Code are required; and
WHEREAS, following review of the Conflict of Interest Code, it was determined that the
amendments contained in this Ordinance were appropriate.
NOW, THEREFORE, The City Council of the City of Dublin does ordain as follows:
Section 1. Chapter 2.24.020 is amended to read as follows:
For local officials specified in Government Code Section 87200 (including the Mayor, City
Councilmembers, Planning Commissioners, City Manager, and City Attorney), no disclosure is
required by this Conflict of Interest Code as full disclosure is required by Government Code
Section 87200 et seq.
The positions listed in this section are designated positions, and this section is hereby deemed
the Appendix referenced in the provisions incorporated by Section 2.24.015. Officers and
employees holding those positions are designated public officials, and are deemed to make, or
participate in the making of, decisions which may foreseeably have a material financial effect on
a financial interest of the designated public official. Each designated public official shall file an
annual statement disclosing that public official’s interests as required by the disclosure category
applicable to that public official.
Designated Position Disclosure
Category
Accounting Manager 3
Assistant City Attorney 1
Assistant City Manager 1
Assistant to the City Manager 1
Assistant Director of Community Development 1
Assistant Director of Parks and Community
Services
1
Assistant Public Works Director/City Engineer 1
Associate Civil Engineer 1
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Ord. No. XX-26, Item X.X, Adopted XX/XX/26 Page 2 of 4
Designated Position Disclosure
Category
Capital Improvement Program (CIP) Manager 1
Chief Building Official 1
Chief Information Security Officer 1
City Clerk 3
Code Enforcement Officer 1
Community Engagement Manager 1
Community Development Director 1
“Consultant”* as defined in FPPC Reg. sect.
18700.3
1
Deputy City Clerk 3
Deputy City Manager 3
Economic Development Director 1
Economic Development Manager 1
Environmental Specialist 1
Environmental Technician 1
Environmental Sustainability Manager 1
Finance Director 3
Financial Analyst 1
Housing Specialist 1
Human Resources Director 3
Human Resources Manager 3
Information Systems Manager 3
Management Analyst II 3
Parks and Community Services Director 1
Parks and Community Services Manager 3
Plan Check Engineer 1
Planning Manager 1
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Ord. No. XX-26, Item X.X, Adopted XX/XX/26 Page 3 of 4
Designated Position Disclosure
Category
Principal Engineer 1
Principal Planner 1
Public Works Director 1
Public Works Maintenance Manager 1
Transportation and Operations Manager 1
Recreation Supervisor 2, 3
Senior Civil Engineer 1
Senior Code Enforcement Officer 1
Senior Digital Engagement Specialist 1
Senior Management Analyst 3
Senior Planner 1
Special Projects Manager 1
Senior Public Works Inspector 1
Designated Boards and Commissions Disclosure
Category
Heritage and Cultural Arts Commission 1
Parks and Community Services Commission 1
* Consultants/new positions shall be included in the list of designated employees and shall
disclose pursuant to the terms of the Disclosure Category 1, subject to the following limitation:
The City Manager may determine in writing that a particular consu ltant or new position, although
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 chapter. Such a written
determination shall include a description of the consultant’s or new position’s duties and, based
upon that description, a statement of the extent of the 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. (Gov. Code Section 81008.)
Section 2. Effective Date. This Ordinance shall take effect and be enforced thirty (30)
days following its final adoption.
Section 3. Posting. The City Clerk of the City of Dublin shall cause this Ordinance to
be posted in at least three public places in the City of Dublin in accordance with Section 36933 of
the Government Code of the State of California.
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Ord. No. XX-26, Item X.X, Adopted XX/XX/26 Page 4 of 4
PASSED, APPROVED, AND ADOPTED by the City Council for the City of Dublin this 6th
day of October 2026, by the following vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
______________________________
Mayor
ATTEST:
_________________________________
City Clerk
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