Public Access to Conflict of Interest Codes

The Grand Jury found that Conflict of Interest Codes for Ventura County and its 10 cities are not easily accessible to the public. (FA-07, FA-10) (Att-01) Conflict of Interest Codes 3 Recommendations

The Act establishes the California Fair Political Practices Commission (FPPC) to regulate standards for a Conflict of Interest Code for public officials in State and local governments. The FPPC has posted online the following: “Under the Political Reform Act (‘the Act’), all public agencies are required to adopt a conflict-of-interest code (code). A code designates positions required to file Statements of Economic Interests (Form 700), and assigns disclosure categories specifying the types of interests to be reported. The Form 700 is a public document intended to alert public officials and members of the public to the types of financial interests that may create conflicts of interests.” (Ref-01, Ref-02)

The FPPC website states that each ”Conflict of Interest Code” must contain the following:  How to report financial interests  The disqualification procedures  The governmental positions subject to Conflict of Interest Code requirements  Disclosure categories FPPC Regulation 18730 contains all of the provisions that must be included in a Conflict of Interest Code. The FPPC recommends that agencies incorporate Regulation 18730, by reference, because the type of information required to be in the main body of the code is complex. (Ref-02)

As stated in the FPPC website: “A primary purpose of the code is to require disclosure of those types of investments, interests in real property, sources of income and business positions that designated positions may affect in their decision-making.” (Ref-02)

The Ventura County Board of Supervisors (BOS) has established a Conflict of Interest Code with standards and requirements for all County agencies and departments. (Ref-03)

The County website includes information on the standards for conflict of interest for the Board of Supervisors. (Ref-03)

Each of the 10 cities in Ventura County has established a Conflict of Interest Code. These Codes may be accessed by official websites, Google search, or request to the city. Conflict of Interest Codes

California Government Code § 6250, also known as the California Public Records Act (CPRA), states: “…access to information concerning the conduct of the people’s business is a fundamental and necessary right of every person in this State.” (Ref-04)

California Government Code § 6253(e) states that a local agency may adopt requirements for itself that allow for faster, more efficient, or greater access to records than the minimum standards prescribed by State law. (Ref-04)

The Grand Jury searched online for the Conflict of Interest Codes for the County Board of Supervisors and each of the 10 cities within the County. The following summarizes the results of online searches for Conflict of Interest Codes conducted on May 13, 2016:  Ventura County Board of Supervisors requires four steps and a search.  City of Camarillo website requires five steps.  City of Fillmore website does not provide access. A Google search yielded no results.  City of Moorpark website does not provide access. A Google search yielded no results.  City of Ojai website does not provide access. A Google search yielded no results.  City of Oxnard website was offline. However, a Google search yielded a document stating that the Code is available by request from the City Clerk.  City of Port Hueneme website requires three steps to direct the user to a list of “Statutory References for California Cities” which then requires a search of the statutory references.  City of Santa Paula website does not provide access. A Google search yielded no results.  City of Simi Valley website requires five steps to direct the user to a list of “Statutory References for California Cities” which then requires a search of the statutory references.  City of Thousand Oaks website requires six steps and a search.  City of Ventura website requires six steps and a search. (Ref-03) (Att-01) Findings