HomeMy WebLinkAbout2021 Ordinance No. 004Page 1 of 10
BY AUTHORITY
ORDINANCE NO. 4 COUNCIL BILL NO. 02
SERIES OF 2021 INTRODUCED BY COUNCIL
MEMBER OLSON
AN ORDINANCE AMENDING TITLE 1 BY ADOPTING CHAPTER 11,
SECTIONS 1-9 REGARDING ESTABLISHMENT OF A CODE OF ETHICS, ALL
WITHIN THE CITY OF ENGLEWOOD, COLORADO.
WHEREAS, the City of Englewood, Colorado, (“City”), is a home rule municipality,
organized and existing under and by virtue of Article XX, Section 6 of the Colorado Constitution,
and as such the City has all legislative powers and functions of home rule municipal government
as reserved to it by the Colorado Constitution and the laws of the State of Colorado;
WHEREAS, the City Council finds and determines that its regulation of the subject of the
ethical conduct of Representative of the City is a matter of local concern upon which the City of
Englewood is empowered to legislate and that once adopted these regulations shall supersede
within the City of Englewood all conflicting state statutes, including, but not limited to Title 24,
Article 18, Colorado Revised Statutes, C.R.S. § 24-6-203; and C.R.S. § 31-4-404;
WHEREAS, the provisions of this Code of Ethics are distinct from and in addition to the
reporting requirements for candidates for elected position, and do not relieve an incumbent in or
elected candidate to public office from reporting financial matters in accordance with State law;
and
WHEREAS, this Title 1, Chapter 11 shall replace Resolution 86, Series of 2006 which
was previously adopted to serve as the Code of Ethics for the City of Englewood.
NOW, THEREFORE, BE IT ORDAINED BY THE CITY COUNCIL OF THE CITY OF
ENGLEWOOD, COLORADO, AS FOLLOWS:
Section 1: Establishment of Title 1, Chapter 11. Title 1, Chapter 11, Code of Ethics
shall be adopted as set forth below:
1-11-1: PURPOSE AND AUTHORITY.
A. The City Council finds and determines that its regulation of the subject of the ethical
conduct of Representative of the City is a matter of local concern upon which the City of
Englewood is empowered to legislate pursuant to the home rule authority granted in Article
XX of the Constitution of the State of Colorado. These regulations do not supersede the City
Manager’s authority to create more restrictive ethical standards for employees in accordance
with Charter §52, but are intended to supersede all conflicting state statutes and local
ordinances, including, but not limited to:
1. Title 24, Article 18, Colorado Revised Statutes;
2. C.R.S. § 24-6-203; and
3. C.R.S. § 31-4-404.
B. The City Council finds and determines that this chapter addresses the matters covered by
Article XXIX of the Constitution of the State of Colorado. Therefore, per Section 7 of said
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Article XXIX, its provisions do not apply to the City or any Representative of the City and the
independent ethics commission created by Section 5 of said Article XXIX has no jurisdiction
over any Representative of the City.
C. The provisions of this Code of Ethics are distinct from and in addition to the reporting
requirements for candidates for elected position, and do not relieve an incumbent in or elected
candidate to public office from reporting financial matters in accordance with State law.
1-11-2: PUBLIC TRUST; FIDUCIARY DUTY.
The holding of public office or employment is a public trust, and imposes a fiduciary duty upon
every representative of the City, including elected officials and City employees. A member of
City Council, Board or City employee shall carry out their duties for the benefit of the people
of the City in accordance with this Code of Ethics.
1-11-3: DEFINITIONS. As used in this chapter, unless the context otherwise requires:
BOARD: Any board, committee, commission, authority or other body appointed by the City
Council, whether standing, provisional or temporary.
BOARD MEMBER: A member of any board, commission or committee appointed by the City
Council, pursuant to the authority vested in the City Council through Charter, ordinance or
state law, including both regular and alternate members. Such term does not include or cover
any compensated full-time or part-time City employee.
BUSINESS: Any corporation, limited liability company, partnership, sole proprietorship, trust
or foundation, or other individual or organization providing a service, resource(s) or goods,
whether or not operated for profit.
COMPENSATION: Any money, thing of value, or economic benefit conferred on or received
by any person in exchange for goods or services rendered, whether rendered by himself or
another.
CONFLICT OF INTEREST (Personal or Private): A a personal right or a pecuniary right or
liability that would materially (i.e. not de minimis) affect a Representative of the City’s financial
interest, those of such representative’s family members or any business with which the
Representative of the City is associated. A Conflict of Interest does not include a public
interest.
Examples include: (i) A Representative of the City is employed by or consults for a firm that
will be directly benefitted by a decision of City Council; (ii) A Representative of the City's
spouse or family member owns a share of business that is pursuing a new housing
development and needs City Council action to move forward on zoning or licensing; or (iii) A
Representative of the City owns an interest in property that the City wishes to purchase.
ECONOMIC BENEFIT: An economic benefit tantamount to a gift of substantial value includes,
without limitation, a loan at a rate of interest substantially lower than the commercial rate then
currently prevalent for similar loans and compensation received for private services rendered
at a rate substantially exceeding the fair market value of such services.
EMPLOYEE: Any compensated person in the service of the City who is designated as an
employee in the City's personnel policies and procedures, except a member of the City
Council, the municipal judge or an independent contractor.
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FAMILY (FAMILY MEMBER): Family includes any person related to the Representative of the
City by one degree of kinship (i.e., parents, siblings, children) by blood or marriage and shall
also include spouses, domestic partners, and persons in a civil union regardless of whether
the relationship is formally recognized.
FIDUCIARY DUTY: A duty to act for the benefit of the City on matters within the scope of
one’s position.
FINANCIAL INTEREST: A substantial interest held by a Representative of the City, or their
spouse, which is:
(1) An ownership interest in a business;
(2) A creditor interest in an insolvent business;
(3) An employment or a prospective employment for which negotiations have begun;
(4) An ownership interest in real or personal property;
(5) A loan or any other debtor interest; or
(6) A directorship or position of corporate officer in a business.
GIFT OR GRATUITY: The acceptance by a Representative of the City or Board Member of
goods, services or money for his or her own personal benefit offered by a person who is at
the same time providing goods or services to the City under a contract or other means of
which the Representative of the City or Board Member has a measure of control or decision-
making authority, unless the totality of the circumstances attendant to the acceptance of the
goods or services indicates that the transaction is legitimate, the terms are fair to both parties,
the transaction is supported by full and adequate consideration, and the Representative of the
City does not receive any substantial benefit resulting from such person’s official or
governmental status that is unavailable to members of the public generally.
OFFICIAL ACT OR OFFICIAL ACTION: Any vote, decision, recommendation, approval,
disapproval, or other action, including inaction, which involves the use of discretionary
authority.
PERSON: Any individual or any other legal entity.
PUBLIC INTEREST: Something in which the community at large has some interest.
Examples include: Interests in general City goals, such as facilitating economic
opportunity or protecting the natural environment, are shared with the public and do not
cause a conflict of interest even if the Representative of the City may indirectly benefit
from these policies. Similarly, a Representative of the City who is the patron of a grocery
store or other business does not have a conflict of interest if the business seeks an
approval from the City because the Representative of the City's interest as a customer is
shared with the public. Living in the City, attending church or having children who attend
local schools are further examples of matters of public interest.
REPRESENTATIVE OF THE CITY: For purposes of this Chapter a member of the City
Council or an employee.
THING OF VALUE: Any tangible or intangible thing having a market value.
1-11-4: RULES OF CONDUCT FOR CITY COUNCIL MEMBERS AND CITY EMPLOYEES.
A. It shall be a breach of a Representative to the City’s fiduciary duty and the public trust to:
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1. Disclose or use confidential information acquired in the course of their official
duties in order to further substantially a personal financial interest. Confidential or
privileged information, including information learned within an executive session, shall not
be disclosed except as provided by law.
2. Engage in a substantial financial transaction for a private business purpose with a
person who is inspected or supervised by Representative of the City in their capacity as a
Representative of the City.
3. Perform an official act directly and substantially providing a direct or indirect
economic benefit to/for a business or other undertaking in which they or a family member
either have a substantial financial interest or are engaged as counsel, consultant,
representative, or agent.
B. An employee of the City who has a personal or private interest in any matter associated
with such employee’s employment shall disclose such interest to their Department Director
and immediate supervisor in writing. Employees shall not provide to any other entity, public
or private, the same services for which they are retained by City without written approval from
their Department Director. Employees shall not privately provide services to or accept
payment from parties in contract with the City or provide services to the City.
C. No employee may directly or indirectly supervise his or her family member or work under
the line of supervision of any family member.
1-11-5: RULES OF CONDUCT FOR BOARD MEMBERS.
A. Commission of any act enumerated in this section is proof that the actor has breached a
fiduciary duty. Final determination shall be made by the City Council. That decision is not
subject to appeal.
B. A member of a board who has a personal or private interest in any matter proposed or
pending before the board shall disclose such interest to the board and shall not vote thereon
and shall refrain from attempting to influence the decisions of the other members of a board
in voting on the matter.
C. A member of a board who has an appearance of impropriety in any matter proposed or
pending before the board shall disclose such interest and shall either affirm his or her vote will
not be influenced by such interest or shall not vote thereon and shall refrain from attempting
to influence the decisions of the other members of the board in voting on the matter.
1-11-6: GIFTS AND GRATUITIES.
A. Neither a Representative of the City nor a Board Member shall solicit or accept any gift
from any person, either directly or indirectly through a spouse or dependent child, which gift
the Representative of the City or Board Member knows or which a reasonable person in such
person’s position should know, under the circumstances, is either:
1. A gift that would tend to improperly influence that Representative of the City or
Board Member to depart from the faithful and impartial discharge of his or her public duties;
or
2. Is a gift being solicited or given for the primary purpose of rewarding the
Representative of the City or Board Member for an official action he or she has taken;
B. Rebuttable presumption of ethical violation arising from the acceptance of gift or gratuity.
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1. There shall be a rebuttable presumption that a gift to a Representative of the City
from a person who has submitted a pending application, or who the Representative of the
City knows is considering submitting such an application, to the City for any kind of
contract or permit is prohibited.
2. There shall be a rebuttable presumption that a gift to a Board Member from a person
who has submitted, or intends to submit, some form of application for contract or permit
to the board upon which such Board Member is appointed to serve is prohibited.
3. There shall be a rebuttable presumption that a gift exceeding $50.00, trips outside
the jurisdiction for non-work-related purposes, or tickets to an event outside the jurisdiction
for a non-work-related purpose is a prohibited gift unless enumerated under subsection
(C) below.
C. The following gifts shall not be deemed to improperly influence a Representative of the
City as described in paragraph (b)(1) or to be an unlawful reward for official action as
described in paragraph (b)(2) and shall not be prohibited for that reason, but they shall be
subject to the prohibition set forth in paragraph (b)(3):
1. Campaign contributions and contributions in kind as authorized by law;
2. An unsolicited, occasional non-pecuniary gift that is of trivial value not exceeding fifty
dollars ($50.00);
3. An unsolicited token or award of appreciation in the form of a plaque, trophy, desk
item, wall memento, or similar item;
4. Unsolicited informational material, publications, or subscriptions related to the
recipient's performance of official duties;
5. Payment of, or reimbursement for, meals, lodging, travel expenses, and admission
for attendance at a convention or other meeting at which the Representative of the City is
scheduled to participate;
6. Gifts similarly available to the general public;
7. Educational scholarships, fellowships, and grants (hereafter collectively referred to
as "scholarships") awarded by any person, whether such scholarships and grants are
awarded to the Representative of the City, or to the Representative of the City's spouse
or family member; provided however, the scholarships must be awarded based on merit,
or competitive application, or ongoing performance requirements, and they must be
awarded on the basis of objective and non-discriminatory criteria;
8. Gifts received pursuant to fundraising activities within the community at large when a
Representative of the City or a Representative of the City's spouse or dependent child has
special medical or financial needs resulting from an accident, medical condition, or other
extraordinary event;
9. Gifts received pursuant to fundraising activities within the community at large when a
Representative of the City or a Representative of the City's spouse retires;
10. An occasional, unsolicited opportunity to participate in a business meeting or social
function where a meal is served and/or entertainment is provided if the Representative of
the City's attendance would not be considered extraordinary when viewed in light of the
position held by the Representative of the City;
11. Anything given by an individual who is a relative;
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12. Anything given by a personal friend of the recipient and such gift is given for personal
reasons, including wedding, birthday, or similar commonly understood reason for gift
giving;
13. Any ticket to a sporting, recreational, or cultural event where the Representative of
the City's attendance is reasonably related to the official or ceremonial duties of the
Representative of the City;
14. Payment for a speech, appearance, or publication with an organization unrelated to
the City and not anticipated to enter into a contract with the City;
15. Payment of salary from employment;
16. Anything given as part of an inter-office gift exchange; or
17. Gifts or things of value received by a Representative of the City from the City, or
received by a Representative of the City arising from his or her non-City employment and
which is unrelated to his or her official City duties.
1-11-7: APPEARANCES OF IMPROPRIETY DISCOURAGED.
A. An appearance of impropriety is created when a Representative of the City or Board
Member will or may take a direct official action that, although not constituting a conflict of
interest, will create a reasonable perception that the Representative of the City or Board
Member's ability to carry out his or her official duties with integrity, impartiality, and
competency is impaired. As examples only, such appearance may be created in the following
circumstances:
1. When the direct official action will involve a close friend, employer, employee, or
business associate of the Representative of the City or Board Member.
2. When the Representative of the City or Board Member is a recipient of an official
notice of a quasi-judicial hearing due to the Representative of the City or Board Member's
ownership or lease of property to be affected by such hearing.
3. When the Representative of the City or Board Member will be called upon to
consider taking official action of a quasi-judicial nature and the Representative of the City
or Board Member has previously and publicly expressed an opinion, position, or bias
regarding the matter.
4. When the Representative of the City or Board Member will be called upon to
consider taking official action of a fiduciary nature and members of the Public would have
reason to believe the Representative of the City to have a personal or private interest in
the matter. Example, when a Representative of the City or Board Member’s personal or
private interest, including those of a family member, are included in advertising published
by the City even when no direct monetary exchange occurs.
B. A Representative of the City or Board Member who determines that his or her actions may
cause an appearance of impropriety should disclose the appearance of impropriety in
accordance with 1-11-8 below, and, if deemed necessary and appropriate by the
Representative of the City, may recuse him or herself from participation.
C. Violations of this Section do not constitute a violation of this Code of Ethics because an
appearance of impropriety is not an actual ethical violation. However, a City Council member
or Board Member who fails to publicly disclose an appearance of impropriety may be subject
to public censure by the City Council. An employee may be disciplined pursuant to the
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administrative policy manual when failure to disclose leads to a breach of trust between the
community and the City/City Administration. Compliance with this Section shall not constitute
a defense for violation of another subsection or section of the Code of Ethics.
1-11-8: DISCLOSURE AND RECUSAL PROCEDURE; CHALLENGES.
A. Disclosure.
1. Mandatory disclosure of a personal/private conflict of interest, or a voluntary
disclosure of an appearance of impropriety, shall be made when the conflict or appearance
is first reasonably known to the Representative of the City or Board Member. For members
of the City Council, disclosure shall be made either orally during a public meeting or in
writing to all other members of the City Council. For the City Manager or City Attorney,
disclosure shall be made either orally during a public meeting or in writing to the City
Council. For Board Members, disclosure shall be made either orally during a meeting or
in writing to all other members of the board or commission. Employees shall make
disclosure in writing to their immediate supervisor. Such immediate supervisor shall inform
the Department Director and the Director of Human Resources.
2. A disclosure shall identify whether the matter is a conflict of interest or an appearance
of impropriety, the general nature of the interests involved, whether the matter will create
or potentially create an economic, pecuniary, or financial benefit or detriment for the
Representative of the City or Board Member, and the approximate value of any potential
benefit or detriment.
B. Recusal.
1. When recusal is required due to a conflict of interest, or at the determination of a
Department Director, or is voluntarily elected due to an appearance of impropriety, the
Representative of the City or Board Member shall:
a. Refrain from communicating with any other Representative of the City or Board
Member regarding the matter and attempting to influence any other Representative of
the City or Board Member's official action concerning the matter;
b. Refrain from voting upon or taking any official action concerning such matter; and
c. Physically leave the podium or meeting area at which the matter is being
considered. Non-elected officials should leave the room.
2. A majority of City Council may require the recusal of a Council Member in
accordance with subsection (c)(1) below. A majority of a Board may require the recusal
of a member in accordance with (C)(3) below. The City Manager may require the recusal
of an employee in accordance with subsection (c)(2) below.
3. Notwithstanding the prohibition against participation and voting where a conflict of
interest exists, a City Council member may participate and vote on a matter
notwithstanding a conflict of interest if participation is necessary to obtain a quorum or
otherwise enable the City Council to act and if the City Council member complies with the
voluntary disclosure procedures, and the City Council affirmatively votes to approve or
require participation.
C. Challenges for conflict of interest.
1. Challenge of City Council Member. Any person may challenge a City Council
member's failure to declare a conflict of interest or failure to recuse himself or herself. A
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challenge must be submitted to the City Council in writing or orally made during a public
meeting stating the facts in support of the challenge. The City Council shall promptly
inquire into the basis and facts of the challenge and may request an opinion from the City
Attorney, or outside counsel, regarding the challenge. The City Council may by majority
vote of those present and voting (excluding any challenged member) render a
determination whether a conflict of interest exists and/or whether recusal of the challenged
Council Member is required. That determination is final and not subject to appeal. The
City Clerk shall note in the minutes of the meeting the recused member’s vote as an
abstention due to conflict of interest.
2. Challenge of employee. Any person may challenge an employee's failure to declare
a conflict of interest or failure to recuse himself or herself. A challenge must be submitted
in writing to the Director of Human Resources stating the facts in support of the challenge,
with a copy to the City Manager. The Director of Human Resources shall promptly inquire
into the basis and facts of the challenge and render a determination whether a conflict of
interest exists. The Director of Human Resources shall make a recommendation as to the
appropriate response to such conflict of interest and provide such recommendation to the
applicable Department Director and City Manager. The City Manager will make a
determination as to the required response to the conflict of interest. That determination is
final and not subject to appeal.
3. Challenge of a Board Member. Any person may challenge any Board Member's
failure to declare a conflict of interest or failure to recuse himself or herself. A challenge in
writing or orally made during a public meeting must be submitted to the City Clerk, to be
distributed to the City Council, and to the chair of that person's board. The written
challenge must state the facts supporting the challenge. The person's board or
commission shall promptly inquire into the basis and facts of the challenge and render a
determination as to whether a conflict of interest exists and/or whether recusal is required.
That determination is final, but may be reviewed by the City Council at the discretion of
the City Council.
1-11-9: ENFORCEMENT OF ETHICAL VIOLATIONS.
A. General Enforcement Provisions. Enforcement of this Code of Ethics shall not involve
either a fine or imprisonment, nor shall enforcement be pursuant to the E.M.C. Title 1, Chapter
4, General Penalty Clause. Action under this Code shall not prohibit or prevent the pursuit of
criminal or civil action if a crime or civil wrong is deemed to have occurred.
B. City Council Members and Board Members. The appropriate means of enforcement of this
Code of Ethics shall be determined by the City Council, in accordance with the restrictions
provided within 1-11-9(A) and any other applicable law, for any alleged violation or actual
violation of this policy by any member of the City Council, any member of any Board, the City
Attorney or the City Manager. Members of the City Council may be censured by a majority
vote of the City Council and required to recuse themselves from a vote in which they are found
to have a personal/private conflict of interest. Board members may be removed from their
appointments for acting upon a matter in which they have a personal/private conflict of
interest. Actions against appointed officials shall be in accordance with applicable law.
C. Employees. The method and manner of enforcement of this Code of Ethics for allegations
made against employees shall be subject to the discretion of the City Manager who, pursuant
to Englewood Charter §52 and Englewood Municipal Code Title 1, Chapter 6, Article A, is
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responsible for the supervision of employees and the suspension, transfer, or termination of
any employee.
Section 2. Notice of general provisions and findings applicable to interpretation and
application of this Ordinance:
Applicability of Title 1, Chapter 2, Savings Clause. The provisions of E.M.C. Title 1, Chapter
2, Savings Clause apply to the interpretation and application of this Ordinance, unless otherwise
set forth above, including, but not limited to, the provisions regarding severability, inconsistent
ordinances or code provisions, effect of repeal or modification, and legislation not affected by
repeal.
Enforcement. Enforcement of the above provisions shall be in accordance with Title 1, Chapter
11, Section 9. Enforcement of this Code of Ethics shall not involve either a fine or imprisonment,
nor shall enforcement be pursuant to the E.M.C. Title 1, Chapter 4, General Penalty Clause.
Action under this Code shall not prohibit or prevent the pursuit of criminal or civil action if a crime
or civil wrong is deemed to have occurred.
Safety Clauses. The Englewood City Council hereby finds, determines, and declares that this
Ordinance is promulgated under the general police power of the City of Englewood, that it is
promulgated for the health, safety, and welfare of the public, and that this Ordinance is necessary
for the preservation of health and safety and for the protection of public convenience and welfare.
The Englewood City Council further determines that the Ordinance bears a rational relation to the
proper legislative object sought to be obtained.
Introduced, read in full, and passed on first reading on the 4th day of January, 2021.
Published by Title as a Bill for an Ordinance in the City’s official newspaper on the 7th
day of January, 2021.
Published as a Bill for an Ordinance on the City’s official website beginning on the 6th
day of January, 2021 for thirty (30) days.
Read by Title and passed on final reading on the 19th day of January, 2021.
Published by Title in the City’s official newspaper as Ordinance No. 4, Series of 2021, on
the 21st day of January, 2021.
Published by title on the City’s official website beginning on the 20th day of January,
2021 for thirty (30) days.
This Ordinance shall take effect thirty (30) days after publication following final passage.
Linda Olson, Mayor
ATTEST:
Stephanie Carlile, City Clerk
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I, Stephanie Carlile, City Clerk of the City of Englewood, Colorado, hereby certify that the
above and foregoing is a true copy of the Ordinance passed on final reading and published by
Title as Ordinance No. 4, Series of 2021.
Stephanie Carlile