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POST-EMPLOYMENT RULE


One-Year Limitation
The City’s Code of Ethics limits the activities of former city officials and employees in connection with appearances before the City, work on city-related projects, and financial disclosure for one year following their separation from city employment or service. The one-year preclusion period begins on the first day following the severance of the individual’s employment or service with the City.

Purpose
The purpose of this provision is to prevent former city officials and employees from attempting to further their own financial interests by using inside information obtained during city service, deriving personal benefits from actions made while employed with the City, or asserting undue influence on former colleagues who continue to work for the City.

Ban on Appearances
The term “appear” means formal presentations, letters, emails, telephone calls, conversations, and other forms of communication. 

  • Former city elected officials and employees may not appear before city agencies on behalf of private interests for one year 
  • Former city board members may not appear on behalf of private interests for one year before the city board on which they served or the agency regulated by it

No Compensation for Special Knowledge
Section 2-810 also prohibits former officials and employees from being paid for services related to any matter in which they were directly concerned, personally participated, actively considered, or acquired knowledge while employed with the City.  This prohibition depends on the individual's specific participation and knowledge gained while serving the City. 

Example: A city planner reviewed applications for new subdivisions while employed by the City.  After he leaves city employment, he may not represent the property owner regarding a subdivision plan that the employee actively considered as an planner. 

Financial Disclosure Required
To assure compliance with the one-year cooling-off period, the Code of Ethics requires filers to submit a city financial disclosure statement in the year after they leave city employment or service.  Beginning in 2009, filers will be asked to disclose appearances made before city agencies on behalf of private interests.

When Appearances Allowed

  • City officials and employees may appear as a citizen before any city agency in connection with their own personal property interests
  • Former city officials and employees may appear without pay before any city agency while performing civic or public obligations