DATE: November 4, 2025
TO: Board of Supervisors
SUBMITTED BY: Paul Nerland, County Administrative Officer
SUBJECT: Revision to Administrative Policy No. 1 - Code of Ethics
RECOMMENDED ACTION(S):
TITLE
Approve revised Administrative Policy No. 1 - Code of Ethics to include “Conflict of Interest” in the title, clarify the roles of the Board Chairman, County Administrative Officer, County Counsel and the Director of Human Resources, and remove details regarding reporting and training requirements that are not consistent with County Administrative Policy format.
REPORT
Approval of the recommended action will adopt the revised Administrative Policy No. 1 (AP 1) to include “Conflict of Interest” in the title, clarify the roles of the Board Chairman, County Administrative Officer (CAO), County Counsel and Director of Human Resources in enforcing AP 1. Additionally, the revised policy proposes to remove specific information on how the County will comply with State law relating to gifts and gratuities reporting as well as ethics training. Instead, the proposed policy directs the CAO to specify how the County will comply with State law via a Management Directive. This item is countywide.
ALTERNATIVE ACTION(S):
Your Board could choose not to approve the recommended revisions or direct staff to make different changes to AP 1 prior to Board approval.
FISCAL IMPACT:
There is no fiscal impact associated with the recommended action.
DISCUSSION:
AP 1 establishes ethical standards for the Board, elected officials, and all County employees, ensuring integrity, fairness, and public trust. The proposed revisions to AP 1 modernize language, clarify responsibilities, and align the County’s ethical standards with current State law and best practices.
The policy title has been expanded to include “Conflict of Interest” to reflect its broader purpose. The revisions refine and reorganize the policy’s ethical principles for clarity, emphasizing professionalism, respect, and integrity. Updated guidance on gifts and gratuities specifies that such items may only be accepted when they serve a legitimate County interest and must be reported as required by State law. The revisions also clarify the roles and responsibilities of County leadership and departments:
• The Chairman of the Board and the CAO share responsibility for ensuring adherence to the policy;
• The CAO and department heads are tasked with promoting compliance, developing procedures, and ensuring required ethics training and conflict-of-interest disclosures;
• County Counsel’s advisory role is clarified to apply to employees in their official capacity; and
• The Director of Human Resources is assigned responsibility for distributing policy information to new employees and overseeing required training and reporting.
Additionally, formatting and structure have been updated to ensure consistency with current County administrative policy standards.
If the revised AP 1 is approved by your Board, the CAO, in consultation with the County Counsel, will release a Management Directive that details how the County will comply with AP 1 and State law, including reporting and training requirements.
One major area of compliance to be addressed by the Management Directive is the biennial training requirement from Assembly Bill (AB) 1234 (2005), which requires two hours of conflict of interest and ethics training be provided to certain County officers upon joining the County and every two years following. The existing AP 1 requires the following County officers and employees to complete the AB 1234 Ethics Training every two years:
• The Board of Supervisors;
• The members of all County boards, committees, and commissions who receive per diem under the Salary Resolution;
• The members of all County boards, committees, and commissions who receive reimbursement for expenses under the Salary Resolution;
• All elected County officers; and
• The CAO and all appointed department heads.
The Management Directive will expand the group of employees responsible for training under AB 1234 to include all employees who are designated filers under the County’s Conflict of Interest Code of the Fair Political Practices Commission (FPPC) Form 700. This would ensure that all employees who are responsible for decisions affecting County finances are aware of their legal responsibilities.
AP 1 specifies that the Director of Human Resources is authorized to prescribe the manner for completing ethics and conflict of interest training, including AB 1234 ethics training, and required reporting.
Revisions to AP 1 will also remove the quarterly gifts and gratuities reporting requirement. That requirement is largely redundant of FPPC Form 700 reporting, and amounts to an unnecessary administrative burden.
ATTACHMENTS INCLUDED AND/OR ON FILE:
Administrative Policy No. 1 (Redline)
Administrative Policy No. 1 (Clean)
CAO ANALYST:
Amy Ryals