HomeMy WebLinkAbout12-519 Huber
ADVICE OF COUNSEL
March 23, 2012
Connie S. Huber, CPA, CGFM
1813 Hunter Drive
Mechanicsburg, PA 17050-1606
12-519
Dear Ms. Huber:
This responds to your two letters dated February 2, 2012, by which you
requested an advisory from the Pennsylvania State Ethics Commission.
Issue:
Whether the Public Official and Employee Ethics Act (“Ethics Act”), 65
Pa.C.S. § 1101 et seq., would impose any prohibitions or restrictions upon a Special
Assistant for Financial Management with the Pennsylvania Department of Community
and Economic Development (“DCED”), whose spouse is the majority owner of a
corporation that has applied for a grant which would be funded in part by the U.S. Small
Business Administration and would be awarded by DCED, with regard to matter(s)
pertaining to such grant.
Facts:
You request an advisory from the Pennsylvania State Ethics Commission
based upon submitted facts that may be fairly summarized as follows.
You are employed as a Special Assistant for Financial Management with the
Financial Management Center within DCED. You have submitted copies of a document
entitled “Special Assistant for Financial Management DCED,” which you state outlines
your job duties, and an organization chart for DCED, both of which documents are
incorporated herein by reference.
You state that your duties and responsibilities as a Special Assistant for Financial
Management include the review and supervision of the Monitoring and Reporting
Division within the Financial Management Center of DCED and special projects. You
directly supervise and complete the Employee Performance Review (“EPR”) for one
employee. You indirectly supervise three other employees and serve as the reviewing
officer for their EPRs. As a supervisor, you have the authority to make
recommendations but not final decisions with regard to hiring and firing.
Your spouse, Richard J. Huber, is the majority owner of a corporation named
“Genesis Systems, Inc.” (“Genesis”). Genesis, through the World Trade Center of
Central Pennsylvania, applied for a Global Access Program grant (“Grant”). The Grant
would be funded in part by the U.S. Small Business Administration (“USSBA”) and
would be awarded by the Office of International Business Development (“Office”) within
DCED. The Grant could be awarded for a maximum amount of $5,000.00 per year and
Huber, 12-519
March 23, 2012
Page 2
would be a one-to-one matching grant to offset a portion of the awardee’s qualifying
expenses associated with export promotion activities. Genesis has applied for the
maximum Grant amount.
You state that prior to you having any knowledge that Genesis would be applying
for the Grant, you provided financial advice to Office staff handling the federal grant
awarded from the USSBA. In April 2011, you certified that the Commonwealth of
Pennsylvania has the proper internal financial management system in place that meets
standards prescribed by the federal government.
Based upon the above submitted facts, you seek guidance as to whether you
would have a conflict of interest in your position as a Special Assistant for Financial
Management for DCED with regard to matter(s) pertaining to the Grant.
Discussion:
It is initially noted that pursuant to Sections 1107(10) and 1107(11) of
the Ethics Act, 65 Pa.C.S. §§ 1107(10), (11), advisories are issued to the requester
based upon the facts that the requester has submitted. In issuing the advisory based
upon the facts that the requester has submitted, the Commission does not engage in an
independent investigation of the facts, nor does it speculate as to facts that have not
been submitted. It is the burden of the requester to truthfully disclose all of the material
facts relevant to the inquiry. 65 Pa.C.S. §§ 1107(10), (11). An advisory only affords a
defense to the extent the requester has truthfully disclosed all of the material facts.
It is further initially noted that, pursuant to the same aforesaid Sections of the
Ethics Act, an opinion/advice may be given only as to prospective (future) conduct. To
the extent that your inquiry relates to conduct that has already occurred, such past
conduct may not be addressed in the context of an advisory opinion. However, to the
extent your inquiry relates to future conduct, your inquiry may and shall be addressed.
As a Special Assistant for Financial Management for DCED, you are a public
employee subject to the provisions of the Ethics Act. This conclusion is based upon the
submitted facts, which when reviewed on an objective basis, indicate clearly that the
power exists to take or recommend official action of a non-ministerial nature with
respect to one or more of the following: contracting; procurement; administering or
monitoring grants or subsidies; planning or zoning; inspecting; licensing; regulating;
auditing; or other activity(ies) where the economic impact is greater than de minimis on
the interests of another person.
Sections 1103(a) and 1103(j) of the Ethics Act provide:
§ 1103. Restricted activities
(a)Conflict of interest.--
No public official or public
employee shall engage in conduct that constitutes a conflict
of interest.
(j)Voting conflict.--
Where voting conflicts are not
otherwise addressed by the Constitution of Pennsylvania or
by any law, rule, regulation, order or ordinance, the following
procedure shall be employed. Any public official or public
employee who in the discharge of his official duties would be
required to vote on a matter that would result in a conflict of
interest shall abstain from voting and, prior to the vote being
taken, publicly announce and disclose the nature of his
interest as a public record in a written memorandum filed
with the person responsible for recording the minutes of the
meeting at which the vote is taken, provided that whenever a
governing body would be unable to take any action on a
Huber, 12-519
March 23, 2012
Page 3
matter before it because the number of members of the body
required to abstain from voting under the provisions of this
section makes the majority or other legally required vote of
approval unattainable, then such members shall be
permitted to vote if disclosures are made as otherwise
provided herein. In the case of a three-member governing
body of a political subdivision, where one member has
abstained from voting as a result of a conflict of interest and
the remaining two members of the governing body have cast
opposing votes, the member who has abstained shall be
permitted to vote to break the tie vote if disclosure is made
as otherwise provided herein.
65 Pa.C.S. §§ 1103(a), (j).
The following terms related to Section 1103(a) are defined in the Ethics Act as
follows:
§ 1102. Definitions
"Conflict" or "conflict of interest."
Use by a public
official or public employee of the authority of his office or
employment or any confidential information received through
his holding public office or employment for the private
pecuniary benefit of himself, a member of his immediate
family or a business with which he or a member of his
immediate family is associated. The term does not include
an action having a de minimis economic impact or which
affects to the same degree a class consisting of the general
public or a subclass consisting of an industry, occupation or
other group which includes the public official or public
employee, a member of his immediate family or a business
with which he or a member of his immediate family is
associated.
"Authority of office or employment."
The actual
power provided by law, the exercise of which is necessary to
the performance of duties and responsibilities unique to a
particular public office or position of public employment.
"Immediate family."
A parent, spouse, child, brother
or sister.
"Business."
Any corporation, partnership, sole
proprietorship, firm, enterprise, franchise, association,
organization, self-employed individual, holding company,
joint stock company, receivership, trust or any legal entity
organized for profit.
"Business with which he is associated."
Any
business in which the person or a member of the person's
immediate family is a director, officer, owner, employee or
has a financial interest.
65 Pa.C.S. § 1102.
Pursuant to Section 1103(a) of the Ethics Act, a public official/public employee is
prohibited from using the authority of public office/employment or confidential
Huber, 12-519
March 23, 2012
Page 4
information received by holding such a public position for the private pecuniary benefit
of the public official/public employee himself, any member of his immediate family, or a
business with which he or a member of his immediate family is associated.
The use of authority of office is not limited merely to voting, but extends to any
use of authority of office including, but not limited to, discussing, conferring with others,
and lobbying for a particular result. Juliante, Order 809.
In each instance of a conflict of interest, a public official/public employee would
be required to abstain from participation, which would include voting unless one of the
statutory exceptions of Section 1103(j) of the Ethics Act would be applicable.
Additionally, the disclosure requirements of Section 1103(j) of the Ethics Act would have
to be satisfied in the event of a voting conflict.
In applying the above provisions of the Ethics Act to the instant matter, you are
advised as follows.
Your spouse is a member of your immediate family as that term is defined in the
Ethics Act. Genesis is a business with which your spouse is associated in his capacity
as an owner. Subject to the statutory exclusions to the definition of “conflict” or “conflict
of interest” as set forth in the Ethics Act, 65 Pa.C.S. § 1102, pursuant to Section
1103(a) of the Ethics Act, you would have a conflict of interest in matters before DCED
that would financially impact Genesis.
You also would be prohibited from using the authority of your public position, or
confidential information accessed or received as a result of being a Special Assistant for
Financial Management for DCED, to effectuate a private pecuniary benefit to Genesis
through a detriment to a competitor for grant(s) from DCED.
You specifically would have a conflict of interest under Section 1103(a) of the
Ethics Act in matter(s) pertaining to the Grant. If Genesis would be awarded the Grant,
you would continue to have a conflict of interest in your official capacity in matter(s)
relating to the Grant.
In each instance of a conflict of interest, you would be required to abstain from
participation, which would include voting unless one of the statutory exceptions of
Section 1103(j) of the Ethics Act would be applicable. Additionally, the disclosure
requirements of Section 1103(j) of the Ethics Act would have to be satisfied in the event
of a voting conflict.
The propriety of the proposed conduct has only been addressed under the Ethics
Act; the applicability of any other statute, code, ordinance, regulation or other code of
conduct other than the Ethics Act has not been considered in that they do not involve an
interpretation of the Ethics Act. Specifically not addressed herein is the applicability of
the Governor’s Code of Conduct.
Conclusion:
As a Special Assistant for Financial Management for the
Pennsylvania Department of Community and Economic Development (“DCED”), you
are a public employee subject to the provisions of the Public Official and Employee
Ethics Act (“Ethics Act”), 65 Pa.C.S. § 1101 et seq. Based upon the submitted facts
that: (1) your spouse, Richard J. Huber, is the majority owner of a corporation named
“Genesis Systems, Inc.” (“Genesis”); (2) Genesis, through the World Trade Center of
Central Pennsylvania, applied for a Global Access Program grant (“Grant”); (3) the
Grant would be funded in part by the U.S. Small Business Administration and would be
awarded by the Office of International Business Development within DCED; (4) the
Grant could be awarded for a maximum amount of $5,000.00 per year and would be a
one-to-one matching grant to offset a portion of the awardee’s qualifying expenses
Huber, 12-519
March 23, 2012
Page 5
associated with export promotion activities; and (5) Genesis has applied for the
maximum Grant amount, you are advised as follows.
Your spouse is a member of your immediate family as that term is defined in the
Ethics Act. Genesis is a business with which your spouse is associated in his capacity
as an owner. Subject to the statutory exclusions to the definition of “conflict” or “conflict
of interest” as set forth in the Ethics Act, 65 Pa.C.S. § 1102, pursuant to Section
1103(a) of the Ethics Act, you would have a conflict of interest in matters before DCED
that would financially impact Genesis. You also would be prohibited from using the
authority of your public position, or confidential information accessed or received as a
result of being a Special Assistant for Financial Management for DCED, to effectuate a
private pecuniary benefit to Genesis through a detriment to a competitor for grant(s)
from DCED. You specifically would have a conflict of interest under Section 1103(a) of
the Ethics Act in matter(s) pertaining to the Grant. If Genesis would be awarded the
Grant, you would continue to have a conflict of interest in your official capacity in
matter(s) relating to the Grant. In each instance of a conflict of interest, you would be
required to abstain from participation, which would include voting unless one of the
statutory exceptions of Section 1103(j) of the Ethics Act would be applicable.
Additionally, the disclosure requirements of Section 1103(j) of the Ethics Act would have
to be satisfied in the event of a voting conflict. Lastly, the propriety of the proposed
conduct has only been addressed under the Ethics Act.
Pursuant to Section 1107(11) of the Ethics Act, an Advice is a complete defense
in any enforcement proceeding initiated by the Commission, and evidence of good faith
conduct in any other civil or criminal proceeding, provided the requester has disclosed
truthfully all the material facts and committed the acts complained of in reliance on the
Advice given.
This letter is a public record and will be made available as such
.
Finally, if you disagree with this Advice or if you have any
reason to challenge same, you may appeal the Advice to the full
Commission. A personal appearance before the Commission will be
scheduled and a formal Opinion will be issued by the Commission.
Any such appeal must be in writing and must be actually
received at the Commission within thirty (30) days of the date of this
Advice pursuant to 51 Pa. Code § 13.2(h). The appeal may be
received at the Commission by hand delivery, United States mail,
delivery service, or by FAX transmission (717-787-0806). Failure to
file such an appeal at the Commission within thirty (30) days may
result in the dismissal of the appeal.
Sincerely,
Robin M. Hittie
Chief Counsel