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HomeMy WebLinkAbout1711 GreenSTATE ETHICS COMMISSION 309 FINANCE BUILDING HARRISBURG, PENNSYLVANIA 17120 In Re: Timothy Green, File Docket: Respondent X -ref: Date Decided Date Mailed: 16 --014 Order No. 1711 3128117 3131117 Before: Nicholas A. Colafella, Chair Mark R. Corrigan, Vice Chair Roger Nick Maria Feeley Melanie DePalma This is a final adjudication of the State Ethics Commission. Procedurally, the Investigative Division of the State Ethics Commission conducted an investigation regarding possible violation(s) of the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1101 et seq., by the above -named Respondent. At the commencement of its investigation, the Investigative Division served upon Respondent written notice of the specific allegations. Upon completion of its investigation, the Investigative Division issued and served upon Respondent a Findings Report identified as an Investigative Complaint. A Stipulation of Findings and a Consent Agreement were subsequently submitted by the parties to the Commission for consideration. The Stipulated Findings are set forth as the Findings in this Order. The Consent Agreement has been approved. ALLEGATIONS: That Timothy J. Green, a public official/public employee in his capacity as a Supervisor for Smith Township, Washingtoni County, violated [Sections 1103(a), 1104(a), 1104Ml 1105(a), and 1105(b)(5)] of the State Ethics Act (Act 3 of 1995) when he utilized the hority of his public positionloffice resulting in a pecuniary benefit to himself, members of his immediate family and/or a business with which he /members of his immediate family are associated, namely Green Road & Towing Services, Inc., when he racrtiucTated in discussions and actions of the Smith Township Board of Supervisors, nlng] regularly reviewinglapproving invoices from Green Road & Towing Services, Inc. issued to the Township concerning vehicle repairs; when he served as an authorized Township signatory on Township checks issued to Green Road & Towing Services, Inc.; when he voted affirmatively to approve Township monthly bill listslpayments which included payments to Green Road & Towin Services, Inc.; and when he failed to disclose the Township as a source of income onja Statement of Financial Interests filed for the 2014 calendar year, and filed an inaccurate 015 calendar year Statement of Financial Interests, by misdating the form. II. FINDINGS: Timothy J. Green ( "Green ") has served as a Supervisor for Smith Township (hereafter, "Township "), Washington County, from January 6, 2014, through the present. Green has been the appointed Township Secretary since January 2014. P.O. BOX 11470, HARRISBURG, PA 17108 -1470 • 717- 783 -1610 • 1- 800 - 932 -0936 • www.ethics.state.pa.us Green, 16 -014 Page 2 1. The Township does not maintain an official job description for the Secretary position; however, the Secretary position is responsible for the following: aa. Reviewing invoices; bb. Signing Township checks; cc. Signing Board of Supervisor meeting minutes; and dd. Signing Township documents (as needed). 2. The Township Secretary is compensated $100.00 a month for performing duties /responsibilities associated with the position. b. In addition to serving as the Township Secretary, Green has worked for the Township Road Department as a part -time equipment operator since February 2014. 1. Green works as an equipment operator for the Township on an as- needed basis only. 2. The Township is a Second Class Township governed by a three (3) Member Board of Supervisors (hereafter, "Board "). 3. The 2010 census reported the Township [population as] 4,476. a. Regular meetings were held on the second Monday of each month prior to 2016; however, since 2016 the Board meets on the third Monday of each month. 1. Special meetings are held on occasion throughout the year. 4. Official voting at Township meetings occurs via an "aye" or "nay" fashion after a motion is made and properly seconded. a. Abstentions or dissenting votes are not specifically documented in the minutes. 1. Township minutes normally note only that a motion was made, seconded, and carried. 5. The Township Treasurer, Michelle Meneely, audio records and takes notes at meetings to later generate the minutes. a. The official minutes are subsequently approved by the Board at the following meeting. b. Green, as Township Secretary, signs the minutes once they are approved to signify official approval. 6. The Board Chairman assembles a meeting packet for each Township Supervisor prior to each Board meeting. a. The packet normally includes an agenda, the prior month's meeting minutes, correspondences, and finance reports. Green, 16 -014 F-a 3 1. The finance reports are provided by the Township Treasurer and include the amounts of Township revenue and expenditure and General Fund & Payroll balances. 2. The finance reports do not include a listing of checks or bills to be approved for payment. 7. The Township Supervisors and the Township Treasurer hold signature authority over the financial accounts associated with the Township. a. Township checks are signed by the Township Treasurer, Township Secretary, and Board Chairman. 1. The Board Vice - Chairman signs checks in the absence of the Township Secretary or Board Chairman. b. Facsimile signature stamps are not utilized. 8. Day -to -day operations at the Township are managed by the Township Treasurer, Township Roadmaster, and Township Police Chief. a. The Township Treasurer is responsible for the accounts payable /receivable. b. The Township Treasurer is responsible for drafting Township checks issued as payment. C. Procedurally, the Township Treasurer contacts the Township Secretary to review the bills and to sign checks to be issued as payment. 1. The Township Secretary has historically been a Member of the Board. 2. Since 2014, Green has served as the Township Secretary. 9. At each regular meeting, the Board votes to approve payment of the bills, without having first officially reviewed what was to be paid. a. The Board is not provided with a listing of bills that are to be paid. b. Bills are available for review at any time by the Board/Township Supervisors. C. The Township Supervisor serving as the Township Secretary is the only Board Member who regularly reviews bills prior to payment being issued. d. The Board vote occurs after the Township Secretary reviews and initials approval of the invoices. THE FOLLOWING FINDINGS RELATE TO GREEN'S BUSINESS HOLDINGS AND THOSE OF HIS IMMEDIATE FAMILY. 10. Green and members of Green's immediate family own and operate a towing, road service, and auto repair business known as Green's Road & Towing, Inc. (hereafter, "G RT" a. GRT maintains offices located in the Township; Steubenville, Ohio; and Weirton, West Virginia. 1. The GRT [office located in the Township] is approximately one mile from the Township Municipal Building. Green, 16 -014 age 4 b. Pennsylvania Department of State Corporation Bureau records reflect that GRT, Entity No. 2884570, was incorporated on June 25, 1999. 1. Corporate filings do not list Green as an officer of the company. 11. Green is employed by GRT as the manager of the auto repair facility owned by GRT at its Township location. a. Although Green has the primary responsibility as the manager for GRT at its auto repair facility in the Township, he performs other duties for GRT when needed, including towing services. 12. In addition to his employment with GRT, Green and his spouse are the owners of Green's Collision, LLC, an auto body repair shop located in Hanover Township, Pennsylvania. a. Green's Collision, LLC is not affiliated with GRT. b. Pennsylvania Department of State Corporation Bureau records reflect that Greens Collision, LLC, Entity No. 6281589, was incorporated on August 19, 2015. 1. Corporate filings list Green as an organizer of the company. 13. Green disclosed on his Statements of Financial Interests ( "SFIs ") for the 2013, 2014, and 2015 calendar years his financial interest in GIRT and Green's Collision, LLC [as follows]. a. Green's SFIs for calendar years 2013, 2014, and 2015 reflect Green as holding a 9.8% financial interest in GRT. b. Green's SFI for calendar year 2015 reflects Green as president of and holding a 50% financial interest in Green's Collision, LLC. THE FOLLOWING FINDINGS RELATE TO GREEN'S OFFICIAL ACTIONS IN REVIEWINGIAPPROVING INVOICES FROM GRT, SERVING AS AN AUTHORIZED SIGNATORY ON TOWNSHIP CHECKS ISSUED TO GRT, AND PARTICIPATING IN VOTES TO APPROVE TOWNSHIP BILL LISTS/PAYMENTS TO GIRT IN RELATION TO VEHICLE REPAIRS. 14. The Township maintains vehicles for use by the Township Road Department and the Township Police Department. 15. The Township Road Department fleet consisted of ten (10) vehicles for the time period of 2014 to 2016. a. The vehicles were housed at the Township Garage (located across the street from the Township Municipal Building). b. The Township Police Department fleet consists of six (6) vehicles. 16. The Township did not have a formal procedure pertaining to the selection of auto repair services for Township vehicles /equipment until July 2016. a. Prior to July 2016, it was the practice of the Township Road Department, when selecting auto repair services, for an employee to inform the Township Roadmaster of a vehicle needing service or repair. Green, 16 -014 'gage 5 The Township Roadmaster, Supervisor Tom Schilinski, is a full -time employee, and was made aware by employees when a vehicle needed service. 2. Employees often made arrangements for vehicles to be repaired after advising the Township Roadmaster. b. There are three auto repair shops (not including repair shops affiliated with car dealerships) located within the Township: GRT, Wally's Auto Service and Collision ( "WASC "), and John W. Thomas and Sons Trucking ( "TS "). TS performed diesel and major heavy equipment repairs. C. The Township Road Department employees typically complete preventative maintenance (i.e., oil changes, grease -ups) in -House on Township vehicles. 17. Prior to 2014, the Township Road and Police Department vehicles [were sent to WASC for service /repairs]. a. The excepption was specialty repairs, such as diesel, for which vehicles were sent to TS. b. A majority of the Board had a friendship with WASC owner Brandon Kriznik ... prior to 2014. 1. Supervisor Schilinski, interviewed by State Ethics Commission investigators, stated that he had no explanation for why WASC was the sole vendor for vehicle repairs other than "politics" but confirmed that whomever "the supervisors were friends with got the business." 2. Former Supervisor Gerald Yacoviello, also interviewed, confirmed to State Ethics Commission investigators that he was friends with the owners of WASC, but did not know why GRT was never used by the Township. G. Prior to 2014, the Township Road Department employees made comments to Supervisor Yacoviello criticizing the amount of time it took WASC to service /repair Township vehicles. 18. Township records confirm that between 2009 and 2013, 96% of all vehicle repairs ($83,035.25) were completed by WASC. a. The remaining 4% were completed by TS. b. GRT was not utilized by the Township during this time frame. C. The following chart confirms vendors utilized by the Township for vehicle repairs: Year WASC °o of Twp. Auto Repair Business GRT % of Twp. Auto Repair Business TS % of Twp. Auto Repair Business 2009 8,4 8.54 1 o0 0 0 O o 0.00 D o 2010 10,660.38 92% 2011 2,541.54 97% D D o 06.30 0 2012 $26,527.53 0 0 0 0 0 0 0 a 2013 0 3.55 a 0 D o ,54 .72 1% Totals 80,171.54 96% 1 so.uu I U% 2,863.71 1 4N Green, 16 -014 age 6 19. In or about early 2013, Green declared his candidacy for a position on the Board. a. Green opposed incumbent Supervisor Yacoviello. b. Green defeated Yacoviello during the primary and was assured a seat on the Board prior to the November 2013 general election. 20. Around the time of the 2013 primary election, Supervisors Schilinski and Yacoviello discussed services for /repairs of Township vehicles. a. Yacoviello and Schilinski discussed that it was unfair that the Township did not utilize GRT for auto repair services. GRT had not done any repair services over the past five (5) years. b. The discussion concluded with Schilinski and Yacoviello agreeing to begin dividing work between WASC and GIRT. C. Neither Schilinski nor Yacoviello took any action to authorize vehicle repairs by Green /GRT. d. Township Road Department employees had also advised Township Supervisors of their dissatisfaction with WASC's services due to WASC not prioritizing Township work and poor turnaround time. 21. In early 2014, after taking office, Green, in his capacity as a part -time laborer and equipment operator, was assisting the Township Road Department with snow removal. a. At the end of the shift, Township Road Department employees informed Green that they would be recommending to the Board that Green's company, GRT, be used for vehicle repairs. b. Green was receptive to the Township Road Department's suggestion. 22. Beginning in the latter part of January 2014, GRT began servicing Township vehicles. a. Township Road Department employees contacted Green directly by telephone, asking him to assess a vehicle for repair at the Township Garage. b. Green would assess the vehicle to determine whether it could be fixed in- house by the Township Road Department or by GRT. 23. Green did not propose, lobby, or direct the Township Road Department to have vehicles /equipment repaired at GRT. 24. Between at least 2009 and 2014, Township Police Department vehicles were also serviced by WASC. a. Prior to Green taking office in Januar)r 20'14, the past practice of the Smith Township Police Department ("STPD') when selecting auto repair services was for the STPD Police Chief and/or Officer George Galish to arrange service /repairs with WASC. 1. The Township Road Department performed preventative maintenance (i.e,, oil changes, grease -ups) on STPD vehicles. Green, 16 -014 �7 25. After Green took office in 2014, Officer Galish observed that Township Road Department vehicles were now being repaired at GRT. a. Officer Galish began alternating vehicle servicelrepairs between GRT and WASC after seeing Township Road Department vehicles in the lot of GRT. b. Repairs at GRT were scheduled directly with Green by Galish or the STPD Police Chief. 1. Green, as the GRT repair shop manager, oversaw or personally worked on Township vehicle repairs. C. The STPD was not considering the use of GRT for vehicle repairs prior to observing the Township Road Department vehicles being repaired at GRT. 26. After Green took office in January 2014, repairs to Township Road Department and STPD vehicles were divided among WASC, GRT, and TS. a. Between 2014 and June 2016, the percentage of vehicle repairs completed by GRT ranged from 20% in 2014 to 43% in 2016 through June. 27. The following reflects the distribution of payments by the Township for vehicle repairs from 2014 through June 2016: Year WAS % of Twp. Auto Repair Business GRT % of Twp. Auto Repair Business TS % of Twp. Auto Repair Business 2014 9 763.90 48 a 4,040.08 20 0 6,683,40 32 0 2015 5,792. 4$ 0 4,67 .79 3 0 ,6 5. 9 3 0 2015 $4,106.83 39% 4,461.83 43% 1,$9 .3 8 0 Totals $19,662.83 46% 13,174.70 30% $10,189.90 1 24% 28, From January 2014 to June 2016, Green, as [a Township Supervisor /the Township Secretary], regularly reviewed invoices, signed as a Township signatory on check payments issued by the Township to GRT, and voted affirmatively to pay the monthly bills that included payments to GRT, as detailed in the chart below: Check Check Invoice No. Amount Township GRT Invoice Reviewed Meeting Date No. Check Endorsed Signatures 02-03-12f— - 75.00 A 32750 -T 4 and Card Yes Yes 03 -03- 4 re -it - 75.00 A 327 7- 3- 7- 4 Card Yes 05-28-14 6749 - an $690, 4 MM, tamp 63623- 6-16-14 #634110 -WBL Yes 06-23-14 6778 63714 $743.90 MM TS, TG Stamp 637 4- 7-21-14 Yes 07-09-14 6796 64133 53.40 tamp 64 3- 7-21-14 Yes 08 -06 -14 831 -blank- 722.46 mm, tamp 6422 -T 8 -18 -14 #32731 -TG Yes —9-T5-14 09-15-14 6866 64865 138.53 MM tamp 64865- Yes 09 -3 - 4 9 622, 654 332.23 , tamp 6543 - 0 -20 -14 #32622 -TG Yes 0- 4- 4 6 670 $102.41 MM, tamp 65670- 0 -20- 4 Yes 09 -23- 4 9 -blank- 363.0 imm, tamp 6597 - TG 10-20-14 #65988 -TG Yes #65861 -TG #65810 -TG Green, 16 -014 age 8 Check Check Invoice No. Amount Township GRT Invoice Reviewed Meeting Date No. Check Endorsed Si natures 11-12-14 6946 66214, 66197, 3 .39 tamp --#66214- -1 7- 66086 #66197 -TG Yes #66086 -TG -22- 4 6993 66828, 6 75 43 .25 tamp #66828-TG -5 -15 #66675 -TG Yes 01-20-15 7022 66998 $187.40 IVIM, TS, TG Stamp Invoice Unavailable 2-17-15 Yes 02-04-15 7039 35321 35247, $550.24 MM, TS, Stamp 3532 - G 2- 7- 5 67261, 67245 #35247 -TG Yes #67261 -TG #67245 -TG 03 -0415 70 7 67379, 67399 660.53 WITS, AG Stamp 67379- 3-16-15 #67399 -TS Yes 03-16-T5— 7079 67797, 67796 0.00 IVIM, TS, AG Stamp 67797- 3- 6 -15 #67796 -TS Yes 04-29-T5-- 7 16 68407,68412 $382.03 MM, tamp #68407- 5- 8- 5 #68412 -TS Yes 06 -09- 5 —7166- - an - 43.00 M , T tamp 68942- 6- 5 -15 Yes 09 -16- 5 7272 899 0, 70180, $1,37U.97 MM, T-8, tamp 699 -T 9-21-15 70085 #70180 -TS Yes #70085 -TS 11 -24- 5 735 -blank- 24 .74 MM, TS, TG Stamp 7 338- 12 -21 -15 _ #71508 -JW TS Yes 12-2T--f 5 7387 71748 7T764 1, 27.88 M , T tamp --97-1748-H 12 -21 -15 71701, 71656, #71764 -RH Yes 71857 #71701 -RH, TS #71656 -JW, TS #71857 -RH 0 -20 -16 7413 72078, 72052 4 0.45 M, T , T tamp P-2- —07-8-- , M , 2 -15- 6 #72052 -TS MK Yes 02-03-16 7431 003 , 72189, ,990.29 IVIM, TS, TG tamp #4003 -TS' 2 -15- 72376, 72264 #72189 -RH,TS Yes #72376 -RH,TS #72264 -RH TS 02 -17- 7452 72486, 72539 53.82 MMF TS, TG Stamp 72486- 3 -21 -16 #72539 -JW Yes 03 -02- 6 746 72605, 38034 606.5 M, TS, T tamp 72605- 3 -2 -16 #38034 -TS, TG Yes 03-30-16 7503 72950 27.77 IVIM, T tamp 72950- 4-18-16 Yes 04 -2 - 6 7 29 7304 4.15 MM tamp 7304 - B 6 Yes Yes 05-11-16 7556 73579 295.54 M tamp 73579- H 5- 6- 6 Yes -25 -16 7572 73683,73676 573.38 MM, tamp 7368 - 6-20-16— #73678 -JW Yes 6 7591 90564 90.28 M, tamp 7392 -JW 6-20-T6 Yes Total $13,174.70 Initials: AU- Anthony vlantrancesco, Jvv -.lone vvPUams, ivtivr- ivrierteie urreneety, rvir\- ivucjiaei rvvuuwani, TS- Thomas Schilinski, WBL- Bernie Larue, RH -Ron Held Stamp- Green's Towing Service, Inc. - f=irst Commonwealth Bank - Oakdale, PA 29. From January 2014 to June 2016, Green, as a Township Supervisor /the Township Secretary, initialed or signed twenty -seven (27) of the fifty -eight (58) GRT invoices, signifying his review and approval for payment. a. The total dollar amount of the invoices approved by Green was $4,115.21. b. The total dollar amount of the invoices] initialed /signed by Green ($4,115.21 of the $13,174.70) represented 31 % of the total amount of the GRT invoices issued to the Township. Green, 16 -014 Page 9 30. From January 2014 to June 2016, Green, as a Township Supervisor /the Township Secretary, signed twenty -five (25) of the twenty -eight (28) Township checks issued to GRT. a. The amount approved for payment by Green totaled $12,361.17. b. The amount approved for payment by Green ($12,361.17 of the $13,174.70) represented 94% of the total amount issued to GRT by the Township. 31. From January 2014 to June 2016, Green, as a Township Supervisor, voted affirmatively on thirty (30 occasions to approve payment of the monthly bills, which included payments to MT andlor to the Township credit card that was utilized for payments to GRT. 32. Since 2003, the Township has contracted with a certified public accounting firm, Cypher & Cypher, to perform audits of its financial statements and payroll. a. The audit review covers financial statements from the most recent calendar year. b. The audits are normally performed in or around February of each year. C. The auditors provide verbal recommendations based on their findings throughout the course of the audit but do not always memorialize the recommendations in their final report. d. The auditors provide a formal presentation of the audit findings to the Board upon completion of the audit. 33. In or around February 2015, Cypher & Cypher initiated an audit of the Township's 2014 financial statements. a. The audit report dated February 10, 2015, noted a potential conflict of interest for Green in his actions of reviewing GRT invoices, signing Township check payments to GRT, and voting to approve the respective payments. b. The auditors advised Township Treasurer Michelle Meneely that Green should stop approving GRT invokes, of which Meneely later informed Green. 34. Green was advised by Meneely of the auditors' recommendation to stop reviewing /initialing GRT invoices in his capacity as the Township Secretary. a. GRT issued thirty -three (33) invoices to the Township between March 2015 and June 30, 2016, after the receipt of the audit report. b. Green initialed his approval of three (3) of the thirty -three (33) invoices after the auditors' recommendation. C. [Following the auditor review, Green signed] all fifteen (15) checks issued to GRT between April 2015 and June 2016. 35. The Board held a special meeting on July 1, 2016, for the purpose of reviewing and establishing a Township policy for the consideration of contracts. a. The meeting was attended by Supervisors Anthony Gianfrancesco and Schilinski; Township Solicitor Gary Sweat; and Township Treasurer Meneely. Green was absent from the meeting. Green 16 -014 ag 'e -10 b. The meeting was prompted by the initiation of the investigation tin the instant matter] by the Investigative Division of the State Ethics Commission. 36. During the July 1, 2016, meeting, the Board approved a policy relating to the selection of vendors to repair Township vehicles. The approved policy included the following: a. The Township Roadmaster will authorize vehicle repair requests and assign the repairs to a third party. In the absence of the Township Roadmaster, the Board Vice - Chairman will make the decision. b. Green cannot make a referral, approve a work order, vote on paying himself, or sign any checks to GRT. C. Green will abstain from motioning to pay any GRT bills and file a memo with the explanation for his abstention. 37. During the July 1, 2016, meeting, the Board took action to seek reimbursement from GRT for work performed between 2014 and June 2016, less the cost of parts. a. The Board directed Township Treasurer Meneely to compile a summary of all GIRT invoices issued to the Township for work performed from the date Green took office, to the present, for review by the Supervisors prior to the July 2016 meeting, and if possible, to identify materials, supplies, and parts costs. b. The Board approved that once the actual cost of parts was identified, the Board would review and make a motion at the appropriate time to refund GRT the amounts for parts. 38. During the July 1, 2016, special meeting, Township Solicitor Sweat noted the following regarding Green's company performing repairs to Township vehicles: a. Sweat announced that Green was being investigated by the State Ethics Commission and that he (Sweat) had been unaware of Green reviewing GRT invoices and/or signing Township check payments to GRT. b. Sweat commented that he would have advised the Board and Green accordingly, had he known of the situation prior to being notified by the Investigative Division. C. Sweat advised that the Board establish a policy to specify how the Township Road Department and STPD are to decide where to take a vehicle for repairs. d. Sweat reported that Green contacted him (Sweat) regardingg the matter into which the State Ethics Commission was conducting a preliminary inquiry, and that Sweat advised Green how payment of bills and awarding of jobs needed to be handled when a Township Supervisor has a business interest in that entity and could derive an economic benefit from the business relationship with the Township. e. Sweat reported that Green would be issuing a check to the Township representing reimbursement of the full amount charged to the Township by GRT for auto repair services, labor, and costs of any supplies. Green 16 -014 Fsage l 1 f. Sweat also reported that Green, in fairness, would like to be reimbursed for the costs for parts. g. Sweat reported his belief that Green did not do anything intentional, nor did he (Sweat) believe that Green ever referred work to his business or insisted the Township give him work. 39. Township Treasurer Meneely's review of the GRT invoices covering the time period of 2014 to 2016, as directed by the Board, determined the total cost for parts to be $9,396.48 and the total cost of labor to be $3,778.22, as reflected in the total amount paid by the Township to GRT of $13,174.70. a. Meneely provided Green with her breakdown of the costs for parts and labor. 40. Green submitted two GRT payment checks to Township Treasurer Meneely, who in turn deposited the checks into the Township's general fund account, as reflected in the chart below: a. The payments made by Green represented reimbursement to the Township for parts (check no. 16112) used in the repair of Township vehicles and labor (check no. 16068). 41. At the Board's September 19, 2016, regular meeting, Supervisor Gianfrancesco motioned, seconded by Supervisor Schilinski, to refund GRT for the full cost of parts from GRT invoices for the time period of January 1, 2014, to the present, in the amount of $9,396.48. a. The motion carried with Green abstaining. 42. The Township remitted check no. 7698, dated September 27, 2016, made payable to GRT in the amount of $9,396.48. a. The check was signed by Township Treasurer Meneely and Township Supervisors Schilinski and Gianfrancesco. b. Township check no. 7698 was negotiated by GRT at First Commonwealth Bank on October 7, 2016. The back side of the check bears a GRT stamp signifying its endorsement as being negotiated. 43. Since the July 1, 2016, Board action, the Township Road Department employees have informed Schilinski (Township Roadmaster) of requested repairs /services for Township Road Department vehicles. a. Schilinski authorizes the request and instructs the employee where to send the vehicle for repairlservice. b. The Township Road Department employee schedules the repair /service at the auto repair shop, per the direction of the Township Roadmaster. C. The Township Road Department employee picks up the vehicle after being notified by the auto repair shop that the repair /service is complete. Check Date I Check No. moun I Signatures Deposited 07-2 $3778.22 1 Mary Ann Green U-1-16 08 -31- 6 6 2 9 396.48 1 Mary Ann Green 9-1-16 Total Paid $13,174.70 a. The payments made by Green represented reimbursement to the Township for parts (check no. 16112) used in the repair of Township vehicles and labor (check no. 16068). 41. At the Board's September 19, 2016, regular meeting, Supervisor Gianfrancesco motioned, seconded by Supervisor Schilinski, to refund GRT for the full cost of parts from GRT invoices for the time period of January 1, 2014, to the present, in the amount of $9,396.48. a. The motion carried with Green abstaining. 42. The Township remitted check no. 7698, dated September 27, 2016, made payable to GRT in the amount of $9,396.48. a. The check was signed by Township Treasurer Meneely and Township Supervisors Schilinski and Gianfrancesco. b. Township check no. 7698 was negotiated by GRT at First Commonwealth Bank on October 7, 2016. The back side of the check bears a GRT stamp signifying its endorsement as being negotiated. 43. Since the July 1, 2016, Board action, the Township Road Department employees have informed Schilinski (Township Roadmaster) of requested repairs /services for Township Road Department vehicles. a. Schilinski authorizes the request and instructs the employee where to send the vehicle for repairlservice. b. The Township Road Department employee schedules the repair /service at the auto repair shop, per the direction of the Township Roadmaster. C. The Township Road Department employee picks up the vehicle after being notified by the auto repair shop that the repair /service is complete. Green, 16 -014 Page 12 d. The Township Road Department employee receives the bill from the auto repair shop at the time of pick -up or the bill is mailed to the Township. 1. The employee submits the bill to Township Treasurer Meneely for payment processing. 44. Since July 2016, a Township Police Officer, mainly Officer Galish, will inform the Township Police Chief of a needed repairlservice for a Township Police vehicle. a. The Township Police Chief will instruct the Township Police Officer to have the vehicle repaired, without directing the Township Police Officer where to send the vehicle. The Township Police Officer decides where to send the vehicle for repair. aa. Vehicles under warranty are sent to the Ford dealership for repairs without consideration of any other auto repair shop. 2. Green has not recommended or directed that the STPD send vehicles to GRT. b. The Township Police Officer is responsible for scheduling the repair, picking . up the vehicle, and ensuring the Township is billed by the auto repair shop. The July 1, 2016, policy notes that the Township Roadmaster will authorize vehicle repair requests and assign the repair to a third party. 2. The Township Police Chief has not been formally advised of the July 1, 2016, policy. 45. From July 1, 2016, to January 13, 20'17, the Township made payments totaling $5,975.45 for auto repair services. a. [The] Township made payments totaling $4,847.65 to WASC (81% of the total payments for auto repairs). b. The Township made payments totaling $145.75 to TS (2.5% of the total payments for auto repairs). C. The Township made ayments totaling $982.05 to GRT (16.5% of the total auto repair payments 46. From July 2016 to January 2017, Green, as a Township Supervisor /the Township Secretary, did not review Invoices, sign as a Township signatory check payments issued by the Township to GRT, or vote affirmatively to pay the monthly bills that included payments to GRT, as detailed in the chart below: Check Check Description Amount Township GRT Invoice Reviewed Meeting Date No. I Check Endorsed Action Signatures 9-28-16 7698 B R E 9,39 .48 MM, TS, AG tamp RE EM 0- 7- 6 PARTS Abstained 0- 2 -16 8009 754 38 .49 MM, TS, A tamp 75422 -no initial 0- T2---T6 Abstained 1 - 94 6 8030 75976 25 .00 TS, A tamp 7597 - 1 -2 - 6 Abstained _T2_-_0_7-T6_ 8059 7 3 7, 76329 4 5 MM, T, AG Stamp -TS, RH 2 -19- 6 #76329 -TS Abstained Green 16 -014 age l3 47. On October 27, 2016, Green was interviewed by representatives of the Investigative Division, during which Green asserted the following: a. Green was trained in the Township Secretary duties /responsibilities by the Board Chairman (Schilinski) and Township Treasurer (Meneely). b. Green was unfamiliar with the process of how the Township Road Department decided where to have Township vehicles repaired. C. Green denied having attempted to influence Township decisions in deciding where to send a vehicle for repair. d. Green denied directing the Township Road Department to send vehicles to GRT for repairs. 1. The Township Road Department has asked for input from Green on repairs, Green advised which repairs he was capable of completing, subsequently performed the repair at GRT, and billed the Township for the work. e. Green believed the Township Police Chief decided where to send Township Police Department vehicles for repairs. f. Green denied having attempted to influence the Township Police Department as to where to send a vehicle for repair. g. Township Police Officers have stopped unannounced at GRT after business hours, and asked Green to complete a minor repair (i.e., change a headlight, repair a. flat tire) which Green performed and subsequently billed to the Township. h. Green was unable to explain why in 2014 the Township began sending vehicles to GRT for repair. 1. Green believed his election as a Township Supervisor gave a perception to the Township employees that repairs should be sent to GRT. L Green did not believe there would be an issue with him reviewing /approving payment of bills from GIRT since he had only a "small share" in GRT. j. Green did not recall having been advised by the auditors or any Township official to stop reviewing /approving bills from GRT, or signing Township checks made payable to GRT, until 2016 when the Township Solicitor advised him to cease such actions. 1. Green recalled having signed a GRT bill sent to the Township and as the Township Secretary reviewing /approving payment of the bill. Green was then advised by Meneely to no longer review /approve bills as the Township Secretary that he personally submitted to the Township from GRT. k. Green admitted to having made a mistake by reviewing GRT bills and approving their respective Township payments. 8092 765 2, 76530, 7 563 8.41 MM, TS, AG Stamp 765 2- 1-3-17 1 I #76530 -T5' Abstained #76563 -TS RH Total 400,378.53 47. On October 27, 2016, Green was interviewed by representatives of the Investigative Division, during which Green asserted the following: a. Green was trained in the Township Secretary duties /responsibilities by the Board Chairman (Schilinski) and Township Treasurer (Meneely). b. Green was unfamiliar with the process of how the Township Road Department decided where to have Township vehicles repaired. C. Green denied having attempted to influence Township decisions in deciding where to send a vehicle for repair. d. Green denied directing the Township Road Department to send vehicles to GRT for repairs. 1. The Township Road Department has asked for input from Green on repairs, Green advised which repairs he was capable of completing, subsequently performed the repair at GRT, and billed the Township for the work. e. Green believed the Township Police Chief decided where to send Township Police Department vehicles for repairs. f. Green denied having attempted to influence the Township Police Department as to where to send a vehicle for repair. g. Township Police Officers have stopped unannounced at GRT after business hours, and asked Green to complete a minor repair (i.e., change a headlight, repair a. flat tire) which Green performed and subsequently billed to the Township. h. Green was unable to explain why in 2014 the Township began sending vehicles to GRT for repair. 1. Green believed his election as a Township Supervisor gave a perception to the Township employees that repairs should be sent to GRT. L Green did not believe there would be an issue with him reviewing /approving payment of bills from GIRT since he had only a "small share" in GRT. j. Green did not recall having been advised by the auditors or any Township official to stop reviewing /approving bills from GRT, or signing Township checks made payable to GRT, until 2016 when the Township Solicitor advised him to cease such actions. 1. Green recalled having signed a GRT bill sent to the Township and as the Township Secretary reviewing /approving payment of the bill. Green was then advised by Meneely to no longer review /approve bills as the Township Secretary that he personally submitted to the Township from GRT. k. Green admitted to having made a mistake by reviewing GRT bills and approving their respective Township payments. Gre--el n 16 -014 ag4 48. Green, a public official in his capacity as a Township Supervisor, utilized the authority of his public position /office for the private pecuniary benefit of GRT when he reviewed and approved invoices from GRT, a business with which he and his immediate family are associated; when he served as an authorized Township signatory on Township checks issued to GRT; and when he voted affirmatively to approve Township monthly bill lists /payments which included payments to GRT. a. Green issued payment of $3,778.22 to the Township which constituted labor costs and profit. THE FOLLOWING FINDINGS ARE IN RELATION TO DISCREPANCIES FOUND ON GREEN'S STATEMENT OF FINANCIAL INTERESTS FORMS. 49, Section 1104(a) of the State Ethics Act sets forth that each public official shall file a Statement of Financial Interests ( "SFI ") for the preceding calendar year no later than May 1 of each year that he holds such position and of the year after he leaves such position. a. Green was required to file SFIs for calendar years 2014 and 2010 as a Township Supervisor. 50. In June 2016, an SFI compliance review was conducted at the Township Municipal Building by the Investigative Division of the State Ethics Commission. 51. The compliance review confirmed the following SFIs on file at the Township for Green: Calendar Year Date on Form an i ate) 2014 01/23/15 2015 01/13116. 52. Green disclosed the following information regarding direct and indirect sources of income and his business interests: 2013: Line 10, Direct/Indirect Sources of Income: GRT Line 13, Office, Directorship or Employment in any Business: GRT - Manager Line 14, Financial Interest in any Legal Entity in Business for Profit: GRT 9.8% 2014: Line 10, Direct/Indirect Sources of Income: GRT Line 13, Office, Directorship or Employment in any Business: GRT- Manager Line 14, Financial Interest in any Legal Entity in Business for Profit: GRT 9.8% 2015: Line 10, Direct/Indirect Sources of Income: GRT, Greens Collision, LLC Line 13, Office, Directorship r Employment in any Business: GRT - Manager, Greens Collision, LLC - President Line 14, Financial Interest in any Legal Entity in Business for Profit: GRT 9.8 %, Greens Collision, LLC 50% 53. Block 10 of the SFI requires the disclosure of direct or indirect sources of income for $1,300 or more in gross income. a. Green's 2014 W -2 from the Township reflects income received of $3,370.20. Green, 16 -014 age 15 b. Green failed to disclose income received from the Township on his 2014 calendar year SFI, dated January 23, 2015. 54. Block 7 requires the listing of the prior calendar year for which one is filing a form. All information on an SFI from blocks 8 to 15 pertains to the calendar year designated in block 7. a. Green mistakenly listed "2016" in block of his SFI, dated January 13, 2016. b. The correct entry for block 7 was 2015. III. DISCUSSION: As a Supervisor for Smith Township ( "Township "), Washington County, from January 6, 2014, through the present, Respondent Timothy Green, also referred to herein as "Respondent," "Respondent Green," and "Green," has been a public official subject to the provisions of the Public Official and Employee Ethics Act ( "Ethics Act "), 65 Pa.C.S. § 1101 et se . The allegations are that Green violated Sections 1103(a), 1104(a), 1104(d), 1105(a), and 1105(b)(5) of the Ethics Act when he utilized the authority of his public position /office, resulting in a pecuniary benefit to himself, members of his immediate family and/or a business with which he /members of his immediate family are associated, namely Green Road & Towing Services, Inc., when he participated in discussions and actions of the Township Board of Supervisors, including regularly reviewing /approving invoices from Green Road & Towing Services, Inc. issued to the Township concerning ,vehicle repairs; when he served as an authorized Township signatory on Township checks issued to Green Road & Towing Services, Inc.; when he voted affirmatively to approve Township monthly bill lists /payments which included payments to Green Road &Towing Services, Inc.; and when he failed to disclose the Township as a source of income on a Statement of Financial Interests filed for the 2014 calendar year, and filed an inaccurate 2015 calendar year Statement of Financial Interests by misdating the form. Pursuant to Section 1103(a) of the Ethics Act, a public official /public employee is prohibited from engaging in conduct that constitutes a conflict of interest: § 1103. Restricted activities (a) Conflict of interest. —No public official or public employee shall engage in conduct that constitutes a conflict of interest. 65 Pa.C.S. § 1103(a). The term "conflict of interest" is 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 Green 16 -014 6 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. 65 Pa.C.S. § 1102. Section 1103(a) of the Ethics Act prohibits a public official /public employee from using the authority of public office /employment or confidential information received by holding such a public position for the private pecuniary benefit of the public officiallpublic employee himself, any member of his immediate family, or a business with which he or a member of his immediate family is associated. Section 1104(a) of the Ethics Act provides that each public official/public employee must file a Statement of Financial Interests (°SFI ") for the preceding calendar year, each year that he holds the position and the year after he leaves it. Section 1104(d) of the Ethics Act provides that no public official shall be allowed to take the oath of office, or enter or continue upon his duties, nor shall he receive compensation from public funds, unless he has filed an SFI as required by the Ethics Act. Section 1105(a) of the Ethics Act provides that the SFI shall be filed on the form prescribed by this Commission; that all information requested on the form shall be provided to the best of the knowledge, information and belief of the filer; and that the form shall be signed under oath or equivalent affirmation. Subject to certain statutory exceptions not applicable to this matter, Section 1105(b)(5) of the Ethics Act requires the filer to disclose on the SFI the name and address of any direct or indirect source of income totaling in the aggregate $1,300 or more. As noted above, the parties have submitted a Consent Agreement and Stipulation of Findings. The parties' Stipulated Findings are set forth above as the Findings of this Commission. We shall now summarize the relevant facts as contained therein. The Township Board of Supervisors ( "Board ") consists of three Members. A Township Supervisor ( "Supervisor ") has historically been the Township Secretary ( "Secretary'). The Secretary's responsibilities include reviewing invoices and signing Township checks. The Secretary is compensated $100.00 per month for performing duties /responsibilities associated with the position. Prior to each regular meeting of the Board, the Board Chairman assembles a meeting packet for each Supervisor. The Board is not provided with a listing of the bills that are to paid. Bills are available for review by the Supervisors at any time. The Supervisor serving as the Secretary is the only Board Member who regularly reviews the bills prior to payment being issued. At each regular meeting, the Board votes to approve payment of the bills without first officially reviewing what is to be paid. The Board vote occurs after the Secretary reviews and initials approval of the invoices. The Township Treasurer ( "Treasurer ") is responsible for drafting Township checks issued as payment. The Supervisors and the Treasurer hold signature authority over the financial accounts associated with the Township. Township checks are signed by. the Treasurer, the Secretary, and the Board Chairman. The Board Vice - Chairman signs checks in the absence of the Secretary or the Board Chairman. Procedurally, the Treasurer contacts the Secretary to review the bills and sign checks to be issued as payment. Green has served as a Supervisor from January 6, 2014, through the present. Since 2014, Green has also served as the Secretary. In addition to serving as the Green 16 -014 aT B n 7 Secretary, Green has worked for the Township Road Department ( "Road Department ") as a part-time equipment operator on an as- needed basis since February 2014. Green and members of his immediate family own and operate a towing, road service, and auto repair business known as Green's Road & Towing, Inc. ( "GRT"). Green is employed by GRT as the manager of an auto repair facility that GRT owns in the Township. The GRT auto repair facility is located approximately one mile from the Township Municipal Building. In addition to GRT, there are two other auto repair shops in the Township which are not affiliated with car dealerships, namely Wally's Auto Service and Collision ( "WASC ") and John W. Thomas and Sons Trucking ( "TS "). The Township maintains vehicles for use by the Road Department and the Township Police Department ( "Police Department "). Road Department employees typically complete preventative maintenance for Township vehicles, such as oil changes and grease -ups, in- house. Until July 2016, the Township did not have a formal procedure pertaining to the selection of vendors for repairs for Township vehicles or equipment Prior to July 2016, it was the practice of the Road Department for an employee to inform the Township Roadmaster ( °Roadmaster ") of a vehicle needing repairs. Employees often made arrangements for vehicles to be repaired after advising the Roadmaster. The Township Police Chief ( "Police Chief ") or Township Police Officer George Galish ( "Officer Galish') made arranqements with WASC for service /repairs for Police Department vehicles. Prior to 2014, a majority of the Board, including then- Supervisor Gerald Yacoviello ( "Yacoviello "), had a friendship with WASC owner Brandon Kriznik. The Road Department and Police Department vehicles were sent to WASC for repairs except for vehicles needing specialty /diesel repairs, which were sent to TS. Between 2009 and 2013, 96% of all Township vehicle repairs were performed by WASC, and the rest were performed by TS. Prior to 2014, the Road Department employees made comments to Supervisor Yacoviello criticizing the amount of time it took WASC to servicelrepair Township vehicles. In or about early 2013, Green declared his candidacy for the seat on the Board held by Yacoviello. Around the time of the 2013 primary election, Yacoviello and Supervisor Tom Schilinski ("Schilinski"), who also served as Roadmaster, discussed repairs of Township vehicles. Yacoviello and Schilinski discussed that it was unfair that the Township did not utilize GRT for auto repair services, and they agreed to begin dividing work between WASC and GRT. Neither Yacoviello nor Schilinski took any action to authorize vehicle repairs by GreenIGRT. Green defeated Yacoviello during the primary and was assured a seat on the Board prior to the November 2013 general election. In early 2014, after taking office as a Supervisor, Green was assisting the Road Department with snow removal in his capacity as a part -time laborer and equipment operator. At the end of the shift, Road Department employees informed Green that they would be recommending to the Board that Green's company, GRT, be used for vehicle repairs. Green was receptive to the suggestion. Beginning in the latter part of January 2014, GRT began servicing Township vehicles. Green did not propose, lobby, or direct the Road Department to have vehicles or equipment repaired at GRT. Road Department employees would contact Green directly by telephone and ask him to assess a vehicle for repair at the Township Garage, and he would assess the vehicle to determine whether it could be fixed by the Road Department in -house or by GRT. After Green took office in 2014, Officer Galish observed that Road Department vehicles were now being repaired at GRT, and he began alternating service /repairs for vehicles between GRT and WASC. Repairs at GRT were scheduled directly with Green by Officer Galish or the Police Chief. Green 16 -014 image 8 Between 2014 and June 2016, repairs to Road Department and Police Department vehicles were divided among WASC, GRT, and TS. During that time period, the percentage of vehicle repairs completed by GRT ranged from 20% in 2014 to 43% in 2016 through June. Green, as the GRT repair shop manager, oversaw or personally worked on Township vehicle repairs. From January 2014 through June 2016, the Township made payments totaling $13,174.70 to GRT for repairs to Township vehicles. During this time period, Green, as a Supervisorlthe Secretary, initialed or signed twenty -seven GRT invoices totaling $4,115.21, which signified his review and approval of the invoices for payment. Green, as a Supervisor /the Secretary, signed twenty -five Township checks totaling $12,361.17 that were issued to GRT. As a Supervisor, Green voted affirmatively on thirty occasions to approve payment of monthly bills that included payments to GRT and/or the Township credit card utilized for payments to GRT. Since 2003, the Township has contracted with a certified public accounting firm, Cypher & Cypher, to perform audits of the Township's financial statements and payroll. The audit is normally performed in or around February of each year and covers financial statements from the most recent calendar year. The auditors provide verbal recommendations based on their findings throughout the course of the audit but do not always memorialize the recommendations in their final report. The auditors provide a formal presentation of the audit findings to the Board upon completion of the audit. In or around February 2015, Cypher & Cypher initiated an audit of the Township's 2014 financial statements. The audit report dated February 10, 2015, noted a potential conflict of interest for Green in his actions of reviewing GRT invoices, signing Township check payments to GRT, and voting to approve the respective payments. The auditors advised Township Treasurer Michelle Meneely ( "Treasurer Meneely ") that Green should stop approving GRT invoices. Treasurer Meneely later advised Green of the auditors' recommendation that he should stop reviewing /initialing GRT invoices in his capacity as the Secretary. Between March 2015 and June 30, 2016, GRT issued thirty -three invoices to the Township. Green initialed his approval of three of the thirty -three invoices, and he signed all fifteen Township checks issued to GRT between April 2015 and June 2016. On July 1, 2016, the Board held a special meeting for the purpose of reviewing and establishing a Township policy for the consideration of contracts. The meeting was prompted by the initiation of the Investigative Division's investigation in the instant matter. Supervisors Schilmski and Anthony Gianfrancesco ( "Gianfrancesco "), Township Solicitor Gary Sweat ( "Solicitor Sweat "), and Treasurer Meneely attended the meeting. Green was absent from the meeting. During the special meeting, the Board approved a policy relating to the selection of vendors to repair Township vehicles. The approved policy included that the Roadmaster will authorize vehicle repair requests and assign the repairs to a third party and that in the absence of the Roadmaster, the Board Vice - Chairman will make the decision. The approved policy further included that Green cannot make a referral, approve a work order, vote on paying himself, or sign any checks to GRT and that he will abstain from motioning to pay any GRT bills and file a memo with the explanation for his abstention. The Board also took action during the special meeting to seek reimbursement from GRT for work performed between 2014 and June 2016, less the costs for parts. The Board directed Treasurer Meneely to compile a summary of all GRT invoices issued to the Township for workperformed from the date Green took office to July 1, 2016, for review by the Supervisors prior to the July 2016 regular Board meeting. The Board further directed Treasurer Meneely to identify costs for materials, supplies, and parts if possible. The Green, 16 -014 X19 Board approved that once the actual cost of parts was identified, the Board would make a motion at the appropriate time to refund GRT the costs for parts. During the meeting, Solicitor Sweat reported that he had been contacted by Green and that Green would be issuing a check to the Township representing reimbursement of the full amount that GRT charged the Township for auto repair services, labor, and costs of any supplies. Sweat also reported that Green, in fairness, would like to be reimbursed for the costs for parts. Treasurer Meneely's review of GRT invoices covering the time period at issue determined the total cost of parts to be $9,396.48 and the total cost of labor to be $3,778.22 as reflected in the total amount of $13,174.70 paid to GRT by the Township. Treasurer Meneely provided Green with her breakdown of the costs for parts and labor, and he submitted to her two GRT checks totaling $13,174.70, which represented reimbursement to the Township for parts used in the repair of Township vehicles and labor. Treasurer Meneely deposited the checks into the Township's general fund account. At the Board's September 19, 2016, regular meeting, Supervisor Gianfrancesco motioned, and Supervisor Schilmski seconded, to refund GRT the amount of $9,396.48 for the full cost of parts from the GRT invoices for the time period at issue. The motion carried with Green abstaining. The Township issued a check dated September 27, 2016, made payable to GRT in the amount of $9,396.48. The check was signed by Treasurer Meneely and Supervisors Schilinski and Gianfrancesco. Since July 2016, a Road Department employee will inform the Roadmaster of requested repairs or service for a Road Department vehicle, and the Roadmaster will authorize the request and instruct the employee where to send the vehicle for repairs or service. The Road Department employee will schedule the repairs or service at the repair shop per the direction of the Roadmaster. A Township Police Officer ( "Police Officer ") will inform the Police Chief of needed repairs or service for a Police Department vehicle. The Police Chief will instruct the Police Officer to have the vehicle repaired, and the Police Officer will decide where to send the vehicle for repairs or service. From July 1, 2016, to January 13, 2017, the Township made payments totaling $5,975.45 for auto repair services, which included payments totaling $982.05 to GRT. During that time period, Green did not review invoices, sign as a Township signatory check payments issued by the Township to GRT, or vote affirmatively to pay the monthly bills that included payments to GRT. As for Green's SFIs, in June 2016 an SFI compliance review was conducted at the Township Municipal Building by the Investigative Division of the Commission. Green's SFIs for calendar years 2013 (Candidate) and 2014 and 2015 (Supervisor) were on file with the Township. Although Green's W _ 2 from the Township for 2014 reflects that he received income in the amount of $3,370.20 from the Township, he faded to disclose the Township as a source of income on his SFI for calendar year 2014. Green mistakenly listed "2016" in Block 7, "calendar year," on his SFI for calendar year 2015. Having highlighted the Stipulated Findin .9s and issues before us, we shall now apply the Ethics Act to determine the proper disposition of this case. The parties' Consent Agreement sets forth a proposed resolution of the allegations as follows: The Investigative Division will recommend the following in relation to the above allegations: a. That a violation of Section 1103(a) of the Public Official and Employee Ethics Act, 65 Pa.C.S. § 1103(a), occurred in relation to Green participating in discussions and actions of the Green, 16 -014 ag—e2 0 Smith Township Board of Supervisors, fincluding] regularly reviewing/approving invoices rom Green Road & Towing SServices, Inc. issued to the Township concerning vehicle repairs; serving as an authorized Township signatory on Township checks issued to Green Road & Towing Services, Inc.; and voting affirmatively to approve Township monthly bil lists /payments which included payments to Green Road & Towing Services, Inc.; which resulted in a pecuniary benefit to Green Road & Towing Services, Inc., a business with which he and/or members of his immediate family are associated. That a violation of Section 1104(a) of the Public Official and Employee Ethics Act, 65 Pa.C.S. § 1104(a), occurred when Green filed an inaccurate 2015 calendar year Statement of Financial Interests, by misdating the form. That a violation of Section 1105(b)(5) of the Public Official and Employee Ethics Act, 65 Pa.C.S. § 1105(b)(5), occurred when Green neglected to discllose the Township as a source of income on [a] Statement of Financial Interests filed for the 20f4 calendar year. The Investigative Division is not seeking an disgorgement pursuant [to] 65 Pa.C.S. § 1104(d) of the Ethics Act. 4. Green has previously made payment of $13,174.70 to Smith Township, exceeding the amount of any private pecuniary gain received by Green Road & Towing Services, Inc., as reflected in the attached Stipulation of Findings. 5. To the extent he has not already done so, Green agrees to file complete and accurate amended Statements of Financial Interests with Smith Township through the Pennsylvania State Ethics Commission, for the 2014 and 2015 calendar years within thirty (30) days of the issuance of the final adjudication in this matter. 6. Green agrees to not accept any reimbursement, compensation or other payment from Smith Township representing a full or partial reimbursement of the amount paid in settlement of this matter. 7. The Investigative Division will recommend that the State Ethics Commission take no further action in this matter; and make no specific recommendations to any law enforcement or other authority to take action in this matter. Such, however, does not prohibit the Commission from initiating appropriate enforcement actions in the event of Respondent's failure to comply with this agreement or the Commission's order or cooperating with any other authority who may so choose to review this matter further. Green, 16 -014 X21 Consent Agreement, at 2 -3. In considering the Consent Agreement of the parties, we accept the parties' recommendation for a finding that Green violated Section 1103(a) of the Ethics Act in relation to his participating in discussions and actions of the Board, including regularly reviewing /approving invoices from GRT issued to the Township concerning vehicle repairs; serving as an authorized Township signatory on Township checks issued to GRT; and voting affirmatively to approve Township monthly bill lists /payments which included payments to GRT; which resulted in a pecuniary benefit to GRT, a business with which he and /or members of his immediate family are associated. Green began serving as a Supervisor and as the Secretary in January 2014. The Secretary's responsibilities include reviewing invoices and signing Township checks. Green and members of his immediate family own and operate GRT, and Green is employed by GRT as the manager of CRT's auto repair facility located in the Township. Beginning in the latter part of January 2014, GRT began servicing Township vehicles. During the time period from January 2014 through June 2016, the Township made pa meats totaling $13,174.70 to GIRT for repairs to Township vehicles. Green used the authority of office when: (1) as a Supervisor /the Secretary, he initialed or signed twenty - seven GRT invoices totaling $4,115.21, which signified his- review and approval of the invoices for payment; (2) as a Supervisor /the Secretary, he signed twenty -five Township checks totaling $12,361.17 that were issued to GRT; and (3) as a Supervisor, he voted affirmatively on thirty occasions to approve payments of monthly bills that included payments to GRT and/or the Township credit card utilized for payments to GRT. Based upon the Stipulated FindinOs and the Consent Agreement, we hold that Green violated Section 1103(a) of the Ethics Act, 65 Pa.C.S. § 1103(a), in relation to his participating in discussions and actions of the Board, including regularly reviewing /approving invoices from GRT issued to the Township concerning vehicle repairs; serving as an authorized Township signatory on Township checks issued to GRT; and voting affirmatively to approve Township monthly bill lists /payments which included payments to GRT; which resulted in a pecuniary benefit to GRT, a business with which he and /or members of his immediate family are associated. Turning to the allegations regarding Green's SFIs, we hold that: (1) a violation of Section 1104(a)/1105(a) of the Ethics Act, 65 Pa.C.S. § 1104(a)/1105(a), occurred when Green filed an inaccurate 2015 calendar year SFI, by misdating the form; and (2) a violation of Section 1105(b)(5) of the Ethics Act, 65 Pa.C.S. §.1105(b)(5), occurred when Green neglected to disclose the Township as a source of income on an SFI filed for the 2014 calendar year. We note that the Investigative Division is not seeking any disgorgement of Green's Supervisor compensation pursuant to Section 1104(4) of the Ethics Act, 65 Pa.C.S. § 1104(d). We further note that per the Consent Agreement, the parties are in agreement that the payment Green previously made to the Township, as reflected in the Stipulated Findings, exceeds the amount of any private pecuniary gain received by GRT. As part of the Consent Agreement, Green has agreed to not accept any reimbursement, compensation or other payment from the Township representing a full or partial reimbursement of the amount paid in settlement of this matter. To the extent he has not already done so, Green has agreed to file complete and accurate amended SFIs with the Township, through this Commission, for the 2014 and Green, 16 -014 F a--g—e-2 2 2015 calendar years within thirty (30) days of the issuance of the final adjudication in this matter. We determine that the Consent Agreement submitted by the parties sets forth a proper disposition for this case, based upon our review as reflected in the above analysis and the totality of the facts and circumstances. Accordingly, per the Consent Agreement of the parties, Green is directed to not accept any reimbursement, compensation or other payment from the Township representing a full or partial reimbursement of the amount previously paid in settlement of this matter. To the extent he has not already done so, Green is directed to file complete and accurate amended SFIs with the Township, through this Commission, for the 2014 and 2015 calendar years by no later than the thirtieth (30th) day after the mailing date of this adjudication and Order. Compliance with the foregoing will result in the closing of this case with no further action by this Commission. Noncompliance will result in the institution of an order enforcement action. IV. CONCLUSIONS OF LAW: 1. As a Supervisor for Smith Township ( "Township "), Washington County, from January 6, 2014, through the present, Respondent Timothy Green ( "Green' has been a public official subject to the provisions of the Public Official and Empoyee Ethics Act ("Ethics Act"), 65 Pa.C.S. § 1101 et seg. 2. Green violated Section 1103(a) of the Ethics Act 65 Pa.C.S. 1'103(a)) in relation to his participating in discussions and actions of the Township Lard of Sit ervisors, including regularly reviewing /approving invoices from Green Road & Towing Services, Inc. issued to the Township concerning vehicle repairs; serving as an authorized Township signatory on Township checks issued to Green Road & Towing Services, Inc.; and voting affirmatively to approve Township monthly bill lists /pa ments which included payments to Green Road & Towing Services, Inc.; which resulted in a pecuniary benefit to Green Road & Towing Services, Inc., a business with which he and/or members of his immediate family are associated. 3. A violation of Section 1104(a)/1105(a) of the Ethics Act, 65 Pa.C.S. § 1104(a)/1105�a), occurred when Green filed an inaccurate 2015 calendar year Statement of Financial Interests, by misdating the form. 4. A violation of Section 1105(b)(5) of the Ethics Act, 65 Pa.C.S. § 1105(b)(5), occurred when Green neglected to disclose the Township as a source of income on a Statement of Financial Interests filed for the 2014 calendar year. In Re: Timothy Green, File Docket: 16-014 Respondent Date Decided: 3125117 Date Mailed: 3/31117 ORDER NO. 1711 As a Supervisor for Smith Township "Township "), Washington County, Timothy Green ( "Green ") violated Section 1103((a} of the Public Official and Employee Ethics Act ("Ethics Act'), 65 Pa.C.S. § 1103(a), in relation to his participating in discussions and actions of the Township Board of Supervisors, including regularly reviewing /approving invoices from Green Road & Towing Services, Inc. issued to the Township concerning vehicle repairs; serving as an authorized Township signatory on Township checks issued to Green Road & Towing Services, Inc.; and voting affirmatively to approve Township monthly bill lists /payments which included payments to Green Road & Towing Services, Inc.; which resulted in a pecuniary benefit to Green Road & Towing Services, Inc., a business with which he and /or members of his immediate family are associated. 2. A violation of Section 1104(a)/1105(a ) of the Ethics Act, 65 Pa.C.S. § 1104(a)/1105(a), occurred when Green filed an inaccurate 2015 calendar year Statement of Financial Interests, by misdating the form. 3_ A violation of Section 1105(b)(5) of the Ethics Act, 65 Pa.C.S. § 1105(b)(5), occurred when Green neglected to disclose the Township as a source of income on a Statement of Financial Interests filed for the 2014 calendar year. 4. Per the Consent Agreement of the parties, Green is directed to not accept any reimbursement, compensation or other payment from the Township representing a full or partial reimbursement of the amount previously paid in settlement of this matter. 5. To the extent he has not already done so, Green is directed to file complete and accurate amended Statements of Financial Interests with the Township, through the Pennsylvania State Ethics Commission, for the 2014 and 2015 calendar years by no later than the thirtieth (30th) day after the mailing date of this Order. 6. Compliance with paragraphs 4 and 5 of this Order will result in the closing of this case with no further action by this Commission. a. Noncompliance will result in the institution of an order enforcement action. BY THE COMMISSION, ' I �'-