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HomeMy WebLinkAbout80-575 WankoTO: FACTS: DISCUSSION: STATE ETHICS COMMISSION 308 FINANCE BUILDING HARRISBURG, PENNSYLVANIA 17120 March 13, 1980 ADVICE OF CHIEF COUNSEL John Wanko Vice President Pye Karr Ambler & Co., Inc. Thomas and Water Streets Jenkintown, PA 19046 RE: School Board Member Advice 4! 80 -575 On January 9, 1980, John Wanko, a school director, wrote this Commission for an opinion. He advised that his school district contracts for its busing with an independent contractor and that as a board member of the insurance firm of which he is employed has an opportunity of reviewing the bus contractor's insurance, and if he can im- prove the coverage or reduce the cost, he would then be awarded the business. The issue is whether a business associate of a school board member can negotiate an insurance contract with a contractor of the school board where the insurance is required by the school board. Section 3(c), which prohibits a public official or public employee from contracting with his or her governmental body unless there is an open and public process does not apply because the insurance is not with the governmental body. However, Section 3(d) of the State Ethics Act permits the State Ethics Commission to address other areas which relate to a conflict in interest. A conflict of interest exists when a public official re- presents two or more parties who have an interest reverse to eachother. Mr. Wanko does not directly represent the contractor with the school board, nor does it appear from the facts that he has any role in the bus contractor's decision. Wanko March 13, 1980 Page 2 CONCLUSION: DRM /af There is no conflict of interest under Act 170 for a school board director to serve on a school board where his business associate attempts to sell insurance to a busing contractor even when this contractor has business with the school district. Pursuant to Section 7(9)(ii), this 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, providing the requestor has disclosed truthfully all the material facts and committed the acts complained of in re- liance on the advice given. Personal appearance before the Commission and formal opinion will be issued upon your request, if you feel this reply does not suffice. This letter is a public record and will be made available as such. D1V] D RITTEN!IOUSE MORRISON Chief Counsel