HomeMy WebLinkAbout88-506 AndressSTATE ETHICS COMMISSION
308 FINANCE BUILDING
HARRISBURG, PA 17120
TELEPHONE: (7171 783-1610
February 8, 1988
ADVICE OF COUNSEL
Mr. Spencer Andress
650 Market Street 88 -506
Oxford, PA 19363
Re: Conflict of Interest, Borough Councilmember, Consulting Services to the
Borough
•
Dear Mr. Andress:
This responds to your letter of January 8, 1988, wherein you requested
advice from the State Ethics Commission.
Issue: Whether the State Ethics Act
presents any prohibitions or restrictions
upon a member of a borough council regarding either his participation in
awarding a consulting contract to a private company with which he is
associated or regarding his providing consulting services for the borough as
an employee of that consulting company with which he is associated.
Facts: In you advice request, you state that you are both a member and
president of the Borough Council of Oxford, Chester County. You state that
you are an employee of Magnox Pulaski, Inc., which is a foreign corporation
and the parent company of Magnox, Inc. D.E.
state that although you do not hold an equity�interestyinwMagnoxbPulask i, You
Inc., you are the corporate secretary. You also state that in your capacity
as president of borough council, you participated in discussions with various
federal and state officials as well as private individuals which resulted in a
contract between the borough and a Pennsylvania business corporation whereby
the borough would sell a portion of its land to the corporation for use as a
soft drink bottling plant. It is also stated by of the agreement, must perform certain other b as a
road construction work on the site prior to its conveyance, extending the
borough's water and sewer lines to the plant site and constructing a side
track from the existing Octarara railway line to the boundary of the premises.
As to the execution of the provisions of the contract, you note that the
borough will extend the sewer line to the property while the Chester Water
Authority will employ a contractor to extend the water line; the cost of these •
projects will be paid by a Business Infrastructure Development grant awarded
to the borough by the Commonwealth of Pennsylvania. Further, you state that
the side track construction will be paid by PennDot but the work will either
be performed by a contractor employed by the railroad or by the borough. You
then state that the borough manager has indicated that he is unable to perform
Mr. Spencer Andress
February 8, 1988
Page 2
his duties both as borough manager and as manager for the above
has resulted in the borough contemplating employing Magnox (D.E.) t i n Ma nox Inc.. (D.E.) toich
provide consulting services. In this regard,
project management services would be provided bbtu oohe y ohat a dhe h h e rsulting and
r
individuals who are employees of Magnox Pulaski, Inc. actin on
behalf of Magnox, Inc. (D.E.). You note that you would receive g
an employee of Magnox Pulaski, Inc., and further that the award your
an
as
consulting contract to them would not result in a change in your compensation.
You note that the monies paid by the borough would be received by Magnox, Inc.
(D.E.). You conclude by asking three questions concerning the applicability
of the Ethics Act to the above factual situation. First
public position would preclude qty
employees engaged in providing the consulting services v you from being one of the Magnox Pulaski, Inc.,
your
relative to this project. Secondly, 7a Magnox, Inc. (D.E.)
preclude either Magnox Pulaski Inc. orruMagnoxhInc., (D .E.) o from o acting d as the
consultant to the borough. Lastly, you inquire that if Magnox, Inc. (D.E.) is
engaged to provide the consulting services, what restrictions would be imposed
so as to comply with the Ethics Act.
,
Discussion: As counci l member and president of Oxford Borough, you are a
"public official" as that term is defined in the State Ethics Act. 65 P.S.
§402. As such, your conduct must conform to the requirements of the Ethics
Act.
Section 3(a) of the Ethics Act provides:
Section 3. Restricted activities.
(a) No public official or public employee shall use his
public office or any confidential information received
through his holding public office to obtain financial
gain
other than compensation provided by law for himself, a
member of his immediate family, or a business with which
he is associated. 65 P.S. 403(a).
Section 3(a) basically provides that a
public
public office or confidential information to obtain o a f financial grin o ot u his
than compensation as provided for by law for himself or a member of his
immediate family or a business with which he is associated, gain
provision, the Ethics Commission has determined that the use ofdofficesby a er
public official to obtain a gain or benefit for himself or a member of his
immediate family or a business with which he is associated which is not
provided for in law constitutes a "financial
provided for by law." These determinations been other than
e
to comoethetion h
Commonwealth Court of Pennsylvania which has affirmed theOrdersofthe
Commission. See Mc_ Cutcheon v. State Ethics Commission, 77 Pa. Commw. 529
(1983). See also Yocabet v. State Ethics Commission, Pa. Commw.
A.2d 536 (1987). — — , 531
Mr. Spencer Andress
February 8, 1988
Page 3
Within the above provision of law. no pub
position or any confidential information obtai
financial gain for himself or a member of his
with which he is associated. The Act defines
associated as follows:
Section 2
"Business
which the
family is
of stock.
lic official may use his
ned therein in order to obtain a
immediate family or a business
business with which one is
_ Definitions.
with which he is associated." Any business in
person or a member of the person's immediate
a director, officer, owner, employee or holder
65 P.S. 402.
As corporate secretary and employee, Magnox Puloski Inc., is a business
with which you are associated under the Ethics Act.
The Ethics Commission has determined that Section 3(a) of the Ethics Act
quoted above prohibits an individual from serving the interests of two
persons, groups or entities whose interest may be adversed. See Alfano
Opinion, 80 -007. In the instant situation, if you were to simultaneously
serve as borough councilmember and president and also as an employee of Magnox nox
Pulaski, Inc., in providing consulting services via Magnox, Inc. (D.E.) to the
borough, you would be serving entities with interests which are adverse to
each other because you would be simultaneously serving on the borough council
and also representing the interest of your employer, Magnox Pulaski, Inc.,
which is the parent company of Magnox Inc (D.E.).
595, where the Ethics Commission found that a member ofeaKmunicipaleauthority
violated Sections 3(a), 3(c) and 3(e) of the Ethics Act when he negotiated a
contract for his firm which provided consulting services to the municipal
authority. Therefore, under Section 3(a) of the Ethics Act, a conflict of
interest would arise on your part by your simultaneous service as borough
councilmember and president and as an employee of Magnox Pulaski Inc., which
would be providing the consulting services for Magnox Inc., (D.E.).
Section 3(b) of the Ethics Act provides:
Sec t`� Restricted activities.
(b) No person shall offer or give to a public official or
public employee or candidate for public office or a member
of his immediate family or a business with which he is
associated, and no public official or public employee or
candidate for public office shall solicit or accept,
anything of value, including a gift, loan, political
Mr. Spencer Andress
February 8, 1988
Page 4
contribution, reward, or promise of future employment
based on any understanding that the vote, official action,
or judgment of the public official or public employee or
candidate for public office would be influenced thereby.
65 P.S. 403(b).
Reference to Section 3(b) of the Ethics Act is made in order to provide
complete response to your inquiry. Under Section 3(b) of the Ethics Act cited
above, which must be observed, a public official must neither offer nor
accept
anything of value on the understanding or with the intention that the public
official's judgment would be influenced thereby. It is assumed such a
situation does not exist here. Reference to this Section is added not to
indicate that any such activity has been or will be undertaken but in an
effort to provide a complete response to your inquiry.
In addition to the foregoing, the State Ethics Act provides as follows:
Section 3. Restricted activities.
(c) No public official or public employee or a member of
his immediate family or any business in which the person
or a member of the person's immediate family is a
director, officer, owner or holder of stock exceeding 5%
. of the equity at fair market value of the business shall
enter into any contract valued at $500 or more with a
governmental body unless the contract has been awarded
through an open and public process, including
notice and subsequent public disclosure l P sals
e
considered and contracts awarded. Any contract madein
violation of this subsection shall be voidable by a court
of competent jurisdiction if the suit is commenced within
90 days of making of the contract. 65 P.S. 403(c).
In relation to the above provision of law,
the State Ethics Commission
has generally determined that this provision is a
proceure to
public official or employee contracts with his own governmental bbodyeinV ,excess
of $500. Brya n 0 i nion, 80 -014; Winch Opinion, 79 -047. The Commission,
however, has also determined that the above provision of law is not a general
authorization for a public official to contract with his own governmental body
where such is otherwise prohibited by law. The above
is intended to be a procedure to be utilized where contractingnisfotherwiserly
allowed by law. For example, if a particular business transaction was
prohibited under the State Ethics Act, this particular provision of law would
not authorize that transaction. Additionally, if a particular
a public official from being interested in a contract, this provision would
not allow that interest.
Mr. Spencer Andress
February 8, 1988
Page 5
Parenthetically, where contracting is otherwise allowed or where there
appears to be no expressed prohibition to such contracting, the above
particular provision of law would require that an additional procedure be
utilized when such business is transacted. This procedure, the open and
public process, must be used in all situations were a public official is
otherwise appropriately contracting with his own governmental body in excess
of $500. This open and public process would require:
(1) prior public notice of the employment or contracting possibility;
(2) sufficient time for a reasonable and prudent competitor /applicant to
be able to prepare and present an application or proposal;
(3) public disclosure of all applications or proposals considered and;
(4) public disclosure of the contract awarded and offered and accepted.
See, Cantor Opinion, 82 -004.
Thus, in the event that contracting would be allowed, the above process
must be employed.
As noted above, Section 3(c) of the Ethics Act does not preclude a public
official or a business with which a public official is associated from
contracting from his governmental body provided the contract is not prohibited
in law and provided the requirements of Section 3(c) cited above are
satisfied: namely, that if the contract is over $500 it must be awarded
through an open and public process with prior public notice and subsequent
public disclosure, as outlined above.. Therefore, as long as the above
criteria of Section 3(c) of the Ethics Act are satisfied and the contract
would not be prohibited under the Borough Code, Magnox Inc., (D.E.) could
contract with the Borough of Oxford subject to the foregoing limitations and
requirements.
In addition to the foregoing provision of law, the State Ethics
Commission may address other areas of possible conflicts of interest. 65 P.S.
§403(d). The parameters of the types of activities encompassed by this
provision of law may generally be determined by reviewing the purpose and
intent of the Ethics Act. The Ethics Act was promulgated in order to ensure
that the financial interests of public officials do not conflict with the
public trust. In the event that Magnox Inc., (D.E.) is awarded the consulting
management services contract, under Section 3(d) of the Ethics Act you could
not participate in either the negotiation, the award, the administration or
any aspect of the contract between the Borough of Oxford and Magnox Inc.,
(D.E.). Further, whenever any matter concerning Magnox Inc., (D.E.) would
come before borough council, you would have to abstain and further note your
abstention of public record together with the reasons for your abstention.
Mr. Spencer Andress
February 8, 1988
Page 6
Conclusion: As borough councilmember and president
you are
subject to the provisions of the Ethics Act. AlthoughMagnoxaInc.,i(D official .,
the wholly -owned subsidiary Magnox Pulaski, Inc., may contract under Section
3(c) with the borough provided the criteria as outlined above are satisfied,
you individually may not simultaneously serve as borough councilmember and
president and as an employee of Magnox Pulaski Inc., whereby you would be
providing consulting services to the borough via Magnox, Inc. (D.E.). Under
Section 3(d) of the Ethics Act, if the borough awards the contract to Magnox,
Inc. (D.E.), you must not participate in any matter involving Magnox Pulaski,
or its wholly -owned subsidiary Magnox, Inc. (D. E.), before borough council
and you must note your abstention of public record as well as the reason for
your abstention. Lastly, the propriety of your conduct has only been
addressed under the Ethics Act.
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 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 request that the full Commission review this Advice.
A personal appearance before the Commission will be scheduled and a formal
Opinion from the Commission w i l l be issued. Any such appeal must be made, in
writing, to the Commission within 15 days of service of this Advice pursuant
to 51 Pa. Code 2.12.
Sincerely,
Vincent . Dopko
General Counsel