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HomeMy WebLinkAbout934 AumanSTATE ETHICS COMMISSION 308 FINANCE BUILDING HARRISBURG, PENNSYLVANIA 17120 In Re: John Auman File Docket: 93- 029 -C2 Date Decided: 06/23/94 Date Mailed: 06/30/94 Before: James M. Howley, Chair Daneen E. Reese, Vice Chair Roy W. Wilt Austin M. Lee Allan M. Kluger The State Ethics Commission received a complaint regarding a possible violation of the State Ethics Act, Act 170 of 1978 as added and amended by Act 9 of 1989. Written notice, of the specific allegation(s) was served at the commencement of the investigation. A Findings Report was issued and served, upon completion of the investigation, which constituted the Complaint by the Investigation Division. An Answer was not filed and a hearing was deemed waived. The record is complete. This adjudication of the Commission is hereby issued which sets forth the individual Allegations, Findings of Fact, Discussion, Conclusions of Law and Order. This adjudication is final and will be made available as a public document fifteen days after issuance. However, reconsideration may be requested which will defer public release of this adjudication pending action on the request by the Commission. A request for reconsideration, however, does not affect the finality of this adjudication. A reconsideration request must be received at this Commission within fifteen days of issuance and must include a detailed explanation of the reasons as to why reconsideration should be granted in conformity with 51 Pa. Code §21.29(b). The files in this case will remain confidential in accordance with Act 9 of 1989, 65 P.S. §408(h) during the fifteen day period and no one unless the right to challenge this Order is waived, may violate confidentiality by releasing, discussing or circulating this Order. However, confidentiality does not preclude discussing this case with an attorney at law. • Any person who violates confidentiality of the Ethics Act is guilty of a misdemeanor subject to a fine of not more than $1,000 or imprisonment for not more than one year, 65 P.S. S409(e). Auman, 93- 029 -C2 Page 2 I. ALLEGATION: That, John Auman, as a public official /public employee in his capacity as a Supervisor for Spring Township, Centre County, violated the following provisions of the State Ethics Act (Act 9 of 1989) when he received compensation for performing duties other than roadmaster, laborer or secretary /treasurer. Section 3. Restricted Activities (a) No public official or public employee shall engage in conduct that constitutes a conflict of interest. 65 P.S. S403(a). Section 2. 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. "Conflict" or "conflict of interest" 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. 65 P.S. S402. and that, John Auman, as a public official /public employee in his capacity as a Supervisor for Spring Township, Centre County, violated the following provisions of the State Ethics Act (Act 170 of 1978) when he received compensation for performing duties other than roadmaster, laborer or secretary /treasurer and when he failed to disclose sources of income filed on Statements of Financial Interests for 1987, 1988 and 1989 calendar years. 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 Auman, 93- 029 -C2 Page 3 II. FINDINGS: himself, a member of his immediate family, or a business with which he is associated. 65 P.S. 5403(a). Section 5. Statement of financial interests. (b) The statement shall include the following information for the prior calendar year with regard to the person required to file the statement and the members of his immediate family: (5) The name and address of any person who is the direct or indirect source of income totalling in the aggregate $500 or more. However, this provision shall not be construed to require the divulgence of confidential information protected by statute or existing professional codes of ethics. 65 P.S. S405(b)(5). 1. John Auman has served as a Supervisor for Spring Township, Centre County, Pennsylvania since January, 1984 a. He previously served in this position from January, 1963, through 1980. 2. At Reorganization Meetings of the Spring Township Supervisors, from January, 1986, to January 4, 1993, Auman was appointed the First Assistant to the Supervisor of Highways and Building Maintenance. a. At the January 4, 1993, meeting this title was in the supervisor's meeting minutes as First Assistant to Supervisor in charge of the Highways, Township Equipment, Buildings and Facilities. b. At the board meeting of February N3, 1994, Auman was appointed the Supervisor in Charge of Highways and Township Equipment. 1) Auman replaced Supervisor Melvin Zimmerman who died in January, 1994. 3. Since January, 1984, Auman has also served as the Supervisor in charge of the Township Police Department. a. Since January, 1988, he has served as the Supervisor in Auman, 93- 029 -C2 Page 4 charge of planning and zoning variance matters and the sewage enforcement officer. 4. Auman's primary duties as a Spring Township Supervisor serving as First Assistant to the Supervisor of Highways and Building Maintenance and his position of supervisor in charge of the police department, planning and zoning, variances and the sewage enforcement officer included the following: a. Attending meetings with insurance agents and developers, meetings of the Joint Spring, Brenner, Walker Sewer Authority and meetings related to police matters, planning and zoning. b. Make trips to meet with representatives of the Pennsylvania Department of Environmental Resources at Harrisburg, Clearfield and Williamsport. c. Travel to Washington, D.C. and Philadelphia to appeal for funding. d. Along with the other supervisors, perform other duties that would normally be the responsibility of a township manager. e. Twice yearly, perform road inspections. f. Perform emergency road work and or snow removal. 5. Auman was paid an hourly rate for performing the duties outlined in Finding #4. 6. The Spring Township Supervisors have approved, at reorganization meetings from at least 1986 to 1994, the following motion permitting supervisors to attend meetings: a. The supervisors are authorized to attend any and all meetings in the best interest of the township, and any seminars or schooling, mileage and related costs, and the supervisors are authorized to approve the attendance of all employees, and others as approved by the Board to attend any and all meetings in the best interest of the township, and any seminars or schooling, mileage and related costs be approved by the Board of Supervisors. 7. The Spring Township Auditors have approved compensation for the supervisors as follows: January 3, 1989 - A wage of $6.50 per hour for supervisor was approved. Also, $25.00 per attendance at meetings. Auman, 93- 029 -C2 Page 5 8. John Auman submitted hours for compensation on a monthly basis as follows: a. 1990: January 2, 1990 - Wage $6.50 per hour per supervisor. Also, $25.00 per meeting attended. January 7, 1992 - Wage of $6.50 per hour per supervisor. Also, $25.00 per meeting attended. January 5, 1993 - After brief discussion it was on a motion of James Bowmaster seconded by Kenton Dutrow to increase the supervisors' salary from $6.50 to $7.00 an hour. January 8, 1991 - Wage of $6.50 per hour per supervisor. Also, $25.00 per meeting attended. Pav Period Ending Hours Rate of Pav Total 01/26/90 58 $ 6.50 $ 377.00 02/23/90 61 $ 6.50 396.50 03/23/90 63 $ 6.50 409.50 04/20/90 72 $ 6.50 468.00 05/18/90 85 $ 6.50 552.50 06/19/90 65 $ 6.50 422.50 07/16/90 61 $ 6.50 396.50 08/14/90 76 $ 6.50 494.00 09/07/90 59 $ 6.50 383.50 10/05/90 70 $ 6.50 455.00 11/02/90 92 $ 6.50 598.00 12/04/90 73 $ 6.50 474.50 12/28/90 62 $ 6.50 $ 403.00 897 $ 5,830.50 b. 1991: Pay Period Ending Hours Rate of Pav Total 01/25/91 63 $ 6.50 $ 409.50 02/22/91 69 $ 6.50 448.50 03/22/91 78 $ 6.50 507.00 04/19/91 91 $ 6.50 591.50 05/17/91. 73 $ 6.50 474:50 06/14/91 84 $ 6.50 546.00 07/26/91 102 $ 6.50 663.00 08/23/91 94 $ 6.50 611.00 09/20/91 81 $ 6.50 526.50 10/18/91 72 $ 6.50 468.00 11/15/91 85 $ 6.50 552.50 12/13/91 76 $ 6.50 494.00 uman, 93- 029 -C2 Page 6 c. 1992: $ 6,292.00 Pay Period Endina Hours Rate of Pav Total 01/10/92 80 $ 6.50 $ 520.00 02/07/92 84 $ 6.50 546.00 03/06/92 96 $ 6.50 624.00 04/03/92 86 $ 6.50 559.00 05/01/92 86 $ 6.50 559.00 06/01/92 58 $ 6.50 377.00 06/26/92 78 $ 6.50 507.00 07/24/92 65 $ 6.50 422.50 08/21/92 62 $ 6.50 403.00 09/18/92 65 $ 6.50 422.50 10/16/92 63 $ 6.50 409.50 11/13/92 73 $ 6.50 474.50 12/11/92 67 $ 6.50 435.50 963 $ 6,259.50 c. 1993: Pay Period Ending Hours Rate of Pay Total 01/08/93 57 42 hrs. @ $ 378.00 02/05/93 86 $6.50 /hr.; 602.00 03/05/93 76 $ 7.00 532.00 04/02/93 86 $ 7.00 602.00 04/30/93 76 $ 7.00 532.00 05/28/93 65 $ 7.00 455.00 06/25/93 40 $ 7.00 280.00 07/23/93 54 $ 7.00 378.00 08/20/93 66 $ 7.00 462.00 09/17/93 59 $ 7.00 413.00 10/15/93 63 $ 7.00 441.00 11/12/93 76 $ 7.00 532.00 12/10/93 70 $ 7.00 490.00 874 $ 6,097.00 9. Township payroll records and W -2 Forms confirm that Auman was compensated annually as follows for hours submitted. a. Year Amount After Deductions 1989 6,513.00 5,220.91 1990 5,830.50 4,813.68 1991 6,292.00 5,137.43 1992 6,259.50 5,420.67 1993 6,097.00 5,347.88 $30,992.00 $25.940.57 10. John Auman attended meetings of the Spring, Benner and Walker Auman, 93- 029 -C2 Page 7 Joint Sewer Authority as a representative of the Township and was compensated at his hourly rate for such attendance. a. He received pay of $6.50 per hour during 1989 through 1992 and $7.00 /hour in 1993. 11. The dates and times of Auman's attendance at meetings are as follows: Length of Date Timeframe Meetings 2/14/89 2/27/89 3/14/89 5/9/89 5/22/89 6/13/89 7/11/89 8/8/89 5/14/90 8/13/90 8/27/90 2/25/91 5/13/91 6/11/91 8/12/91 9/23/91 1/27/92 2/10/92 3/9/92 9/14/92 9/28/92 11/9/92 5/11/93 9/27/93 7:31 to 9:20 p.m. 7:36 to 8:40 p.m. 7:34 to 9:40 p.m. 7:32 to 10:09 p.m. 7:33 to 8:54 p.m. 7:33 to 9:50 p.m. 7:33 to 8:15 p.m. 7:30 to 8:50 p.m. 7:35 to 9:40 p.m. 7:33 to 10:15 p.m. 7:32 to 9:40 p.m. 7:30 to 9:10 p.m. 7:30 to 10:35 p.m. 7:30 to 8:30 p.m. 7:30 to 8:40 p.m. 7:30 to 9:07 p.m. 7:30 to 10:00 p.m. 7:30 to 9:20 p.m. 7:40 to 8:50 p.m. 7:30 to 9:45 p.m. 7:00 to 8:15 p.m. 7:00 to 8:33 p.m. 7:00 to 9:00 p.m. 7:00 to 8:20 p.m. 1:49 1:03 2:06 2:37 1:21 2:17 :42 1:20 2:05 2:42 2:08 1:40 3:05 1:00 1:10 1:37 2:30 1:50 1:10 1:15 1:15 1:33 2:00 1:20 * Auman's time cards reflect 3 hours worked on May 11, 1993, and 4 hours worked on September 27, 1993. 12. Total paid to Auman for attending authority meetings: 1989 to 1992: 1248.63 1993: 49.00 Total $297.63 13. Prior to January, 1993, the township did not maintain a system to record and document the hours worked by township supervisors. a. Time cards were initiated beginning with the first pay Auman,, 93- 029 -C2 Page 8 period of 1993. b. Time cards reflect hours worked but do not record specific duties. 14. Auman maintains a compilation of hours worked as a supervisor in his personal notes. a. At the end of each month, he reports hours worked to an office secretary at the township. 1. These hours do not reflect specific duties performed. 2. The office secretary records these hours on a timecard. b. He does not keep a record of the type of work he performs for the township. c. Auman destroys his personal notes after a brief period of retention. d. Auman does not perform work on township roads. 15. Auman and the other township supervisors were compensated for attending meetings of the township supervisors at a rate of $25.00 per meeting. a. The rate was established in accordance with the Second Class Township Code. b. A limit of $400.00 per year for each supervisor's attendance at these meetings was set by the township. 16. Auman believed that he was entitled to receive compensation for hourly pay listed in Finding 8. a. He contends that payments were approved by the Auditors during annual audits of township accounts. b. Since the township does not have a township manager, the supervisors are appointed to alternate township roles and are compensated for these duties. 1) The three supervisors provide input with regard to all decisions involving the township. 17. In addition to the duties listed in Finding #4, Auman has performed the following duties since February, 1994. Auman,, 93- 029 -C2 Page 9 a. Develop budgets for road improvements. b. Estimate tonnage requirements in making purchases of curbing, piping and anti -skid material. c. Estimate hours required to complete a road - related job. d. Provide input on all decisions made by the supervisors with regard to township roads and their safety. 18. John Auman filed a Statement of Financial Interests for calendar year 1987 on March 12, 1988. a. Lines 9 through 16 were annotated with the word "none" written across this section of the form. b. All township statements for this year were either misplaced or lost. c. The March 12, 1988 statement was intended to be a refiling and " none" was intended to give notice that there were no changes to the original statement filed for 1987. 19. John Auman filed a Statement of Financial Interests for calendar year 1988 on March 12, 1989. a. Lines 9 through 16 were annotated with the word "none" written across this section of the form. b. All township statements for this year were either misplaced or lost. c. The March 12, 1989 statement was intended to be a refiling and "none" was intended to give notice that there were no changes to the original statement filed for 1988. 20. John Auman filed a Statement of Financial Interests for calendar year 1989 on March 12, 1990. a. Lines 9 through 16 were annotated with the word "none" written across this section on the form. b. All township statements for this year were either misplaced or lost. c. The March 12, 1990 statement was intended to be a refiling and "none" was intended to give notice that there were no changes to the original statement filed for 1989. Auman, 93- 029 -C2 Page 10 III. DISCUSSION: As a Supervisor for Spring Township, Centre County, John Auman, hereinafter Auman, is a public official as that term is defined under Act 9 of 1989. 65 P.S. §402. As such, his conduct is subject to the provisions of the Ethics Law and the restrictions therein are applicable to him. Initially, it is noted that Section 9 of Act 9 of June 26, 1989 provides, in part, as follows: This amendatory act shall not apply to violations committed prior to the effective date of this act, and causes of action initiated for such violations shall be governed by the prior law, which is continued in effect for that purpose as if this act were not in force. For the purposes of this section, a violation was committed prior to the effective date of this act if any elements of the violation occurred prior thereto. Since the occurrences in this case transpired both before and after the effective date of Act 9 (June 26, 1989), we must apply the provisions of Act 170 of 1978 and Act 9 of 1989 to determine whether the Ethics Act was violated. Under Section 3(a) of Act 9 of 1989 quoted above, a public official /employee shall not engage in conduct that constitutes a conflict of interest. Under Section 3(a), of Act 170 of 1978 quoted above, this Commission has determined that use of office by a public official to obtain a financial gain for himself or a member of his immediate family or a business with which he is associated which is not provided for in law transgresses the above provision of law. Thus, use of office by a public official to obtain financial gain which is not authorized as part of his compensation is prohibited by Section 3(a): Hoak /McCutcheon v. State Ethics Commission, 77 Pa. Commw. Ct. 529, 466 A.2d 283 (1983); Yacobet v. State Ethics Commission, 109 Pa. Commw. Ct. 432 531 A.2d 536 (1987). Similarly, Section 3(a) of the .Ethics Act would prohibit a public official /employee from using public office to advance his own financial interests; Koslow v. State Ethics Commission, 116 Pa. Commw. Ct. 19, 540 A.2d 1374 (1988). Section 5(b)(5) of Act 170 of 1978, a Financial Interests Statement (FIS) disclosure provision, requires that a public official /employee list the name and address of any direct or indirect source of income totalling in the aggregate of $500.00. Auman, 93- 029 -C2 Page 11 The issue before us is whether Auman violated Section 3(a) Act 170 of 1978 or Act 9 of 1989 by receiving compensation as an employee- supervisor for Spring Township, Centre County and second whether he violated Section 5 of Act 170 of 1978 by failing to disclose sources of income for the calendar years 1987 through 1989 on his FIS's. Auman has served as a Spring Township Supervisor since January, 1994 with prior service from 1963 to 1980. At the January reorganizational meetings, Auman was appointed to such positions as: First Assistant to Supervisor in charge of the Highways, Township Equipment, Buildings and Facilities; Supervisor in Charge of Highways and Township Equipment; Supervisor in charge of the Township Police Department; the First Assistant to the Supervisor of Highways and Building Maintenance; and Supervisor in Charge of planning and zoning variance matters and the sewage enforcement officer. The above positions were not those which are enumerated and allowed under the Second Class Township Code: superintendent, roadmaster, secretary /treasurer or laborer. The township board of supervisors authorized the attendance at meetings by employees and others with the costs subject to approval by the board of supervisors. Fact Finding 6. The township auditors at their January reorganizational meetings set the meeting pay for the supervisors and also set an hourly wage "per supervisor." Fact Finding 7. Auman performed services and received compensation. Fact Finding 9. Auman believed that he was entitled to receive compensation listed on the theory that the payments were approved by the auditors. In addition, Auman attended certain municipal authority meetings as a representative of the township and received compensation of $297.63 for the year 1989. Fact Findings 10 -12. As to the FIS issue, Auman did file FIS's in the calendar years 1987 through 1989 but listed "None" in all financial interest categories on the theory that "None" meant no changes from a prior filing. Fact Findings 18.C, 19.0 and 20.C. In determining whether the actions of Auman violated Section 3(a) of the Ethics Law, we must review the pertinent provisions of the Second Class Township Code. Although we do not have jurisdiction to interpret the provisions o, the Second Class Township Code, it is nedessary to review those provisions of law in order to make a determination as to whether the financial gain was compensation other than provided for by law under Section 3(a) of Act 170 of 1978 or a private pecuniary benefit under Act 9 of 1989. The Second Class Township Code provides that township supervisors shall receive the following compensation: Auman, 93- 029 -C2 Page 12 53 P.S. §65515. Compensation of Supervisors Supervisors may receive from the general township fund, as compensation, an amount fixed by ordinance not in excess of the following: Township Population Not more than 4,999 5,000 to 9,999 10,000 to 14,999 15,000 to 24,99 25,000 to 34,999 35,000 or more OOP MIN Annual Maximum Compensation Fifteen hundred dollars Two thousand dollars Twenty -six hundred dollars Thirty -three hundred dollars Thirty -five hundred dollars Four thousand dollars Such salaries shall be payable monthly or quarterly for the duties imposed by the provisions of this act. The population shall be determined by the latest available official census figures. The compensation of supervisors shall be fixed by the township auditors either per hour, per day, per week, semi- monthly or monthly, which compensation shall not exceed compensation paid in the locality for similar services, and such other reasonable compensation for the use of a passenger car, or a two -axled four - wheeled motor truck having a chassis weight of less than two thousand pounds when required and actually used for the transportation of road and bridge laborers and their hand tools and for the distribution of cinders and patching material from a stock pile, as the auditors shall determine and approve; but no supervisor shall receive compensation as a superintendent or roadmaster for any time he spends attending a meeting of supervisors. In reference to the meetings for which supervisors may receive compensation, the Code further provides as follows: •The township supervisors shall meet for the transaction of business at least once each month, at a time and place to be fixed by the board, but they shall not be paid for more than sixteen meetings in any one year, except for any township where, on account of the exercise of governmental functions other than those relating to roads, more meetings are necessary, in which case, the number of Auman, 93- 029 -C2 Page 13 53 P.S. 565512. meetings for which the supervisors may be paid may be increased to any number, not exceeding fifty meetings in any year which shall include hearings by aggrieved parties under the Pennsylvania Sewage Facilities Act and other hearings by aggrieved parties, hearings of a judicial or quasi- judicial nature. Two members of any board of supervisors consisting of three members shall constitute a quorum and three members of any board of supervisors consisting of five members shall constitute a quorum. Except as otherwise provided in this act, an affirmative vote of a majority of the entire board of supervisors shall be necessary in order to transact any business. Necessary expenses incurred in such meetings, including office rent, stationery, light and fuel, shall be paid out of the general township fund. The duties that a supervisor is responsible for performing are regulated by statute. The compensation to be paid for a supervisor who is not otherwise employed by the township is strictly regulated by the Second Class Township Code. A supervisor may only receive compensation for supervisor meetings regarding the transaction of township business. The type of meeting for which a township supervisor may be compensated must be one at which official township business is transacted. Additionally, the Second Class Township Code provides for compensation at the specific meetings as outlined in 565512 above. The Code does not appear to permit the compensation of a township supervisor for attending other types of meetings or for performing the administrative functions of his office. Any such other compensation must be earned as part of the services performed while serving in one of the statutorily authorized positions. Thus, if township supervisors were to award to themselves compensation for attendance at meetings that are not official township meetings of the board of supervisors as per Section 515 of the Code, or for performing duties not authorized by law, such would violate the provisions of the State Ethics Law as such payment would not constitute compensation provided by law. The above interpretation of the Second Class Township Code is a view that has also been expressed by the State Association of Township Supervisors which specifically indicated that supervisors may not be compensated for meetings with engineers, solicitors, planning commissions, authorities, or recreation boards. See, Township News, May, 1985, Page 66. In the Township News, June, 1993, page 90, it is stated that supervisors may not be compensated for time spent responding to citizen concerns, phone calls, and such administrative functions. Further, a supervisor- employee may not use "employee" time to deal with official supervisory duties on Auman, 93- 029 -C2 Page 14 non -road- related activities. The Second Class Township Code sets forth clearly when supervisors may receive compensation other than as set forth above. Generally, a township supervisor may be employed by the township as a roadmaster, laborer, or secretary /treasurer. 53 P.S. 565410. The compensation to be paid to supervisors working in such positions is to be fixed by the township board of auditors. 53 P.S. 5565515, 65531, 65540. Township supervisors may not receive any other compensation except as provided above. In Coltar v. Warminister Township, 8 Pa. Commw. Ct. 163, 302 A.2d 859 (1973), the Commonwealth Court of Pennsylvania held that a second class township supervisor may not appoint himself to positions other than those set forth in the township code (roadmaster, laborer, or secretary /treasurer), and receive compensation therefore. See also, Conard v. Exeter Township, 27 D &C.3d 253 (Berks 1983). It is clear, therefore, that the duties for which a township supervisors may be compensated are strictly regulated by the Second Class Township Code, and when performing in the positions set forth in the Code, the supervisor's compensation must be specifically set forth by the township board of auditors. As to Section 5(b)(5) of Act 170 of 1978, that FIS filing and disclosure requirement directs the disclosure of sources of income, direct or indirect, totalling in the aggregate of $500 or more. As to the FIS issue, Auman took the position that "None" meant no change from a prior filing. It is clear under the Ethics Law that each year is a separate filing for the financial interests in the prior calendar year. Thus, a reporting in a particular category or for a particular year does not provide an excuse for the failure to report a given financial interest. Lewis, Orders 876, 876R, affirmed Lewis v. SEC, filed in Commonwealth Court at 1282 C.D. 1993 on June 22, 1994. Therefore, Auman violated Section 5(b)(5) of Act 170 of 1978 when he failed to disclose his sources of income in the 1987 through 1989 calendar years. Auman is directed within thirty (30) days of issuance of this order to file amended FIS's for the calendar years 1987 through 1989 listing his sources of income. Failure to comply will result in the institution of an order enforcement action. • Turning to the matter of the compensation issue under Section 3(a) of Act 170 of 1978 and Act 9 of 1989, we are compelled by the Code which only allows a supervisor to be an employee as a superintendent, roadmaster, secretary /treasurer or laborer but not a First Assistant Supervisor or Supervisor in charge. We are equally compelled by the facts of record which reveal that the auditors erred as to the parameters under which they set the compensation. First, it is not a function of the auditors to set Auman, 93- 029 -C2 Page 15 meeting pay which is done by ordinance within the compensation caps of Section 515 of the Code. Second, the auditors should have set an hourly wage or wages for the enumerated working positions but instead set a wage "per supervisor." The conflicting aspects of the case must be and are resolved according to the law. Thus, Auman did violate Section 3(a) of Act 170 of 1978 and Act 9 of 1989 by receiving compensation which was not obtained by being in one of the enumerated allowable working positions. However, given the extraordinary circumstances of the case, we will exercise our discretion and not impose restitution as to the receipt of such compensation. As to the matter of the compensation for attending the meetings of the municipal authority as the township's representative, we do find violations of Section 3(a) of Act 170 of 1978 and Act 9 of 1989 because that particular activity is clearly within the province of the administrative duties of Auman as an elected public official. Auman under no circumstances could receive compensation as a township employee performing such administrative duties. The fact that the board of supervisors took action to authorize attendance and cost payments for such meetings is unavailing to themselves because such action constitutes public officials setting their own salary which is contrary to decades of judicial precedent, statutory law, the Code and Ethics Law. We accordingly find violations of Sections 3(a) of Act 170 of 1978 and Act 9 of 1989 and impose restitution of $297.63. Fact Finding 12. Accordingly, Auman is directed within thirty (30) days of issuance of this case to make restitution through the Commission to Spring Township in the amount of $297.63. Failure to comply will result in the institution of an order enforcement action. As to Auman, we do not believe that there was any intent on his part to violate the Ethics Law. Auman is nevertheless reminded that the public office is a public trust so that care must be taken by him in his future actions so that the above situations do not reoccur. As to Auman and the township auditors, we remind and suggest that consideration be given to attending various seminars that are periodically held by the Department of Community Affairs, by this Commission or by their respective associations which will educate them on the complexities of these areas of law. IV. CONCLUSIONS OF LAW: • 1. John Auman, as a Spring Township Supervisor, is a public official subject to the provisions of Act 170 of 1978 as added and amended by Act 9 of 1989. 2. Auman violated Section 3(a) of Act 170 of 1978 and Act 9 of 1989 when he used the authority of office to obtain a private pecuniary benefit and a financial gain other than compensation Auman, 93- 029 -C2 Page 16 provided by law as to services which he performed in positions which were not within the enumerated working positions under the Second Class Township Code. 3. Auman violated Section 3(a) of Act 170 of 1978 and Act 9 of 1989 when he received a financial gain /private pecuniary benefit for attending meetings of the municipal authority as a township representative in that such administrative duties were encompassed within the functions of an elected township official. 4. Auman violated section 5(b)(5) of Act 170 of 1978 when he failed to list his sources of income in the aggregate of $500 or more on his Statements of Financial Interests for the calendar years 1987 through 1989. 5. The financial gain /private pecuniary benefit Auman received as to the violation referenced in paragraph 3 totalled $297.63. In Re: John Auman File Docket: 93- 029 -C2 . Date Decided: 06/23/94 . Date Mailed: 06/30/94 ORDER NO. 934 1. John Auman, as a Spring Township Supervisor, violated Section 3(a) of Act 170 of 1978 and Act 9 of 1989 when he used the authority of office to obtain a private pecuniary benefit and a financial gain other than compensation provided by law as to services which he performed in positions which were not within the enumerated working positions under the Second Class Township Code. 2. Auman violated Section 3(a) of Act 170 of 1978 and Act 9 of 1989 when he received a financial gain /private pecuniary benefit for attending meetings of the municipal authority as a township representative in that such administrative duties were encompassed within the functions of an elected township official. 3. Auman violated section 5(b)(5) of Act 170 of 1978 when he failed to list his sources of income in the aggregate of $500 or more on his Statements of Financial Interests for the calendar years 1987 through 1989. 4. The financial gain /private pecuniary benefit received by Auman as to performing administrative duties of attending municipal authority meetings as the township representative amounted to $297.63. 5. Auman is directed within thirty (30) days of issuance of the order to file an amended Financial Interest Statements for the calendar years 1987 through 1989 listing his sources of income totaling in the aggregate of $500.00 or more. 6. Auman is directed within thirty (30) days of the date of issuance of this Order to submit restitution in the amount of $297.63 to this Commission payable to the order of Spring Township. 7. Failure to comply with Paragraphs 5 and 6 will result in a directive of this Commission to institute order enforcement proceedinngs . BY THE COMMISSION, JAMES M. HOWLEY, C IR