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HomeMy WebLinkAbout398 HannunJohn B. Hannun, Jr. Chief Counsel 201 Agriculture Bldg. 2301 N. Cameron Street Harrisburg, PA 17110 Re: #85 -048 -C Dear Mr. Hannun: C'S STATE ETHICS COMMISSION 308 FINANCE BUILDING HARRISBURG, PENNSYLVANIA 17120 ORDER OF THE COMMISSION August 5, 1985 Order No. 398 The State Ethics Commission has received a complaint regarding you and a possible violation of Act 170 of 1978. The Commission has now completed its investigation. The individual allegations, conclusions, and findings on which those conclusions are based are as follows: I. Allegation: That you, Chief Counsel for the Department of Agriculture, violated - Section 4(f) of the Ethics Act which requires that all Statements of Financial Interests be made available for public inspection and copying when you refused to make statements available. A. Findings: 1. You serve as Chief Counsel in the State Department of Agriculture and as such, are subject to the provisions of the State Ethics Act. 2. On or about April 14, 1985, a citizen asked to review the Statement of Financial Interests of a Department of Agriculture official. 3. You refuse to allow the citizen to review the statement and told him he would have to submit a request in writing for your review. 4. Subsequent to that action, you discussed this request with the Executive Director of the State Ethics Commission and were told that the records were public and should be made available. 5. You made the statements available and the citizen was able to review the Statement of Financial Interests within a day or two of that phone conversation. Mr. John B. Hannun, Jr. _Page 2 B. Discussion: Section 4. Statement of financial interests required to be filed. (f) All statements of financial interest filed pursuant to the provisions of this act shall be made available for public inspection and copying during regular office hours.. 65 P.S. 404(f). Although your initial refusal was not in accordance with the requirements of Section 4(f), you made the Statement of Financial Interests available as soon as you were told that the records were public. There is no evidence that you knowingly violated in Section 4(f) or that you had a financial or personal interest in withholding this information. Under these circumstances, we find no violation of the State Ethics Act. C. Conclusion: We find no violation of Section 4(f) of the Ethics Act in your initial refusal to allow a citizen to review a Statement of Financial Interests because you made the statement available immediately after being told that the record was public and there is no evidence that you have a personal or financial interest in withholding this information. Our files in this case will remain confidential in accordance with Section 8(a) of the Ethics Act, 65 P.S. 408(a). However, this Order is final and will be made available as a public document 15 days after service (defined as mailing) unless you file documentation with the Commission which justifies reconsideration and /or challenges pertinent factual findings. See 51 Pa. Code 2.38. During this 15 -day period, no one, including the Respondent unless he waives his right to challenge this Order, may violate this confidentiality by releasing, discussing or circulating this Order. Any person who violates the confidentiality of a Commission proceeding is guilty of a misdemeanor and shall be fined not more than $1,000 or imprisoned for not more than one year or both, see 65 P.S. 409(e). EMS /sfb erb t B. Conner Ch. man August 5, 1985