PREPARED BY: SARAH maroof DATE OF MEETING: 9/08/2026
SUBJECT:
TITLE
CONSIDER ADOPTING RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN PABLO AMENDING THE CITY OF SAN PABLO’S CONFLICT OF INTEREST CODE
CEQA: This proposed action is not a project as defined by CEQA.
Label
CITY MANAGER RECOMMENDATION
Recommendation
Adopt Resolution
Body
COMPLIANCE STATEMENTS
Although not specified in the FY 2025-27 City Council Priority Workplan effective April 7, 2025 and amended most recently on April 20, 2026, amendment of the Conflict of Interest Code is a State-mandated legal obligation.
BACKGROUND
The public rightly expects their public officials to make decisions based on the best interests of the City and not their personal interests. To this end, California Government Code §87300 et seq., The Political Reform Act, requires every public agency to adopt a Conflict of Interest Code. A Conflict of Interest Code designates the positions within an agency which make or participate in making governmental decisions that may foreseeably have a material effect on a personal financial interest (Exhibit 1 to Resolution, Appendix A). These positions are required to disclose annually their financial interests pursuant to disclosure categories for investments, business positions, interests in real property and sources of income (Exhibit 1 to Resolution, Appendix B). Even if a public official or employee is not on the designated list attached with the Conflict of Interest Code, the individual is still prohibited from making governmental decisions in which the official has a financial interest.
The current Conflict of Interest Code was adopted November 3, 2025, pursuant to Resolution 2025-133 (Attachment B).
Biennial review required by Government Code §87306.5 is due in 2026, per the California Fair Political Practices Commission’s 2026 Conflict of Interest Code Biennial Notice Instructions for Local Agencies (Attachment C). The Fair Political Practices Commission (FPPC) notified the City Clerk in May of 2026 that a 2026 Local Agency Biennial Notice must be submitted to the City Council no later than October 1, 2026.
As reported in the City’s completed 2026 Local Agency Biennial Notice (Attachment D), the City has reviewed its Conflict of Interest Code and has determined that an amendment is required, to include new positions and to revise the titles of existing positions.
By Resolution 2026-102, adopted June 15, 2026, the City Council of the City of San Pablo approved an Amendment to the City’s Classification and Compensation Plan for FY 2026-27 (Attached E). Because the Classification and Compensation Plan for FY 2026-27 includes new positions and revised titles of existing positions, it has been determined that a 2026 update to the Conflict of Interest Code is required.
Conflict of Interest Code 2026 (Proposed) Update
The currently proposed Conflict of Interest Code 2026 Update included updates to the list of designated positions and associated disclosure categories. Attachment F provides tracked changes to the Conflict of Interest Code 2026 Update for ease of review.
The City Clerk’s Office serves as the City’s filing officer for mandated disclosure by designated positions. Effective August of 2024, the City Clerk’s Office transitioned to an electronic disclosure system, DisclosureDocs, administered by the City Clerk’s Office in the performance of duties of Filing Officer for the City Council, allowing for electronic submission of Form 700 statements. This electronic disclosure system not only files and securely store the submitted statements, but also provides automatic reminders, messaging, and tracking.
Effective January 1, 2025, public officials identified in Government Code §87200 (“87200 filers”) for whom the FPPC is the filing officer must file their Statement of Economic Interests (Form 700) via the FPPC’s Electronic Filing Portal (the “FPPC Portal”) at: <https://form700.fppc.ca.gov/> The City previously updated its Conflict of Interest Code in 2025 to include this new filing requirement for 87200 filers, and the City Clerk’s Office remains the filing officer for all other filers.
The currently proposed Conflict of Interest Code 2026 update amends the list of designated positions required to file Form 700 Conflict of Interest Statements and their associated disclosure categories.
The following changes are proposed to Appendix A of Exhibit 1 to reflect the City’s current list of Public Officials and Designated Positions, as summarized below:
|
DESIGNATED POSITION |
ACTION / JUSTIFICATION |
|
Administrative Services Director |
MOVED from 87200 list to Designated Position, as not included on FPPC’s 2026 list of direct filers |
|
Assistant City Clerk |
ADDED as position remains in Class & Comp Plan, though is not currently in use |
|
Engineering Services Manager |
ADDED per Resolution 2026-136 adopted 8/3/26 |
|
Information Technology Specialist |
ADDED per Resolution 2026-102(1) adopted 6/15/26 |
|
Management Assistant |
ADDED per Resolution 2026-102(1) adopted 6/15/26 |
|
Manager of Council Services, Elections and Records |
ADDED as position remains in Class & Comp Plan, though is not currently in use |
|
Public Works Director |
REVISED position title per Resolution 2026-102(4) adopted 6/15/26 |
|
Senior Planner |
ADDED per Resolution 2026-102(1) adopted 6/3/26 |
FISCAL IMPACT
No is no fiscal impact associated with amending the City’s Conflict of Interest Code. There is no fiscal impact with the currently proposed amendment to the City’s Conflict of Interest Code.
ATTACHMENTS
Att A. Resolution
Exhibit 1 to Att A. Proposed Conflict of Interest Code 2026 update with Appendices
Att B. Resolution 2025-133 adopting current Conflict of Interest Code effective 11/3/25
Att C. Fair Political Practices Commission’s 2026 Conflict of Interest Code Biennial Notice Instructions for Local Agencies
Att D. City of San Pablo’s 2026 Local Agency Biennial Notice
Att E. FY26/27 City of San Pablo Classification & Compensation Plan adopted 6/15/26 by Resolution 2026-102
Att F. Redline version of tracked (proposed) changes to Conflict of Interest Code