TO: Honorable Mayor and Members of the City Council
THRU: Jarad Hildenbrand, City Manager
FROM: Pamela Coleman, City Clerk/Director of City Clerk Services
1. Subject
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2026 City of Orange Conflict of Interest Code Biennial Review Notice
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2. Summary
The City is required by GC §87306.5 to review, and, if necessary, amend its Conflict of Interest Code every even-numbered year. As the code reviewing body for the Cityof Orange, the City Council must, no later than July 1, 2026, direct review of its code; and, no later than October 1, 2026, receive notice that an amendment is or is not required. If an amendment is required, it must be completed prior to December 31, 2026.
3. Recommended Action
recommendation
Direct staff to review the Conflict of Interest Code and authorize execution of the Biennial Review Notice no later than October 1, 2026.
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4. Fiscal Impact
None.
5. Strategic Plan Goals
This action does not correlate to any of the adopted strategic plan goals; however, Section 87306 of the California Government Code requires biennial review of the City’s Conflict of Interest Code.
6. Discussion and Background
The Political Reform Act of 1973 (“the Act”) and, in particular, Government Code Section 87306.5, requires the City Council to direct a review of the City’s Conflict of Interest Code (“Code”) no later than July 1 of each even-numbered year. If changes are necessary, a revised Code must be submitted to the City Council for approval. The City of Orange Conflict of Interest Code was last amended in 2024.
The Conflict of Interest Code identifies officials, employees, boards, committees and commissions; and consultants who are required to file at Statement of Economic Interests Form 700 when assuming office, on an annual basis, and upon leaving office. The purpose of the update is to specify positions within the agency which involve decision making that may have material or personal financial interests relative to City business. Designated individuals must disqualify themselves when conflicts of interest occur.
The completed review must be submitted to the City Council, with any recommended changes, by October 1, 2026. If an amendment is required, it must be completed prior to December 31, 2026. Staff anticipates necessary changes to the current Code and, therefore, will prepare an amendment to be presented to the City Council for consideration no later than December 31, 2026.
7. ATTACHMENTS
• Resolution No. 11558 adopted on June 25, 2024