Chicago Board of Ethics - A General Guide for the Public

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MISSION AND RESPONSIBILITIES

The Board of Ethics, established in 1987, administers and enforces the Governmental Ethics Ordinance (Chapter 2-156 of the Municipal Code).  The Ordinance establishes conflict of interest standards for City employees, officials, lobbyists, contractors, candidates for elected City office, campaign contributors, and others who interact with governmental personnel.   

The Board has four major work areas:

(1) rendering confidential advice to City personnel and other about the  Ordinances and the code of conduct;

(2) conducting ethics training and education;

(3) enforcing the Ordinance, including conducting administrative “trials” and determining whether the Ordinance has been violated, and imposing sanctions; and

(4) regulating lobbyists, and reviewing and maintaining for public inspection ethics disclosures filed by lobbyists and certain City employees and officials.

ADVISORY OPINIONS

Board advisory opinions are confidential.  The Board can render binding opinions only as to future conduct. If someone discloses a past violation that is not minor, the matter must be referred to an Inspector General. 

BOARD MEMBERS AND STAFF

The law allows for seven Board members, appointed for staggered four-year terms by the Mayor and confirmed by City Council.  Members are uncompensated and independent:  they can be removed by the Mayor only for cause, with written consent of remaining Board members. Mayor Emanuel appointed seven new Board members in October 2012.

Board members may not hold any elected or other appointed public or political office, engage in any political or campaign activity, or have a financial interest in any work or business of the City or certain other governmental agencies in Illinois.

Board members render all formal opinions and determinations. The Board’s staff carries out all Board functions.  The staff of 9 is headed by an Executive Director, who is also appointed by the Mayor and confirmed by the City Council. The agency’s budget for 2013 is $839,000.

ASPIRATIONAL CODE OF CONDUCT

All new employees and officials must sign a code of conduct.  It requires them, among other things, to: disclose waste, fraud, abuse and corruption to the appropriate authorities; give a full day’s work for a full day’s pay; act impartially in performing their duties so that no private organization or individual is given preferential treatment; and remember that they are public servants.  

ETHICS RESTRICTIONS

The Ordinance has a substantive Code of Conduct.  It aims to prevent and correct conflicts of interest in City government.

The Code’s complete text is on our website.  It covers, among others things:

Conflicts of Interest
Outside Employment
Gift/Travel Limitations
Use of City-Owned Property
Representation of Third Parties
Post-Employment Restrictions
Contracting with the CityRelatives / Domestic Partners
Political Contributions
Political Activity
Fiduciary Duty

LOBBYIST REGULATION

Article IV of the Ordinance requires that every person who lobbies City government must register with the Board and pay a $350 annual registration fee and a $75 fee for each client after the first (there are different fees for certain non-profits).  Registrations must be filed by January 20 or within five business days of first lobbying.

Every 3 months, lobbyists file reports of their lobbying activities in the previous three months. Failure to register and file reports can result in fines and suspension, or cancellation of City contracts or actions.

All lobbyists’ filings are available for examination in paper and through the Board’s website.

CAMPAIGN CONTRIBUTION LIMITATIONS

The Ordinance regulates campaign contributions to elected City officials and candidates for elected City office.

→        Anonymous contributions and those made other than in the name of the true donor are prohibited.

→        Contributions based on an understanding that the candidate’s votes or official actions would be influenced are prohibited.

→        Cash contributions exceeding $250 are prohibited.

Contributions are limited to $1500 per candidate per calendar year from:

→        Lobbyists registered with the City;

→        Persons seeking to do business with, or who, within the preceding four years, have done business with, the City or the CTA, Board of Education, Park District, City Colleges, or Metropolitan Pier and Exposition Authority

The $1500 limit applies to contributions to:

→        Each candidate for City office during a single candidacy; or

→        Each City elected official per calendar year or any City employee or official seeking election to any non-City office.

Persons who violate these limitations and the political committees to whom they contribute are subject to fines up to $5,000 or three times the excessive contribution. Other laws also limit contributions to candidates for elected City office, including the Illinois Election Code.

NOTE: By Mayoral Executive Order, lobbyists, City contractors and subcontractors and their owners, spouses or domestic partners, are prohibited from contributing to the Mayor’s political committee.

MANDATORY ETHICS EDUCATION

All lobbyists, elected officials, appointed officials and full-time City employees must complete an annual ethics training program designed by the Board. Aldermen, City Council employees and all Senior Executive employees must attend face-to-face ethics training every four years.  New employees must complete ethics training within 2 months of their start date.

FINANCIAL DISCLOSURE

Article II of the Ordinance requires that following persons file annual Statement of Financial Interests:

• All appointed officials, except members of a board that is solely advisory in nature;
• All elected City officials;
• City employees at the managerial level

Filers disclose, among other things:

• Certain non-City compensation and gifts;
• Sources of certain capital gains realized, and stock ownership;
• Ownership of businesses in the City; and
• Investment or income-generating real estate owned and located in the City.

All Statements filed with the Board are available for public examination for seven years after filing.  Statements filed in 2009 and after are posted on the City’s website.   Older forms are available from the Board.

INVESTIGATIONS AND ADJUDICATIONS

The Board can accept and refer for investigation complaints alleging violations of the Ordinance by City employees, officials and others subject to their provisions. If, after a complaint is investigated by the appropriate Inspector General, the Board concludes that there is reasonable cause to believe the law was violated, it may settle the matter, or hold an evidentiary hearing to determine whether the Ordinance was actually violated.  All complaints, Board investigations, determinations and recommendations thereon are confidential in accordance with the Ordinances, though settlement agreements and findings of violations must be made public.

WHISTLEBLOWER PROTECTION

The ethics law provides that any person who experiences retaliatory action as a result of reporting violations of the law or rules or providing information in an investigation can recover damages, be reinstated with double back pay, or  have regulatory or financial denials reconsidered.

PENALTIES

The Board determines whether violations of the law have occurred, and can impose or recommend penalties, including employment sanctions, removal from office, censure, fines or invalidation of contracts. Summaries of concluded cases can be made public, according to the law.