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Explanation of the City's Ethics Code
for Contractors, Vendors, Customers, and Clients

The Seattle Ethics Code is the City's commitment to the values of integrity, accountability, stewardship, and independence in the performance of our jobs. The Code sets ethical standards about work activities, business relationships, and the use of City resources that apply to all City employees, elected officials, members of most City boards and commissions, and City contractors and vendors who provide more than 1,000 hours of service to the City in any 12 month period.

Here are some examples of issues that arise in official dealings with individuals covered by the Ethics Code. For more information, please contact the SEEC. You may also download a brochure, in PDF format, that explains the Code.

Click or scroll down for answers regarding the following topics.

GIFTS

In 2006 the Commission adopted an interpretive rule that describes some circumstances under which gifts accepted by City employees and officials would not violate the Code. It also sets some parameters for accepting gifts. You may download the "Gift Rule" (PDF) for guidance in your dealings with City employees and officials. Covered Individuals who are offered gifts outside of the "safe harbors" described in the Rule should either decline the gift or call the Commission office for guidance.

  1. Question: I would like to deliver a large basket of fruit and candy to a City work group thanking them for the work we've done together. Is this permitted?

    Answer: If you want to appreciate people you've worked with, it is permissible for you to send tokens of appreciation that are valued at $25 or less and can be shared in the workplace, such as a box of candy or flowers. Elaborate bouquets or gift baskets exceeding that value are not appropriate. Moreover, the cumulative value of such items must not exceed $50 from a single source in a calendar year.

    City employees may not accept gifts, entertainment, loans, favors, or other things of value that appear to be given to influence future City actions. If you want to thank a City employee, the best way is to write a letter of praise to the employee's supervisor or department head.

    Employees cannot receive gifts or premiums for the City orders they place, and they cannot purchase items for their personal use under the City's discount. Be sure that any special discounts you offer to City employees are vetted through the City's process. Contact us for more information.


  2. Question: Is it okay to invite a City workgroup to an open house at our office to celebrate the work we've done together?

    Answer: This situation is not one of the "safe harbors" described in the Gift Rule for Covered Individuals who participate in "contractual or regulatory decisions" with a consultant or vendor. The answer depends on the nature of the work that you do and that the City workers do, and the nature of the event. Covered Individuals are encouraged to turn down such invitations or contact the SEEC for advice.

SOLICITING ITEMS

  1. Question: Is it OK for an employee to ask me for a donation to a charity auction?

    Answer: City employees may not ask people with whom they do City business to donate items, whether for personal, charitable, or other purposes. Nor can they accept unsolicited items from you for charitable purposes.

    Employees also cannot ask businesses they regulate or inspect for donations of meeting spaces or supplies or for any other item of value.

NO FREE MEALS

  1. Question: When I'm meeting with City employees over lunch, I'd like to treat them out of my expense account. Is this ok?

    Answer: No, Covered Individuals may not accept free meals from people with whom they do City business, or who wish to do business with the City. The Covered Individual should pay his or her own way each time.

REFRESHMENTS AT MEETINGS

  1. Question: Are we prohibited from offering City employees refreshments during a meeting in our office?

    Answer: No. City employees may accept basic refreshments--such as coffee, tea, soft drinks, doughnuts, or cookies--when attending meetings in your office. If the meeting spans mealtime, you may provide a simple meal, such as box lunches. Otherwise, whether meeting in your office or in a restaurant, employees must pay for their own meals.

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USE OF CITY FACILITIES AND RESOURCES

  1. Question: Can we use the City's tools for our project?

    Answer: If your contract with the City calls for the City to provide tools, then of course you may. However, City property, including City paid time, vehicles, tools, and equipment may only be used for a City purpose. A Covered Individual may not use them or loan them for private use.

CONFLICT OF INTERESTS

  1. Question: Our City project manager's spouse has just hired on with our company. Is there any problem with this?

    Answer: It depends on several factors. If the spouse stands to gain from the project manager's City duties, the employee must stop working on your project. We encourage you or the employee to contact the SEEC for advice.

    The Ethics Code says that a Covered Individual may not take part in City business where any of the following have a financial interest:
    i) the Covered Individual;
    ii) an immediate family member of the Covered Individual;
    iii) an individual residing with the Covered Individual;
    iv) a person the Covered Individual serves as an officer, director, trustee, partner or employee;
    v) a person with which the Covered Individual is seeking or has an arrangement concerning future employment.

    Even if they do not have actual financial interests in your project, Covered Individuals also are prohibited from taking part in City business where their outside activities or relationships would appear to have impair their judgment, unless they disclose the situation to their department head and the SEEC Executive Director. This gives management and the public an opportunity to weigh in on the appropriateness of the Covered Individual being involved.

    This includes selection processes. City employees must withdraw from a vendor selection process if one of the competitors is a relative or household member, or if a competitor has been the employee's business partner or client within the last twelve months, or if the employee's relationship with the candidate would appear to a reasonable person to impair the employee's judgment.


  2. Question: I'd like to hire the City employee I deal with all the time. May I offer her a job?

    Answer: You may offer the employee a job. Be aware, though, that once you open discussions about prospective employment with a City employee, that employee cannot be involved in City matters affecting your business. A reasonable person will believe that your discussions have created a conflict of interest, and will influence the employee's dealings with you. See below for limits on a former employee's activities after leaving City employment.

ADVERTISING

  1. Question: People who use the City's services could also use mine. Is it ok for me to give a supply of brochures to the City employees I deal with?

    Answer: Employees cannot use their positions for anyone's private gain, or use City resources for a non-City purpose. Therefore, they cannot hand out or post advertising materials, including your discount coupons or other promotional items.

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INVITATIONS TO SEMINARS & CONFERENCES

  1. Question: My company would like to fly the City employee I deal with to our head office for some training. Can we?

    Answer: City employees may attend conferences paid for by City vendors or potential vendors only under limited conditions outlined in Section III.4.c. of the Gift Rule: 1) the gift complies with City and departmental policies for accepting gifts, 2) the expenses are reimbursable under the City's Travel Policies and Procedures, 3) the City--not the donor--determines who will use the gift, and 4) the City's receipt of the gift is documented appropriately.

    Neither the City nor the employee can accept reimbursement for expenses incurred that are not allowable under the City's Travel Policies and Procedures. In all cases, the event must serve a City purpose. If you are required by contract to provide training or education to City employees, the employee's attendance is subject to the above conditions.

    Remember, reimbursement for travel and lodging must be made to the City, not to the individual. And the employee cannot accept your treat for special events connected with the conference trip, such as a golf game or night on the town.

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AFTER LEAVING CITY EMPLOYMENT

  1. Question: I'd like to hire an employee I've dealt with at the City. May I?

    Answer: You may hire a current or former City employee. Keep in mind, however, that the Ethics Code places some restrictions on that employee's activities following separation from the City:
    For two years after leaving City office or employment, City officers and employees cannot assist anyone on a matter in which they participated while employed by the City.
    For one year former City officers or employees cannot communicate on behalf of any person on a matter involving the City, with an employee of the agency with which he or she was previously employed.
    For one year a Covered Individual cannot participate as a competitor in any competitive selection process for a City contract in which he or she assisted in determinine the project or work to be done or the process to be used in selecting the contractor.
    The Covered Individual is also prohibited from sharing or using confidential information that is not otherwise available to the public. This prohibition has no time limit.

    Please also see #8 under Conflict of Interests above, regarding limitations on the activities of a current employee receiving a job offer from a City contractor.

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ETHICS COMPLAINTS AND CONSEQUENCES

  1. Question: What do I do if I see inappropriate action by a City employee?

    Answer: Anyone who feels a City officer or employee has violated the Ethics Code may bring it to the attention of the Ethics and Elections Commission. Commission staff will investigate whether there is a Code violation.

    If the Commission finds that an employee or official violated the City's Ethics Code, it may fine that person up to $5,000 per violation, plus costs and restitution. The Commission may also recommend disciplinary action, including suspension or discharge. A complaint may be dismissed if investigation finds no violation of the Code or if the violation is minor and inadvertent or has already been remedied.

    See the questions and answers about "Complaint Procedures" and "Penalties" for more information. Potential fines for members of Advisory Boards and Commissions differ from those for employees.

For the more information, see the Ethics Code,
SMC 4.16, or contact the SEEC.

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Last updated April 13, 2011.



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