Ethics and Elections Commission Wayne Barnett, Executive Director
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Working with Former Clients and Employers

  1. Can I continue to work for current and former clients of my consulting business after I've accepted a job with the City?

    Answer: Generally, yes, so long as you do not use City paid time or facilities to conduct your private business, and as long as your outside business does not overlap with your City responsibilities.

  2. I was hired to work on the contract that the City has with my former employer. I've heard that I cannot do that. Do I have to find another job?

    Answer: Probably not, but the Code may require temporary modifications of your job. The Code prohibits you (or any Covered Individual) from participating on a City matter in which a person who has employed you or retained you or your firm, within the past 12 months, has a financial interest.

    In 2009, amendments to the Code provided the possibility of a waiver of this provision. If your department head submits to the SEEC Executive Director a written determination that there is a compelling City need for you to participate in matters in which your former employer or client has a financial interest, with a written plan showing how management will safeguard the City's interests, and the Executive Director agrees that the plan is satisfactory, a waiver may be granted.

    If the plan is not approved, or your department head determines that your assignment does not serve a compelling City need, you may need to work on different duties until 12 months has passed.

For assistance, contact the SEEC.

Last updated April 13, 2011.

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