Board Policy - Section Number: 07.17.00.00

Purpose and Policy

To require Commissioners’ Aides, and interns and volunteers of the Hillsborough County Board of County Commissioners or an individual Commissioner’s office (hereinafter “covered persons”) to disclose potential conflicts of interests, including outside business interests and activities. To establish procedures for determining if such outside business interests and activities are in conflict with the covered person’s duties, or are otherwise not within the best interest of Hillsborough County.

Covered persons are prohibited from having any direct or indirect outside business interest, financial or otherwise, engaging in any business transaction, engaging in any professional activity, including outside employment, or incurring any obligation of any nature that is in conflict with the covered person’s duties, the business of the Board of County Commissioners, or otherwise not within the best interest of Hillsborough County.

Further, covered persons are specifically prohibited from renting, leasing, or selling any realty, goods, or services to the County, having or holding any employment with any business entity doing business with the County, or having or holding any employment or contractual relationship that will create a conflict between the covered person’s private interests and the performance of the covered person’s official public duties or that would impede the full and faithful discharge of said official public duties.

Covered persons are required to timely disclose any and all actual or potential conflicts of interest in accordance with the procedures and timelines outlined in this policy.

I. Procedure

• Covered persons are required to complete a Disclosure Questionnaire (Attachment 1) within forty-five (45) days of being hired or beginning service with Hillsborough County and/or
• Any other change in employment, intern or volunteer status resulting in a change in job title or a significant change in duties.
• In addition to the requirement in Paragraph 1 above, covered persons are required to complete a Disclosure Questionnaire (Attachment 1) within forty-five (45) days of any change in the covered person’s “conflict of interest” status. For the purposes of this policy, a change in conflict of interest status includes, but is not limited to:
• The covered person being employed by, or serving as an independent contractor for, any person or entity other than Hillsborough County, including self-employment.
• The covered person, or the covered person’s spouse or child, owning a business in whole or part, directly or indirectly.
• The covered person, or the covered person’s spouse or child, owning more than five percent (5%) of the total stock of any business.
• The covered person, or the covered person’s spouse or child, entering into a contractual relationship that may create a conflict between the covered person’s private interests and the performance of the covered person’s official public duties or that may impede the full and faithful discharge of said official public duties.
• The covered person, or the covered person’s spouse or child, serving as an officer, partner, director, or proprietor of any business entity.
• The covered person receiving any salary or payment, other than retirement benefits, from a person or an entity other than Hillsborough County.
• The covered person receiving rental proceeds from any real property.
• The covered person having an active or inactive professional or business license that may directly or indirectly relate to the business of the Commissioner for whom he or she works, or the Commission.
• Depending upon the covered person’s responses to the Disclosure Questionnaire (Attachment 1), it may be necessary for the covered person to also complete a Disclosure Statement (Attachment 2) within the above-specified timeframes.
• Completed Disclosure Questionnaires and completed Disclosure Statements shall be submitted by the covered person to the covered person’s Commissioner for review. Interns or volunteers working for the Board shall submit completed Disclosure Questionnaires and completed Disclosure Statements to the Chairperson.
• The Commissioner (or Chairperson, as applicable) will then seek advice from the County Attorney who will work with the Human Resources Director to provide guidance and a recommendation as to whether a conflict of interest exists.
• Where the Commissioner (or Chairperson, as applicable) determines that a conflict of interest exists, the Commissioner shall inform the covered person in writing and provide the covered person with a reasonable period of time, within the sole discretion of the Commissioner, to resolve the conflict of interest to the satisfaction of the Commissioner.
• The covered person shall submit proof to the Commissioner (or Chairperson, as applicable) of the resolution of any conflict of interest within the specified time frame.
• All documents created by or utilized by the Commissioner (or Chairperson, as applicable) in determining whether or not a conflict of interest exists shall be kept in the covered person’s personnel or intern/volunteer file.
• The Commissioner’s Aide may be subject to discipline, up to and including dismissal, and the intern or volunteer may be subject to dismissal from service of the County for:
• Failure to timely submit a required Disclosure Questionnaire or Disclosure Statement, or additional information requested by the Commissioner.
• Providing false or incomplete information on a required Disclosure Questionnaire or Disclosure Statement.
• Providing false or incomplete information to the Commissioner or making false or misleading statements to the Commissioner.
• Failure to timely resolve any conflict of interest found by the Commissioner to the satisfaction of the Commissioner.