Center for the Study of Ethics in the Professions at IIT

OFFICE OF THE COUNTY MANAGER
CLARK COUNTY, NEVADA

ADMINISTRATIVE DIRECTIVE NO. 18
EFFECTIVE DATE: July 14, 1980
REVISION DATE:

SUBJECT: CONFLICT OF INTEREST GUIDELINES FOR COUNTY EMPLOYEES

I.PURPOSE

A potential conflict of interest exists anytime a County employee has an interest in any other entity that transacts business with the County. An interest includes ownership, employment, participation or an opportunity to derive personal gain. An entity includes individuals, companies, partnerships, corporations, organizations and other governmental agencies.

Clark County is a multi-million dollar government. Daily transactions include the provisions of goods and services, the procurement of goods and services, and the regulation and enforcement functions that extend far beyond its political boundaries. A County employee's involvement in any activity that is, has a high potential of becoming, or appears to be a conflict of interest must be prohibited. Consequently, clear guidelines must be set forth to assist employees in avoiding situations that can be defined as a conflict of interest.

II. ORGANIZATIONS AFFECTED

All County departments.

III. PROCEDURE

Through this directive, the County Manager hereby establishes the following guidelines for minimum standards applicable to all County employees. These minimum standards shall be included in any additional delineation of standards promulgated by individual departments.

A. Minimum standard requirements for all employees

1. Involvement by a County employee in conflict of interest situations is prohibited.

2. Violation of the Code of Conduct as-enumerated in County Code 2.40.130 may be cause for discipline up to and including termination.

3. Cash or negotiable instruments of any kind may not be accepted by a County employee. Violation of this policy may be grounds for discipline up to and including termination.

4. Acceptance and/or use of a card or other vehicle which provides undefined benefit(s) (food, beverage, entertainment, etc.) to a specific individual or individuals named on the card or vehicle is strictly prohibited. Violation of this policy may be cause for diSCiDline up to and including termination.

5. County employees may not accept complimentary benefits of any kind from any person, firm or other entity with whom that employee is currently dealing in an official County business capacity. "Currently dealing" as referenced in this section means a transaction or business
in which a county employee has the authority and capability of using judgmental or administrative discretion in conducting official business with any person, firm,or other entity as opposed to a routine business interaction which is primarily procedural in nature and conducted in accordance with the rules, work load, and service requirements of the employee's department (i.e., recording a document, sweeping a street, accepting an application, etc.)

6. Past complimentary benefits accepted by a County employee from a person, firm or other entity with which that employee is newly dealing in an official county business capacity will be disclosed to that employee's supervisor. If the supervisor determines that the employee must continue in an official capacity having accepted past complimentary benefits, action will be taken to insure the objectivity of the actions of the employee and the protection of the employee's reputation and integrity.

B. The County Manager will prepare additional guidelines pertaining to conflict of interest standards relative to appointed officials and will insure compliance with this directive.

Elected or Appointed heads of all County departments and agencies shall: 1) insure that each employee is made aware of the provisions of this directive, 2) prepare guidelines further defining conflict of interest situations within their realm of authority and/or interest.

Guidelines should provide:

a. examples of activities indigenous to that department that could be construed to be a conflict of interest.

b. examples of activities indigenous to that department that would not be construed to be a conflict of interest.

C. a list of any additional departmental requirements necessary to insure compliance with this directive, (e.g., requests for permission for outside employment).