HomeMy WebLinkAboutStaff Report 2609-6756CITY OF PALO ALTO
CITY COUNCIL
Special Meeting
Monday, September 28, 2026
Council Chambers & Hybrid
5:30 PM
Agenda Item
B.Conflict of Interest Code 2026 Local Agency Biennial Notice; CEQA Status – Not a Project
City Council
Staff Report
From: City Manager
Report Type: INFORMATION REPORTS
Lead Department: City Clerk
Meeting Date: September 28, 2026
Report #:2609-6756
TITLE
Conflict of Interest Code 2026 Local Agency Biennial Notice; CEQA Status – Not a Project
RECOMMENDATION
Receive the attached Conflict of Interest Code 2026 Local Agency Biennial Notice. No City Council
action is required.
BACKGROUND / ANALYSIS
The Palo Alto Municipal Code1 and the Political Reform Act2 require the City to adopt a list of
designated positions and disclosure responsibilities for each position subject to the Conflict of
Interest Code for Designated Employees. The Conflict of Interest Code lists specific City positions
other than those specified in Government Code section 87200 which involve making or
participating in making decisions which have a reasonably foreseeable material effect on an
economic interest, and to designate for each position the specific types of investments, business
positions, interests in real property and sources of income which are reportable based on the
scope of the decision-making authority of the position. The City Council adopts the Conflict of
Interest Code by resolution.
The Political Reform Act requires the City to review its Conflict of Interest Code every two years,
typically in even-numbered years. The City Council most recently reviewed and adopted the
Conflict of Interest Code in February 2025. While the City is in compliance with the 2-year
requirement, potential updates have been identified and staff recommends proceeding with
these updates to stay consistent with the even-numbered year cycle.
In accordance with these requirements, the attached notice must be submitted to the City
Council by October 1, 2026. As stated in the notice, code updates have been identified and are
1 City of Palo Alto Municipal Code, Chapter 2.09:
https://codelibrary.amlegal.com/codes/paloalto/latest/paloalto_ca/0-0-0-60594
2 Government Code, Title 9, Chapter 7, Article 3:
https://www.leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=GOV&division=&title=9.&part=&c
hapter=7.&article=3
being prepared by staff. Staff anticipates presenting the recommended code updates to Council
by the end of calendar year 2026.
FISCAL/RESOURCE IMPACT
STAKEHOLDER ENGAGEMENT
ENVIRONMENTAL REVIEW
ATTACHMENTS
APPROVED BY:
www.fppc.ca.gov
FPPC Advice: advice@fppc.ca.gov (866.275.3772)
Page 1 of 1
2026 Local Agency Biennial Notice
Name of Agency:
Mailing Address:
Contact Person: Phone No.
Email: Alternate Email:
Accurate disclosure is essential to monitor whether officials have conflicts of interest and to
help ensure public trust in government. The biennial review examines current programs to
ensure that the agency’s code includes disclosure by those agency officials who make or
participate in making governmental decisions.
This agency has reviewed its conflict of interest code and has determined that (check one BOX):
An amendment is required. The following amendments are necessary:
(Check all that apply.)
Include new positions
Revise disclosure categories
Revise the titles of existing positions
Delete titles of positions that have been abolished and/or positions that no longer make or
participate in making governmental decisions
Other (describe)
The code is currently under review by the code reviewing body.
No amendment is required. (If your code is over five years old, amendments may be
necessary.)
Verification (to be completed if no amendment is required)
This agency’s code accurately designates all positions that make or participate in the making of governmental
decisions. The disclosure assigned to those positions accurately requires that all investments, business
positions, interests in real property, and sources of income that may foreseeably be affected materially by the
decisions made by those holding designated positions are reported. The code includes all other provisions
required by Government Code Section 87302.
__________________________________________ _________________________
Signature of Chief Executive Officer Date
All agencies must complete and return this notice regardless of how recently your code was approved or
amended. Please return this notice no later than October 1, 2026, or by the date specified by your agency, if
earlier, to:
(PLACE RETURN ADDRESS OF CODE REVIEWING BODY HERE)
PLEASE DO NOT RETURN THIS FORM TO THE FPPC.
City of Palo Alto
250 Hamilton Avenue, Palo Alto, CA 94301
Mahealani Ah Yun, City Clerk (650) 329-2571
city.clerk@paloalto.gov mahealani.ahyun@paloalto.gov
4
4
4
4
4