Conflict of Interest Code

On February 8, 2011, the Board of Supervisors approved the County of Santa Clara's amended Conflict of Interest Code with Exhibits for County Departments, Boards, and Commissions.

Pursuant to the California Political Reform Act, all public agencies are required to adopt a conflict of interest code. Each agency conflict-of-interest code must designate, or include, the employee positions within that agency "which involve the making or participation in the making of decisions which may foreseeably have a material effect on any financial interest" of the employee, and assign disclosure categories specifying the types of financial interests to be reported. (Gov. Code section 87302(a).) Individuals holding designated positions are required to file Statements of Economic Interests (Form 700s). The Form 700 is a public document intended to alert public officials and members of the public to the types of financial interests that may create conflicts of interest.

The text of the County's code is available on this website. In the addendum to the County's conflict of interest code, each County department, board, and commission (Code Agency) has an Exhibit A listing its designated positions and an Exhibit B listing its disclosure categories. Disclosure categories 1 and 2 are predefined by the County, for shared use among the Code Agencies. Each Code Agency has created additional disclosure categories to reflect the required disclosures specific to its designated positions. Each Code Agency's Exhibits are available on this website.

Pursuant to the procedure approved by the Board of Supervisors on December 14, 1999, County Counsel has reviewed the County's code and each of the submitted exhibits to ensure they meet the requirements of Government Code Section 87309, providing:

  1. A description of the manner in which the Code will require all foreseeable potential conflict of interest situations to be disclosed or prevented;
  2. A description of the manner in which the Code provides each affected person a clear and specific statement of his or her duties under the Code; and
  3. A description of the manner in which the Code has differentiated between designated employees with different


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