The Ethics Office

The Ethics Office acts independently, but enlists members of the Board of Directors and Executive Officers to add to the objectivity of review, creativity in fact-finding, and appropriate routing of non-ethics concerns.

Initial Review

The initial Review of questions and concerns is conducted by the Ethics Offices.  The Ethics Office may contact employees, officers, Directors, contractors and members of the public in the process of investigation. Many matters are resolved at this level.

Committees

The Ethics Office uses two Intake Committees: a committee for concerns regarding staff and contractor behavior and a committee for Director Concerns. Both committees meet as needed.

Matters that are not resolved through initial review proceed to Intake Committee.

Members of the Intake Committee for concerns regarding staff and contractor behavior include General Auditor or designee, General Counsel or designee, Human Resources Director and General Manager or designee. The Ethics Officer chairs the Committee. Members of the Intake Committee for Director Concerns include Board Secretary, two additional board members (appointed by Board Chair), General Counsel or designee and General Manager or designee. The Ethics Officer chairs this committee.

Intake Committee activities are reported in the Ethics Officer’s Monthly Report to the Board of Directors. Initial review of all matters will be complete within one calendar month of receipt.

Appeals, Intake Committee for Director Concerns

In the case of a director who has expressed a concern or of someone who has expressed a concern regarding a director and who is not satisfied by the Ethics Officer's disposition, the concern will proceed directly to the Inquiry & Review Committee.

If the Ethics Officer determines that a concern is not within the scope of the Ethics Office or should not proceed to Inquiry & Review for formal review, the person expressing the concern may wish to appeal. At this person's request, the Ethics Officer will add the matter to the agenda of the next Intake Committee meeting. The person may appear before that committee, either in person or via speaker phone, to make the case of why the matter should proceed for formal review. The Ethics Officer will distribute materials, as provided by the person expressing concern, prior to the meeting. The determination of the Committee will be final. If so determined by the Intake Committee, the Ethics Officer will refer the matter for Inquiry & Review. If so determined by the Intake Committee, the person expressing concern must accept the judgment of the committee not to take the matter forward.

The Ethics Officer reviews all suggestions for improvement, questions, expressions of concern, and allegations of non-compliance.

Expressions of concern and significant inquires are logged into a tracking system and reported in the Ethics Officer’s Monthly Report. Those who identify themselves when they communicate with the Ethics Office will receive notice of disposition.

The Intake Committees review expressions of concern and allegation of non-compliance with the goal of seeking consensus on one of the following dispositions:

• Not within the scope of the Ethics Office
• Referred for Policy Review
• Referred to Appropriate Department
• Resolved informally
  
• Referred to Inquiry & Review
• Unsubstantiated

The Ethics Officer makes an independent determination for how the concern should be handled based on the input from Intake Committee.