PURPOSE

The purpose of this policy is to establish the Conflict of Interest Code for SCERS as required by the Political Reform Act (Government Code Section 81000, et seq.) for state and local agencies.

POLICY

The Fair Political Practices Commission (FPPC) has adopted a regulation, 2 Cal. Code of Regs. Section 18730 that contains the terms of a standard conflict of interest code. The terms of that Section 18730 and any amendments thereto adopted by the FPPC are hereby incorporated by reference and, along with the attached Appendix A – Designated Positions, Appendix B – Disclosure Categories, and Appendix C – Agency Positions that Manage Public Investments for the Purpose of Government Code Section 87200, constitute the Sacramento County Employees’ Retirement System (SCERS) Conflict of Interest Code (Code).

APPLICATION

Pursuant to Section 4 of the standard conflict of interest code, designated employees shall file statements of economic interest (Form 700) with the Sacramento County Clerk. Any SCERS Retirement Board members or employees already required to file statements of economic interest pursuant to Government Code Section 87200, et seq. are identified in Appendix C and no additional disclosure is required by this Code. Officials designated in Appendix C shall file their disclosure statements with the Sacramento County Clerk or to the appropriate agency pursuant to 2 Cal. Code of Regs. Section 18753(d).

Responsibility for accurately reporting disclosable interest rests solely with the person(s) required to file pursuant to statute or this Code and not with SCERS.

Pursuant to Government Code Section 87314, Appendix C entitled “Agency Positions that Manage Public Investments for the Purpose of Section 87200 of the Government Code” shall remain posted on SCERS website in a manner that is easily identifiable and accessible.

BACKGROUND

The Political Reform Act, Government Code Section 81000, et seq., requires every state and local government agency to adopt a conflict of interest code. The FPPC has adopted regulation, 2 Cal. Code of Regs. Section 18730 that contains the terms of a standard conflict of interest code, and which may be amended by the FPPC after public notice and hearings to conform to amendments to the Political Reform Act. This standard conflict of interest code can be incorporated by reference into local conflict of interest codes.

RESPONSIBILITIES

Executive Owner: General Counsel
Review Frequency: At least once every two years (usually pursuant to written notice from the Sacramento County Board of Supervisors)

POLICY HISTORY

Date	Description
07-14-2020	Approved by Board of Supervisors
02-19-2020	Board amended Appendix A to include Public Information Officer and Appendix C to        include all Investment Officer classifications
09-18-2019	Board amended Appendix A to include Communication Officer
04-24-2018	Approved by Board Of Supervisors
02-21-2018	Board amended Code in revised format by Resolution 2018-02
02-28-2017	Approved by Board of Supervisors
08-17-2016	Board amended Appendix A; Resolution 2016-07
03-24-2010	Approved by Board of Supervisors
02-18-2010	Board amended Appendix A; Resolution 2010-03
12-05-2000	Approved by Board of Supervisors
10-19-2000	Board replaced Code in Resolution 2000-05
05-23-1985	Board adopted Code

APPENDIX A

DESIGNATED POSITIONS

Persons occupying the following positions are designated as persons who must disclose economic interests as specified under categories described in Appendix B.

POSITION	DISCLOSURE CATEGORY
Chief Benefits Officer	All Categories (Asst. Retirement Administrator –  Benefits)
Chief Operations Officer	All Categories (Asst. Retirement Administrator – Operations)
Chief Strategy Officer	All Categories (Asst. Retirement Administrator – Enterprise Solutions Management)
General Counsel	All Categories (Retirement General Counsel)
Public Information Officer	All Categories (Public Information Officer, Senior Public Information Officer)
Retirement Services Managers	Category 3
Senior Accounting Manager	Category 3
Accounting Managers	Category 3
Senior IT Analyst	Category 3
Consultants*	All Categories

* The Chief Executive Officer may determine that a particular consultant performs a type or range of duties that would cause the consultant to be subject to comply with the disclosure requirements described in this Code. Such determination shall be made in the sole discretion of the Chief Executive Officer in writing and include a description of the consultant’s duties upon which the requirement and extent of disclosure is based. The determination is a public record and shall be retained for public inspection in the same manner and location as this Code.

NOTE: The following positions, although not designated in this Conflict of Interest Code, are required to file Form 700 as “public officials who manage public investments” under Government Code Section 87200:

Retirement Board Members
Chief Executive Officer (Retirement Administrator)
Chief Investment Officer (Chief Investment Officer – Retirement)
Deputy Chief Investment Officer (Asst. Retirement Administrator – Investments)
Investment Officers (Senior Retirement Investment Officer, Retirement Investment Officer, Retirement Investment Analyst)

APPENDIX B

DISCLOSURE CATEGORIES1

CATEGORY 1

Investments in any business, entity, or real estate venture of the type which the Retirement Board is legally authorized to invest, or in any type of entity that provides services or supplies of the type used by SCERS (currently Schedules A-1 and/or A-2 of Form 700)

CATEGORY 2

Interests in Real Property that could be affected by any decision made or participated in by the designated individual (currently Schedules B and/or C of Form 700). If the designated individual is a trustee or SCERS employee, disclosure is only required on real property located in the County of Sacramento.

CATEGORY 3

Income from any source of the type in which the Retirement Board is legally authorized to invest, or from any person or entity that provides services or supplies of the type used by SCERS (currently Schedules, C, D, E, and/or F of Form 700).

CATEGORY 4

Any Position Held as a director, officer, partner, trustee, or any position of management in any business entity that offers or holds investments of the type in which the Retirement Board is legally authorized to invest, or in any type of entity that provides services or supplies of the type used by SCERS (currently Schedule C of Form 700).

1 Only investments in and sources of income from business entities, and sources of income which do business in the geographic area of SCERS, or real property interests located in the County of Sacramento need to be reported.

APPENDIX C

Agency Positions that Manage Public Investments for Purposes of Section 87200 of the Government Code

Retirement Board Members Chief Executive Officer (Retirement Administrator)
Chief Investment Officer (Chief Investment Officer – Retirement)
Deputy Chief Investment Officer (Asst. Retirement Administrator – Investments)
Investment Officers (Senior Retirement Investment Officer, Retirement Investment Officer, Retirement Investment Analyst)

SCERS Policy No. 027