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2025-06-12 - Ethics Commission - Agenda Packet Page 1 of 1 AGENDA ETHICS COMMISSION Regular Meeting: June 12, 2025 at 6:00 PM Beverly Sussman Conference Room Fifty Raupp Blvd Buffalo Grove, IL 60089-2139 1. Call to Order 2. Approval of Minutes A. Minutes from the November 14, 2024 Regular Meeting 3. Introduction of Members A. Introduction of Trustee Liaison Kevin Richards (, ) 4. Appointment of Recording Secretary 5. Workgroup Reports A. Educating Boards, Commissions and Committees - Review of Educational Presentation B. Review for Completeness of Disclosure - CY 2024 Statements 6. Public Comment Public Comment is limited to items that are not on the regular agenda. In accordance with Section 2.02.070 of the Municipal Code, discussion on questions from the audience will be limited to 5 minutes and should be limited to concerns or comments regarding issues that are relevant to Ethics Commission business. All members of the public addressing the Ethics Commission shall maintain proper decorum and refrain from making disrespectful remarks or comments relating to individuals. Speakers shall use every attempt to not be repetitive of points that have been made by others. The Ethics Commission may refer any matter of public comment to the Village Manager, Village staff or an appropriate agency for review. 7. Adjournment The Village of Buffalo Grove, in compliance with the Americans with Disabilities Act, requests that persons with disabilities who require certain accommodations to allow them to observe and/or participate in this meeting or have questions about the accessibility of the meeting or facilities, contact the ADA Coordinator at 847-459-2500 to allow the Village to make reasonable accommodations for those persons. Page 1 of 45 1 MINUTES OF THE REGULAR MEETING OF THE ETHICS COMMISSION OF THE VILLAGE OF BUFFALO GROVE THURSDAY, NOVEMBER 14, 2024 CALL TO ORDER Chair Berman called the meeting to order at 6:05 P.M. This meeting was held at Village Hall, 50 Raupp Boulevard, Buffalo Grove ROLL CALL Roll call indicated commissioners were present: Chair Jeffrey Berman, Commissioners Pragnesh Patel, Leslie Abella and Richard Bellows, Danielle Rodbro were present. Also present were Dane Bragg, Village Manager; Trustee Frank Cesario and Village Attorney, Patrick Brankin. APPROVAL OF MINUTES Commissioner Abella made a motion to approve the minutes of June 20, 2024 which Commissioner Patel seconded. Motion approved by unanimous voice vote. REVIEW OF FUNCTIONS AND DUTIES OF THE COMMISSION A. Amend 2.49.060 Order of Proceedings •An overview was given by Attorney Brankin as to a suggested amendment to Section 2.49.060. •A motion was made to approve by Commissioner Bellows and seconded by Commissioner Patel, after discussion an amended motion was made by Commissioner Abella and seconded by Commissioner Bellows, to replace the word ‘and’ with the words ‘as well as’. The amended motion was approved by unanimous voice vote. WORKGROUP REPORTS Educating Boards, Commissions and Committees Review The Commission reviewed the draft of an education deck intended to be shared with Village Commissions, Committees and Board members using recorded means. After discussion, concurrence was to proceed with deck as presented. QUESTIONS FROM THE AUDIENCE No members of the public were in attendance. ADJOURNMENT A motion to adjourn the meeting was made by Commissioner Abella and seconded by Commissioner Rodbro. Upon voice vote, the vote was unanimous. Motion declared carried. The meeting was adjourned at 7:10 P.M. Page 2 of 45 2 Prepared by: Patrick T. Brankin, Village Attorney APPROVED BY ME THIS DAY OF _____2024 Jeffrey Berman, Chair, Ethics Commission Page 3 of 45 ETHICS TRAINING 2024 Page 4 of 45 Introduction Recent changes to municipal code Purpose of the Ethics Commission To recommend to the Corporate Authorities modifications to The Ethics Commission's procedures and rules governing the performance of its duties….  Review for completeness of disclosure statements required by Chapter 2.48 of  the Village Code… Educate Village Boards and Commissions about the ethics requirements of the Village Code and Illinois State Statute. Page 5 of 45 Responsibility Village Board Policy Ethics Commission Oversight Staff Compliance You Good Governance Page 6 of 45 Recent changes Streamlined filing requirements •No longer a County and local statement of economic interest. •All persons required to file do so with Cook County. •You will receive an email for annual Cook County SEI filing from the Cook County Clerk. •All filings are due by May 1 of each year. •Village will remind you of filing requirements. Local Conflict of Interest (COI) disclosure •Filed at time of appointment. •Annual filing is due by May 1 of each year. •Need to amend filing if conflict of interest changes. •COI disclaimer is filed with the Village Clerk’s office. Paperless processes All filings are online; no paper forms. Page 7 of 45 What will be covered Disclosure requirements Illinois Governmental Ethics Act 5 ILCS 420 Procurement policies Examples Managing conflicts of interest Page 8 of 45 Disclosure requirements Page 9 of 45 Cook County Statement of Economic Interest ü Required annually. ü Because Village Hall is in Cook County, you file your SEI with Cook County regardless of the county you live in. ü Single assets with a value in excess of $10,000. ü Source of income in excess of $7,500 annually. ü Single debts with a value in excess of $10,000. ü Government employment for you or a spouse. ü Gift or gifts, honoraria or honorarium received in excess of $500 value. ü Public utility employment for you or a spouse. Page 10 of 45 Cook County Statement of Economic Interest What is an asset? continued Required for disclosure: Stocks, bonds, sector mutual funds, sector exchange traded funds, real estate investments, beneficial interest in trusts, business interests and partnership interests. NOT required for disclosure: personal residences, personal vehicles, savings or checking accounts, bonds notes or securities issued by any branch of the government, Medicare benefits, inheritances, or bequests (other than beneficial interest in trusts), diversified funds, annuities, pensions, retirement accounts, qualified college savings plans, tax exempt disability plans, and tangible personal property. Page 11 of 45 Cook County Statement of Economic Interest What is a debt? continued Required for disclosure: Any money or monetary obligation owed at any time during the preceding calendar year to an individual, company or other organization, personal loans from friends or business associates, business loans made outside a lender’s regular course of business and loans made below market interest rates. NOT required for disclosure: loans from a financial institution, government agency, or business entity that are granted on terms made available to the general public, mortgages, student loans, credit card debts or car loans. What is “family”? Includes a filer’s spouse, children, stepchildren, parents, stepparents, siblings, step-siblings, sons and daughters in-law, grandparents, grandchildren, as well as parents and grandparents of the filers spouse and any person living with the filer. Page 12 of 45 Local Conflict of Interest disclosure ü Annual filing not later than May 1 of each year. ü Any interest, direct or indirect, in your or your immediate family’s name or in the name of any other person, association, trust or corporation doing business with the village in which I or they have an ownership interest exceeding 5%, in any contract of a value in excess of $500.00 or in the performance of any work of a value in excess of $500.00, for the village of Buffalo Grove in the making or letting of which I may be called upon to act or vote. ü Will not during term of office (or period of appointment or employment) receive income for services rendered from persons having an interest in real property which such services are rendered on behalf of a plan, project or development for which approval or a favorable recommendation is requested of any Board, committee, subcommittee, commission or department of the village of Buffalo Grove unless same shall be disclosed prior to such approval or recommendation. Page 13 of 45 Local Conflict of Interest disclosure ü Acknowledge the requirements of the State Officials and Employees Ethics Act (5 ILCS 430/1 et seq.) ü For elected officials, do not own stock in any bank or other financial institution authorized to accept deposits of the Village funds or, if so, must be disclosed. continued What is “immediate family”? An individual's spouse, dependent children or others if the interest herein required to be disclosed is constructively controlled by the person required to file a Conflict of Interest disclaimer and/or a Statement of Economic Interest pursuant to state statutes. Page 14 of 45 Open Meetings Act training ü Training administered by the Illinois Attorney General. ü Most appointed officials must take the training only once. ü Must be completed within 90 days of initial appointment. ü Elected officials; board, committee and commission chairs and liaisons are required to take the training annually. ü Training is completed online and is updated annually. ü Any time a majority of a quorum is present and discussing business of the public body or taking any action, the Open Meetings Act applies. Page 15 of 45 Open Meetings Act training continued 48-hour notice is required for a public meeting. Must be posted online and at the physical location of the meeting and provided to any media/interested parties that has requested notice. Be aware of public body’s quorum A majority of a quorum equals a public meeting. Key things you need to know about the Open Meetings Act (OMA) Limited to no electronic attendance Electronic attendance is not permitted for boards, committees and commissions EXCEPT for the Village Board in certain circumstances. Closed sessions limited Exceptions for closed sessions must be narrowly construed. All citizens have a right to speak before a public body. It is important to have rules that provide a fair and equitable means for citizens to address the public body. Page 16 of 45 Due dates and reminders Page 17 of 45 Illinois Governmental Ethics Act Page 18 of 45 Illinois Governmental Ethics Act, 5 ILCS 420/1-101 Gift ban: Prohibited from intentionally accepting or soliciting gifts from prohibited sources What is a “prohibited source”? Current vendors, along with their spouses and immediate family members living with the vendors, as well as those who do business or seek to do business with the village, are prohibited sources. Those seeking official action or who have interests that may be substantially affected by the performance or non-performance of the official duties of a village employee or the village are considered prohibited sources. What if I receive a gift from a prohibited source but I didn’t mean to? •Return the gift to the giver. •Donate the gift to an appropriate 501(c)3 charitable organization. •Make a contribution equal to the market value of the gift to an appropriate 501(c)3 charitable organization. . Page 19 of 45 Illinois Governmental Ethics Act, 5 ILCS 420/1-101 Political activity continued Prohibited political activity includes, but is not limited to: soliciting campaign contributions or votes, assisting at the polls, circulating petitions, and hosting rallies for candidates for elective office. When is it prohibited? •During public meetings. •Using public facilities. •Using village resources, including but not limited to telephones, vehicles, tools, copiers, fax machines, email accounts and computers. •When representing the village as an official, including when wearing village apparel, badges or nameplates. Page 20 of 45 Procurement policies Page 21 of 45 How to best procure goods/services for Committees and Commissions Talk to your staff liaison. No reimbursements. Volunteers, Committee and Commission members have no authority to make purchases on behalf of the village nor do they have authority to execute contracts on behalf of the village. Ensures all Federal/State/Local procurement guidelines are followed. Page 22 of 45 How to best procure goods/services for Committees and Commissions Amount of Purchase Procurement Method Notification Approval Purchases of $500.00 or less Credit Card Supervisor or Designee Supervisor or Designee $500.01 to $1250.00 Purchases Credit Card Invoice submitted   Department Supervisor or Designee Department Supervisor or Designee $1250.01 to $2,999.99 Purchases Quotes (verbal, fax, email, written) 3 Quotes Recommended Purchase Order Procedure Department Supervisor or Designee Deputy Department Director or Chief Procurement Officer $3,000.00 to $5,000 Purchases Quotes (written, faxed or email) 3 Quotes Required Purchase Order Procedure Deputy Department Director or Designee Department Director or Chief Procurement Officer Page 23 of 45 How to best procure goods/services for Committees and Commissions Amount of Purchase Procurement Method Notification Approval $5,000.01 to $25,000.00 Purchases Contact the Chief Procurement Officer or Buyer Informal Procurement Process Purchase Order Procedures Department Director or Chief Procurement Officer or Buyer Village Manager, Chief Procurement Officer $25,000.01 to $50,000.00 Contact the Chief Procurement Officer or Buyer Procurement Process Informal/Formal Chief Procurement Officer or Buyer Village Manager Purchase Exceeds $50,000.00 Contact the Chief Procurement Officer or Buyer Formal Procurement Process Award by Village Board Village Manager or Designee Village Board continued Page 24 of 45 Managing conflicts of interest Page 25 of 45 What happens if you have a conflict of interest? Determine if you have a conflict first. •Statutory conflicts. •Appearance of impropriety conflicts. Disclose and recuse yourself (if applicable) •Disclose early. •Requirements for recusal. Just because you have a conflict doesn’t mean you can’t serve! Page 26 of 45 Examples Page 27 of 45 Scenario 1 Do you have a conflict? Are you required to recuse yourself from considering the variance? What if your boss, Wile E. Coyote, asks if you are going to vote in favor of the variance? You are an employee of Acme Insurance Company. Your employer has applied for a zoning variance for a site within the community and you serve as a Planning and Zoning Commissioner. Acme Insurance Company is a prohibited source under the Illinois Governmental Ethics Act Has interests that may be substantially affected by the performance or non- performance of the official duties of a Village employee or the Village Statutory conflict – zoning Cannot discuss your activities with the applicant or other PZC members, nor assist the applicant in assessing voting behaviors of others Page 28 of 45 Scenario 2 Is it a conflict? What if Bob offers you free eggs every Sunday at the market in appreciation of your volunteer efforts? You serve on the Farmers Market Committee and are chairing the selection of vendors for the annual market. Adams Poultry Farm has sold at the market for many years and has requested a better location for this season. Owner Bob Clucksmith calls you and offers free Cubs playoff tickets to you and your spouse. Adams Poultry Farm is a prohibited source under the Illinois Governmental Ethics Act •Seeks to do business with the Village •Subject to gift ban Gift value is irrelevant Because Adams Poultry Farm is a prohibited source, the value of the gift is irrelevant. “Thank you, Bob, for thinking of me, but it would be unethical for me to accept a gift.” Page 29 of 45 Scenario 3 Do you have a conflict? You are a commissioner on the Board of Fire and Police Commissioners. Your nephew, Stewie, has applied to be a candidate as a firefighter for the Village. Your brother, Stewie’s dad, asks you over to dinner to talk about how he is doing in the selection process. It doesn’t matter who makes dinner, you are prohibited from discussing the hiring process with any external parties. You may describe how the selection process works and the timing for a decision to be made. Page 30 of 45 Scenario 4 Does she have a conflict? Fellow RKCRD Commissioner Maddy Knowaguy offers to get t-shirts printed for an upcoming RKCRD event. She says, “Rusty Special is a friend and always gives us a great deal on t-shirts, I’ll take care of it and get reimbursed.” If value of purchase is $1,250 or more: •Procurement policy requires three quotes before items are purchased. •Procurement policy requires a purchase order issued by the Village and approved in advance, reimbursements are not made. Appointed volunteers are expressly prohibited from making purchases or recommending vendors. The staff liaison to the commission will handle the procurement. If value of purchase is up to $1,250: •A credit card and invoice may be used to make the purchase. Page 31 of 45 Scenario 5 Can you accept it?As a trustee on the Police Pension Board, you are conducting a request for proposals for professional services. A vendor offers you a gift card valued at $25. The vendor is a prohibited source under the Illinois Governmental Ethics Act •Seeks to do business with the village. •Subject to gift ban. Procurement process trumps State Gift Ban Act. No item of value or consideration can be accepted. Page 32 of 45 Scenario 6 Is it a conflict? Fellow Health Commission member Kevin offers to host a fundraiser for the commission at his local restaurant. Is Kevin being paid to use the facility? Is any consideration given for sponsorship, logo, promotion, etc.? Are all items for the fundraiser considered a donation? Page 33 of 45 When in doubt, ASK! Page 34 of 45 Tom Wisniewski Purchasing Manager 847-777-6023 twisniewski@vbg.org Resources Jessie Brown Administrative Services Manager and Deputy Village Clerk 847-459-5533 jbrown@vbg.org Patrick Brankin Village Attorney and Partner at Schain Banks 312-345-5722 pbrankin@vbg.org Page 35 of 45 THANK YOU from the Ethics Commission Page 36 of 45 Slide 1: Title Slide “Welcome to the Ethics Training session, brought to you by the BG Ethics Commission. This presentation will guide you through recent updates to municipal ethics codes, filing requirements, and best practices to maintain integrity in public service. Let’s get started.” Slide 2: Introduction “The Ethics Commission strives to build transparency and trust. Its purpose is to recommend updates to procedures, review disclosure statements, and educate boards and commissions on ethics requirements in accordance with Village Code and Illinois State Statutes. Today we will be informing you about your obligations to ethical practices here in the Village, with easy-to-follow guidelines and recommendations, concluding with practical examples for your use.” Slide 3: Responsibility “We each share responsibility in conducting the people’s business with the highest integrity, transparency and accountability, starting with our elected Village Board who sets policy and practice, the Ethics Commission to oversee the implementation of the Board’s policies, our professional staff to ensure compliance throughout the organization and you, to ensure good governance through our many volunteer boards and commissions.” Slide 4: Recent Changes to Municipal Code “Recent updates have streamlined filing requirements. Economic interest statements are now filed exclusively with Cook County. Annual reminders will be provided by the Village, with all filings due by May 1. Additionally, local conflict-of-interest disclosures must also be filed annually, with amendments as necessary. All filings are now fully paperless, enhancing convenience and efficiency.” Slide 5: What Will Be Covered “Today we will cover key topics such as disclosure requirements, procurement policies, managing conflicts of interest and the Illinois Governmental Ethics Act, ensuring you’re equipped with the knowledge to comply with ethical standards. To summarize this training in one sentence, we seek to avoid conflicts of interest and the appearance of conflicts of interest. Today we will help you understand the best ways to go about upholding the public’s confidence.” Slide 6: Disclosure Requirements “Let’s get started with disclosure requirements” Page 37 of 45 Slide 7: Cook County Statement of Economic Interest “All individuals required to file economic interest statements must do so annually with Cook County. You will file with Cook County regardless of which county you live in, because Village Hall is located in Cook County. You will be invited via email from the Cook County Clerk’s Office when it is time to file your statement of economic interest. Only you can fill out your statement. Key disclosures include high-value assets, income, debts, and any relevant gifts or employment. Generally, disclosure is required for single assets with value in excess of $10,000, sources of income in excess of $7,500 annually, government employment for you or your spouse, gifts exceeding $500 in value and public utility employment for you or your spouse. The objective is to promote transparency and avoid conflicts of interest.” Slide 8: Cook County Statement of Economic Interest “The Statement of Economic Interest has specific definitions and exemptions. An asset is defined as ‘stocks, bonds, sector mutual funds, sector exchange traded funds, real estate investments, beneficial interest in trusts, business interests and partnership interests.’ But, there are several exemptions that will cover many of your personal assets from being disclosed, including your personal residence, vehicles, savings or checking accounts, bonds, notes and securities, Medicare benefits, inheritances or bequests, diversified funds, annuities, pensions, retirement accounts, college savings accounts, tax exempt disability benefits and your tangible personal property.” Slide 9: Cook County Statement of Economic Interest “Continuing with the definitions, debt is defined as ‘any money or monetary obligation owed at any time during the preceding calendar year to an individual, company or other organization, personal loans from friends or business associates, business loans made outside a lender’s regular course of business and loans made below market interest rates.’ Exemptions from disclosure include: ‘loans from a financial institution, government agency, or business entity that are granted on terms made available to the general public, mortgages, student loans, credit card debts or car loans.’ Lastly is the definition of family. Family is broadly defined to include a: ‘filer’s spouse, children, stepchildren, parents, stepparents, siblings, step-siblings, sons and daughters in-law, grandparents, grandchildren, as well as parents and grandparents of the filers spouse and any person living with the filer.’ Page 38 of 45 Slide 10: Conflict of Interest Disclosures “Now we will move on to the Local Conflict of Interest disclosure, which is required by the Village. This disclosure is filed electronically and you will receive a reminder email from the Village Clerk’s office in advance of the May 1 filing deadline. The local conflict of interest disclosure is slightly different than the Cook County Statement of Economic Interest. Specifically, conflict of interest disclosures are required for: ‘Any interest, direct or indirect, in your or your immediate family’s name or in the name of any other person, association, trust or corporation doing business with the Village in which I or they have an ownership interest exceeding 5%, in any contract of a value in excess of $500.00 or in the performance of any work of a value in excess of $500.00, for the Village of Buffalo Grove in the making or letting of which I may be called upon to act or vote.’ In addition, an affirmation is required stating that you: ‘will not during term of office (or period of appointment or employment, whichever applies) receive income for services rendered from persons having an interest in real property which such services are rendered on behalf of a plan, project or development for which approval or a favorable recommendation is requested of any Board, committee, subcommittee, commission or department of the Village of Buffalo Grove unless same shall be disclosed prior to such approval or recommendation.’ Whether it’s ownership interests, income from business dealings with the Village, or potential voting conflicts, all relevant information must be disclosed to ensure accountability. When in doubt, disclose.” Slide 11: Conflict of Interest Disclosures “In addition, you must acknowledge the requirements of the State Officials and Employees Ethics Act and, if you are an elected official, affirm that you ‘do not own stock in any bank or other financial institution authorized to accept deposits of the Village funds or, if so, must be disclosed.’ Lastly, immediate family under the local code is defined as: ‘An individual's spouse, dependent children or others if the interest herein required to be disclosed is constructively controlled by the person required to file a Conflict of Interest disclaimer and/or a Statement of Economic Interest pursuant to state statutes.” Slide 12: Open Meetings Act “Training on the Open Meetings Act is required within 90 days for most appointed officials and annually for others. If you are an elected official or serve as a chair of a board, committee or commission, you must take the training every year. The training is completed online and you will receive a reminder email to complete the training in advance of the May 1 deadline. Page 39 of 45 The Act governs public meeting transparency, electronic attendance policies, and public participation rules, ensuring accessibility and accountability.” Slide 13: Open Meetings Act “There are some key things you should know about the Open Meetings Act. One, 48 hours’ notice is required for any public meeting, the notice must be posted on the Village’s website, at the physical location where the meeting will occur and provided to the media and/or any interested parties. This process is managed by the Village Clerk’s office. Two, always be aware that a majority of a public body’s quorum triggers the Open Meetings Act requirements. Thus, if your body has seven appointed members, a quorum is four members and a majority of a quorum is three or more members. Therefore, official business of the public body must be discussed in an open meeting. Three, electronic attendance is generally not permitted except for the Village Board in very limited circumstances. Meetings must happen in-person under the Open Meetings Act. Four, when a closed session occurs, the exceptions to the Open Meetings Act are to be narrowly construed. And five, each public body must permit citizens to speak during any open meeting, in Illinois citizens have a right to speak before a public body. You will learn more about the Open Meetings Act when you take the training, but these key facts are important to remember.” Slide 14: Due Dates and Reminders “Around March of each year, you will receive an email from the Village Clerk’s office with reminders for any and all trainings and disclosures you are required to complete. The email will look like the content here on your screen and will have helpful links for you. Slide 15: Illinois Governmental Ethics Act “Now we will briefly review the key points of the Illinois Governmental Ethics Act, which applies to all appointed and elected officials, employees and volunteers.” Slide 16: Illinois Governmental Ethics Act “Prohibited activities under this act include soliciting gifts from prohibited sources and engaging in political activities during public meetings or using Village resources. A prohibited source is defined to include current vendors, along with their spouses and immediate family members living with the vendors, as well as those who do business or seek to do business with the Village. A vendor who seeks to do business with the Village is a key term as this would apply to any vendors bidding upon or proposing to provide services to the Village. Page 40 of 45 From time to time, well-meaning gifts from prohibited sources may be given to you or another official, employee or volunteer. What can you do in this instance? You have three options, one is to simply return the gift to the giver. Alternatively, you may donate the gift to a recognized 501(c)3 charitable organization, or three you may make a contribution equal to the market value of the gift to a recognized 501(c)3 charitable organization. Whichever option you choose, you should document the gift received, market value and which action you took to remedy the gift from a prohibited source. Generally speaking, there are exemptions that apply to gifts given between personal friends and outside of the scope of a prohibited source, but if you are in doubt you should check with your staff liaison as soon as practical.” Slide 17: Illinois Governmental Ethics Act “The Illinois Governmental Ethics Act also applies to political activity in three ways: when you are conducting affairs representing the Village of Buffalo Grove, when public facilities are utilized and during any public meeting. While you are serving in your official capacity as an elected or appointed official, employee or volunteer of the Village, you are prohibited from soliciting campaign contributions or votes, assisting at polls, circulating petitions and hosting rallies for candidates for elective office. These prohibitions apply during any public meeting, when using any public buildings or facilities, when using any Village resources such as equipment, vehicles, computers or email accounts, and when representing the Village as an official, including when donning Village apparel, badges or nameplates.” Slide 18: Procurement Policies “The Village has a thorough procurement policy to ensure the highest ethical standards are followed in the acquisition of goods and services using taxpayer dollars. Most of the time you will not need to worry about making purchases but if the need arises we have some practical tips to help you along the way.” Slide 19: Procurement Policies “Volunteers and commission members are prohibited from making purchases or signing contracts on behalf of the Village. Procurement must align with Federal, State, and Local guidelines and is managed through staff liaisons. If you need to purchase goods or services, start by talking with your staff liaison. They can guide you on the best practices followed by the Village and will handle the process internally. Page 41 of 45 It is important to note that the Village uses a purchase card and purchase order system. Individuals are not permitted to use personal or other funds to procure goods and services and receive reimbursement later.” Slide 20 and 21: Procurement Policies “These slides show the approval structure for purchases in the Village. Generally you would be making purchases that would total $500 or less, which is handled by a Village purchase card transaction completed by your staff liaison. As the amount of the purchase increases, additional approvals are required. Generally speaking, purchase approvals are handled at or below the Village Manager level for purchases up to $50,000. All purchases above $50,000 require Village Board approval, with limited exceptions for professional services under the Village Manager’s authority. It is also important to note that the Village’s procurement policy strictly prohibits splitting up purchases from the same vendor to avoid higher level approvals. In addition to your staff liaison, the Village’s chief procurement officer is available to provide guidance and manage procurement processes.” Slide 22: Managing Conflicts of Interest “Our last educational topic is managing conflicts of interest. In a community like Buffalo Grove, the interrelated partnerships of government, resident groups and vendors can lead to conflicts of interest. But that doesn’t mean that the Village can’t conduct its business when a conflict of interest arises.” Slide 23: Managing Conflicts of Interest “Just because you have a conflict doesn’t mean you can’t serve. First, you need to determine if you have a conflict. There are two kinds of conflicts: statutory and perceived. A statutory conflict means you are prohibited by either law or case law from participating in one or more decision-making, review or procurement processes because of your conflict. A perceived conflict may give the appearance of impropriety despite no actual conflict. A perceived conflict, for example, could be your membership in a local organization that seeks approval for a matter before the Village. While you may not have a direct interest in or benefit from the outcome, it can still give the appearance of impropriety. If you identify a conflict, the most important step is disclosing your conflict. Your disclosure should be directed to the chair of the board, committee or commission as well as the staff liaison. Once you have disclosed your conflict, it is important that you recuse yourself from any deliberation of the matter that gave rise to the conflict of interest. By doing so, you protect yourself under the law as well as the Village.” Page 42 of 45 Slide 24: Examples “Now that we have concluded the educational portion of this presentation, let’s review some real-world examples using the concepts we learned today.” Slide 25: Scenario 1 “You are an employee of Acme Insurance Company and a Planning and Zoning Commissioner. Acme applies for a zoning variance, and your boss asks if you will support the variance. Do you have a conflict? This is a statutory conflict under the Illinois Governmental Ethics Act. As Acme Insurance Company is a prohibited source, you cannot discuss the variance or assist in influencing other commissioners. Disclosure and recusal are required. What if your boss, Wile E. Coyote, asks you if you are going to vote in favor of the variance? Because it is a conflict of interest, you are not only required to recuse yourself from the deliberation of the request, you also cannot discuss it with your employer. Always prioritize transparency to maintain public trust.” Slide 26: Scenario 2 “You serve on the Farmers Market Committee and are chairing vendor selections. A long- time vendor, Adams Poultry Farm, offers you and your spouse free Cubs playoff tickets while requesting a better location at the market. Adams Poultry Farm is a prohibited source under the gift ban. Accepting any gift, regardless of value, from a prohibited source is unethical for you or your spouse who qualifies as immediate family. Politely decline and inform the vendor of your commitment to ethical standards. But what if Bob Clucksmith offers you free eggs every Sunday at the market in appreciation of your efforts? Even in-kind gifts, regardless of value, are banned from prohibited sources.” Slide 27: Scenario 3 “As a Fire and Police Commissioner, your nephew applies to become a firefighter. At dinner, your brother (Stewie’s dad) asks about his progress in the selection process. Do you have a conflict? Yes, you have a conflict of interest. While you may explain the general process and timing for the hiring process, discussing specific details of your nephew’s application with Page 43 of 45 external parties is prohibited. This ensures impartiality and adherence to ethical practices and respects the confidentiality afforded to candidates for employment.” Slide 28: Scenario 4 “A fellow RKCRD commissioner suggests purchasing t-shirts for an event using a vendor she knows, offering to handle the transaction and get reimbursed. Does she have a conflict? Procurement policies require proper processes. The amount of the purchase dictates the process for approval. For purchases over $1,250, three quotes and prior approval are mandatory. For purchases up to $1,250 a credit card and invoice may be used to make the purchase. Appointed volunteers cannot make purchases or recommend vendors. The staff liaison will manage all procurement to ensure compliance. If you have a friend who is a vendor seeking to do business with the Village, you should direct them to the Vendor Registry service on our website at vbg.org/bids. Please remember that the procurement policy prohibits advance purchase and reimbursement.” Slide 29: Scenario 5 “As a trustee on the Police Pension Board, a vendor involved in a request for proposals offers you a $25 gift card. Can you accept it? Under the Illinois Governmental Ethics Act, this vendor is a prohibited source. Accepting any item of value or consideration during procurement processes violates both ethics laws and Village procurement policies. In this case, the Village’s procurement policy is more restrictive than the State Gift Ban Act. The gift must be declined. Remember to document the process and disposition of the gift and notify your staff liaison as soon as practical.” Slide 30: Scenario 6 “A fellow Health Commission member offers to host a fundraiser for the commission at their restaurant. Is it a conflict? The answer to this question depends on three factors: Is the venue donated or compensated? Are sponsorships, logos or promotion of the restaurant involved? Are all payments, purchases or sponsorships considered donations? Page 44 of 45 If the commissioner is not receiving direct or indirect compensation, sponsorship or promotion and all consideration given is a donation, then it is probably not a conflict. Slide 31: When in Doubt, ASK! When in doubt, always ask. Transparency is essential to avoid conflicts of interest and maintain ethical standards.” Slide 32: Hidden Slide 33: Resources “These scenarios highlight the importance of ethical awareness and proactive decision- making. When faced with uncertainties, disclosure and seeking guidance are your best tools to uphold public trust. For additional information or clarification, reach out to our resources, including the Purchasing Manager, Administrative Services Manager, or Village Attorney. Their contact information is provided here.” Slide 34: Thank You/Closing “Thank you for your attention and commitment to upholding the highest ethical standards. Your dedication to integrity strengthens our community and ensures public trust in our governance.” Page 45 of 45