ethics sheryl johnson

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EXECUTIVE DIRECTOR MEETING PROGRAM ETHICS HUD Philadelphia Regional Office

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Page 1: Ethics   sheryl johnson

EXECUTIVE DIRECTOR MEETING

PROGRAM ETHICS

HUD PhiladelphiaRegional Office

Page 2: Ethics   sheryl johnson

Prepared by:Office of General Counsel and Office of Public

HousingU.S. Department of Housing and Urban DevelopmentFebruary 2003

Public Housing AuthorityETHICS

Reference Manual

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Section 19(A) Public Housing ACC

HA, contractors or subcontractors may not enter into any contract, subcontract, or arrangement in connection with a project under this ACC in which any of the following classes of people has an interest, direct or indirect, during his or her tenure or for one year thereafter:

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Section 19(A) Public Housing ACC

(i) Any present or former member or officer of the governing body of the HA, or any member of the officer's immediate family. EXCEPTION: present or former tenant commissioner who does not serve on the governing body of a resident corporation, does not occupy a policymaking position with the resident corporation, the HA or a business entity.

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Section 19(A) Public Housing ACC

(ii) Any employee of the HA who formulates policy or who influences decisions with respect to the project(s), or any member of the employee's immediate family, or the employee's partner.

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Section 19(A) Public Housing ACC

(iii) Any public official, member of the local governing body, or State or local legislator, or any member of such individual's immediate family, who exercises functions or responsibilities with respect to the project(s) or the HA.

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Section 19(B) Public Housing ACCNepotism Restrictions

(B)(1) The HA may not hire an employee in connection with a project under this ACC if the prospective employee is an immediate family member of any person belonging to one of the following classes:

Page 8: Ethics   sheryl johnson

Section 19(B) Public Housing ACCNepotism Restrictions

(i) Any present or former member or officer of the governing body of the HA. EXCEPTION any former tenant commissioner who does not serve on the governing body of a resident corporation, and who otherwise does not occupy a policymaking position with the HA.

Page 9: Ethics   sheryl johnson

Section 19(B) Public Housing ACCNepotism Restrictions

(ii) Any employee of the HA who formulates policy or who influences decisions with respect to the project(s).

(iii) Any public official, member of the local governing body, or State or local legislator who exercises functions or responsibilities with respect to the project(s) or the HA.

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Section 19(B) Public Housing ACCNepotism Restrictions

(2) The prohibition referred to in subsection (B)(1) shall remain in effect throughout the class member's tenure and for one year thereafter.

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Section 19(B) Public Housing ACCNepotism Restrictions

“immediate family member” means the spouse, mother, father, brother, sister, or child of a covered class member (whether related as a full blood relative, or as a 'half' or 'step' relative, e.g., a half-brother or stepchild)."

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Section 20 – Interest of a Member or Delegate to Congress

No member of or delegate to the Congress of the United States of America or resident commissioner shall be admitted to any share or part of this ACC or to any benefits which may arise from it.

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Sample Waiver Form ACC/Section 8

Name of Housing AuthorityDate of Your RequestName/Title of Person Requesting ReviewWhat Specific Conflict of Interest Provision is the

Subject of this Request?Provide a Title, Position or Other Description of the

individual Involved in the Contract or Arrangement That Gives Rise to the Conflict of interest

Describe the Nature of the Conflict of Interest in Detail

Date and Manner of Disclosure of the Interest to the PHA

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Sample Waiver Form ACC/Section 8

Whom May HUD Contact For More Information?

Describe in Detail the Reason That "GOOD CAUSE" is Present For HUD to Grant a Waiver/Exception. Attach Documentation That Evidences "GOOD CAUSE".

Attach Supporting Documentation, as Well as an Analysis or Other Evidence That the Contract or Arrangement Described in Your Request is in Compliance With State Law. This Should be Supported by a Local Attorney’s Opinion as to State Law Compliance