Frequently Asked Questions

Frequently Asked Questions About The Ethics Code

See the left hand column for links to common questions and answers about the Seattle Ethics Code. You may also download informational brochures, below.

The Commission is committed to helping City officers and employees comply with the Code. We encourage you to contact us if you have any questions about the Code or its application.

The Code seeks to prevent conflicts of interest, and does not attempt to address all possible unethical behaviors. City officials are also responsible for following other regulations and rules that are not part of the Ethics Code and are not administered by the SEEC. For assistance in finding the appropriate authority, you may contact the Customer Service Bureau.


Disclosure of Appearance of Conflict or Impaired Judgment


You are welcome to download the following brochures, or contact the Commission for copies.

Ethics Code Brochure "Top of the Crop!"

Whistleblower Home Page

Ethics Code for Members of Advisory Committees

Public Employee Rights in the Political Process

Definitions of Ethics Code Words

  1. Question:  What does "participate in a matter" mean? What is a "Covered Individual?" Who is included in "immediate family?"

    Answer: These words and phrases are defined in the Ethics Code, along with other words that have particular meaning under the law. Here are excerpts of Ethics Code definitions. See SMC 4.16.030 for the complete list.

    "Appointing authority" means a person authorized by ordinance or Charter to employ others on behalf of the City, usually the head of a department. With reference to a City contractor it is the person who is authorized to award the contract.

    "Assist" means to act, or offer or agree to act, in such a way as to help, aid, advise, furnish information to, or otherwise provide assistance to another person, believing that the action is of help, aid, advice, or assistance to the person and with intent so to assist such person.

    "City contractor" means an individual who spends more than 1,000 hours in any twelve-month period providing services to a City agency under a contract, other than a contract of employment. [Included as a "Covered Individual" after October 20, 2009.]

    "Communicate," for the purposes of SMC 4.16.075, means to communicate in any form, including, without limitation, personally, through another person, by letter, by electronic mail, or by telephone.

    Confidential Information” means (i) specific information, rather than generalized knowledge, that is not available to a person who files a public records request, and (ii) information made confidential by law.

    Covered Individual” means any City officer, City employee, or City volunteer. Covered Individual also includes every individual who was a City officer, City employee, or City volunteer at the time of the act or omission that is alleged to have violated this chapter, even if he or she no longer has that status. [After 10/20/09 includes City contractor.]

    Immediate family” means a spouse or domestic partner, child, child of a spouse or domestic partner, sibling, sibling of a domestic partner, brother-in-law, sister-in-law, parent, parent of a spouse or domestic partner, a person for whom the Covered Individual is a legal guardian, or a person claimed as a dependent on the Covered Individual’s most recently filed federal income tax return.

    "Matter" means an application, submission, request for a ruling or other determination, permit, contract, claim, proceeding, case, decision, rulemaking, legislation, or other similar action. Matter includes the preparation, consideration, discussion, or enactment of administrative rules or legislation. Matter does not include advice or recommendations regarding broad policies and goals.

    "Participate" means to consider, investigate, advise, recommend, approve, disapprove, decide, or take other similar action.

    "Person" means an individual, association, corporation, or other legal entity.

    "Proceeding" means a matter that involves a named party or parties in which a City agency administers, interprets, or executes City laws. Proceeding does not include the preparation, consideration, discussion, or enactment of administrative rules or legislation.

See the Ethics Code for additional definitions, or contact the SEEC for assistance

Getting Advice

  1. If I ask for advice, could my question trigger an investigation? I’m afraid that if I ask for advice about what my co-worker and I are doing, we’ll get in trouble.
    Answer: SEEC staff will not initiate a complaint investigation in response to a good-faith request for guidance. If staff believes that the activities raise issues under the Ethics Code, you will be told of those concerns, and will be advised to stop the activities. If the SEEC receives a complaint, it is obliged to investigate. The Commission and staff want to support the public's trust by helping you comply with the law. Staff provides training and advice, and the Commission issues advisory opinions to respond to questions and to provide guidance. Summaries of those opinions are posted at You may also get a copy of advisory opinions from the Commission office. Note that different facts or circumstances may result in a different opinion, and July 2009 amendments to the Code may render some previous opinions obsolete. Contact staff before acting.

  2. How can I be sure the advice I get is correct?
    Answer: It is important that you give all relevant information when you ask your question. Advice will be given based on the facts that you present. The best way to get complete and accurate advice is to e-mail your inquiry to the Commission office. You may also call staff directly, but e-mailed questions and responses help staff to accurately understand the specifics of each situation. Be thorough in your e-mail describing the situation. Different facts or circumstances may result in a different conclusion.

  3. Will my question be confidential?
    Answer: Yes, to the extent possible. Staff won't release your identity except in response to a public records request.

  4. What if I follow the advice given to me, but I still get in trouble?
    Answer: If your department receives a complaint, your management may or may not ask for the Commission’s opinion. Your department may still hold you responsible for your behavior under internal workplace expectations and discipline procedures. That is one reason why Commission staff recommends that Covered Individuals ask for advice prior to taking questionable actions, and know and follow their department’s workplace expectations, as well. The Ethics Code contains protections for individuals who ask for an advisory opinion in good faith. This provision says that the Commission will not find an Ethics Code violation if 1) the person has submitted to the Executive Director or to the Commission a written request for an advisory opinion; 2) the request describes possible future conduct and accurately and fully discloses the material facts related to that conduct; 3) the Executive Director or the Commission issues a written advisory opinion that the described conduct would not violate the Code, and 4) the person acts in a manner consistent with the opinion. If an Ethics Code complaint is filed, then the person can assert this as a defense. For your best protection, you should always choose actions that foster the public’s confidence in the integrity of government workers.

For more information, see the Ethics Code, SMC 4.16.085, or contact the SEEC.

Advisory Board

Information for Members of Advisory Boards and Commissions

  1. Are members of advisory boards subject to the Ethics Code in the same way City employees are? They don't make decisions, but only give advice to decision-makers. 
    Answer: The Ethics Code sets high ethical standards for members of advisory boards and commissions, whose advice may have a major impact on City policies. 

    Members of advisory committees are required to disqualify themselves from participating in official matters in which they have a financial interest, direct or indirect, personally or through an immediate family member. And the Code requires full disclosure if the member engages or has engaged in an activity or transaction that would appear to a reasonable person to impair the member's independence of judgment. 

    To satisfy the latter requirement, members must fully disclose the facts on the record of the committee meeting, file a copy with the committee staff contact and with the SEEC using this Disclosure Form, downloadable in PDF version or Microsoft Word version, or contact us for assistance. 

    The Code excludes "public corporations and ad hoc advisory committees" from the jurisdiction of the Ethics Code. "Ad hoc advisory committees" are defined as 1) any advisory committee expressly designated by ordinance as "ad hoc"; or 2) any advisory committee created by means other then by federal or state law, or City ordinance, including by resolution, executive order, or other similar action." Members of ad hoc committees should check with their City staff to determine their committees' ethical standards.

  2. How do members of advisory commissions know whether to disqualify themselves from discussions or decisions, or merely disclose their potential interest in a matter before the board? 
    Answer: Members must disqualify themselves from discussion and voting if they have a financial interest, even indirectly, in the matter before their committee. If the members' interests are not financial, but if they engage or have engaged in any transaction or activity which would appear to be in conflict with or incompatible with their duties or would appear to impair their judgment, then they must disclose the circumstances publicly to their committee. 

    Members who are uncertain what to do, are encouraged to contact the Executive Director for guidance, or take the conservative route of recusal.

  3. What penalties might an advisory committee member face? 
    Answer: The penalties vary depending on what part of the Code the member has violated. 

    The Commission can issue a fine of up to $1,000 to members of a voluntary advisory committee who fail to disqualify themselves from matters in which they or a member of their immediate family has a financial interest. In the case of failure to disclose apparent impaired judgment in the performance of advisory committee duties, the Commission may impose a monetary fine of up to $250. 

    The Commission may impose a fine of up to $5,000 if the member violates other prohibitions of the Ethics Code, including improper use of official position for private gain, improper use of City resources, accepting or soliciting items of value, and use or disclosure of privileged information for other than a City purpose. 

    The Commission may also require reimbursement of damages and costs, and may recommend censure or removal from the committee as well as rescindment or reconsideration of any finding or recommendation that has been substantially influenced by the violation.

For more information on the Ethics Code for Advisory Committee members,
see the Ethics CodeSMC 4.16.070 and SMC 4.16.100, download a brochure, or contact the SEEC.



Appearances matter, too, and several sections of the Ethics Code include a standard which asks what a reasonable person who knows all the facts would believe about a particular action.

For example, if a reasonable person, having knowledge of the facts, could think that a Covered Individual's judgment is impaired because of 1) a personal or business relationship that is not covered under the financial interests provisions of the Code, or 2) a transaction or activity engaged in by the Covered Individual, then the covered Individual must disclose the relationship, transaction, or activity to the appropriate department head and to the SEEC Executive Director.

In another example, if a reasonable person who has all the facts would think that something of value was given to a City official or employee with intent to give or obtain special consideration or influence official action, then the item must be rejected. (The Ethics Code specifically makes exception to campaign contributions which are solicited or received and reported in accordance with applicable law. See the Elections Code site for those rules.)

  1. I'm a City employee. Does the "appearance" standard in the Ethics Code mean that I can be punished for violating the Code whenever it just looks like I am doing something unethical? 
    Answer: No, "appearance to a reasonable person" does not mean that you will get in trouble simply because your action raises concerns in an observer. However, you should keep in mind the taxpayer, ratepayer, competing contractor or other concerned observer when you are making a choice that has to do with your work or the people you work with. Whenever you can, you should make the choice that fosters public trust in your integrity. 

    The appearance standard encourages employees to see a situation from another's point of view. Employees should ask, "Could someone else think what I am doing is a violation of the Code?" 

    Employees, officials, volunteers, and persons on contract to perform work for the City should always be careful not to undercut public confidence in our work. The Ethics Code is the minimum standard. City departments and managers may and often do have more stringent workplace rules and expectations. 

  2. I have a close friend that I've traveled with in the past, who wants to compete for a contract that I'll oversee. Does our friendship make me appear too close to him to be able to work on the project? 
    Answer: Amendments to the Code in July, 2009 made it no longer necessary to disqualify yourself in every case where there is an appearance that your outside transactions, activities, or relationships might impair your judgment. Instead, the City's value of transparency comes into play. 

    If you are not required to disqualify yourself because of a financial interest in the matter (see the FAQs on Financial Interests for more information), then you must disclose in writing to your department head and to the SEEC all the relevant facts, before taking official action, using this Disclosure Form or contact us for assistance. 

    After you have put it on the record, you can have a conversation with your supervisors about your situation. Your supervisors can decide that it is best for you not to be involved so that the integrity of the process is not questioned, or your supervisor may decide that management is comfortable with you participating, perhaps subject to some additional management oversight. Either way, what happens is a matter of public record.

See the Ethic Code, SMC 4.16.070, or contact the SEEC for advice. 

Complaint Procedures

Complaint Procedures

  1. If I am contacted and told that an ethics complaint has been made against me, what will happen next? 
    Answer: Commission staff does not assume, based on a complaint, that an employee violated the Ethics Code. When staff receives a complaint or information that someone may have violated the Code, the first step is to determine what happened. 

    First of all, within 30 days after receipt, the Executive Director will review the complaint to determine whether the complaint alleges facts that, if true, would violate the Ethics Code. You will be asked what you know about the situation. The time may be extended by the Commission for good cause. 

    If, after investigation, staff believes that there are no reasonable grounds to believe that a violation has occurred, or that the violation was inadvertent and minor, the Executive Director will dismiss the case and will notify you and the person who filed the complaint by letter. The complainant may appeal the dismissal. 

    If there is reason to believe you have violated the Code, staff may suggest a settlement of the case. If you and the Executive Director reach a settlement agreement, you will be asked to: sign the proposed agreement, attend the Commission meeting at which the proposed agreement is presented, and respond to Commission members' questions at the meeting. 

    If the Commission signs the agreement, the case will be closed. The Executive Director will then send a letter to the complainant explaining the disposition of the case and a copy to you. (Your copy will not include the complainant's name or address.) 

    If a settlement cannot be reached, a public hearing is scheduled. You may have the right to request a closed hearing, if you are not an elected official, department head, board or commission member, deputy mayor, or member of a union without a closed hearing agreement. 

    You will receive in advance all of the evidence that the Executive Director plans to use to prove the case against you. Each party has the right to representation and has an opportunity to present their case and to cross-examine witnesses. The hearing is recorded. 

  2. What are my rights during the investigation? 
    Answer: All employees are entitled to have an attorney with them during the investigation process. Union members may bring a union representative to an interview. 

  3. If I see a City employee involved in behavior I believe to be unethical, what should I do? How do I know when to notify my supervisor or the Ethics and Elections Commission? 
    Answer: If you believe that an employee is violating the Code and you are not a supervisor, you may contact the Commission office, inform your supervisor, or both, whichever you believe is most appropriate. 

    If you think your supervisor is a part of the misconduct or would not know how to correct it, you may contact Commission staff. You can do this anonymously or you may identify yourself. 

    If you are a supervisor, you should act on any employee conduct that you believe violates the Ethics Code. If you do not take action, you may be violating the Code yourself. You can deal with the violation on your own. However, Commission staff is always willing to help employees and supervisors determine if their assessments are correct. 

    If you provide information that indicates the possibility of an Ethics Code violation, the Commission staff will conduct an investigation. Your identity will not be disclosed unless required by court order. If the conduct is not a violation of the Ethics Code, but could or should be addressed by another agency, staff will suggest that you provide the information to the appropriate agency. 

  4. I'm afraid of retaliation. Can I file a complaint anonymously? 
    Answer: Yes. You may file a complaint anonymously, and the staff will conduct an investigation. However, it would help the fact gathering if the investigator can interview you for the details of what leads you to believe that a violation has occurred. 

    Your identity will not be disclosed at any point during the investigation or during the hearing if a violation is found, unless required by court order. Neither the Commission nor the person who is charged with a violation receives the identity of the person who complained. 

  5. Doesn't the accused have a right to face the accuser? How can you keep secret the name of the person who complains about me? 
    Answer: Charges will only be filed against a Covered Individual if the Executive Director believes that an Ethics Code violation has occurred. The Executive Director, then, is the person who is accusing the Covered Individual of the violation. The complaint brings awareness to the problem, and gives the Commission the opportunity to hold the individual accountable. 

  6. What is the difference between an ethics complaint and a whistleblower complaint? 
    Answer: The Ethics Code is about individual accountability and the Whistleblower Code is about bringing attention to government wrongdoing so that it can be corrected. 

    Ethics complaints are complaints about the conduct of a City officer or employee that generally involves private gain, self-dealing, biased decisions, or the misuse of City resources. Ethics complaints may be brought by employees or citizens. Every ethics complaint brought by a City employee is by definition a whistleblower complaint. 

    Whistleblower complaints involve alleged improper governmental actions which violate a federal, state, county, or city law or rule; abuse authority; create a substantial danger to public health or safety; or result in a gross waste of public funds. Whistleblower complaints may be made only by City officers or employees.

For more information on the Commission's Powers and Duties, see SMC 3.70.100 or contact the SEEC for advice.

For more on ethics complaints, investigations, hearings, and enforcement, see SMC 4.16.090 or contact the SEEC for advice.

For information on Whistleblower complaints and investigations, see the Whistleblower site or SMC 4.20.800. Please contact the SEEC for assistance in filing your complaint and navigating the system.

Confidential Information

Confidential Information

  1. A co-worker told me that a lot of the information in the files I work with is confidential and I cannot use or share it. Is that correct? 
    Answer: Partially. Covered Individuals may personally use or disclose any information that is also available to the public by request. Information that is not publicly available is only for internal use, and the Ethics Code prohibits your sharing or using it privately. 

    Case law determines if and when information in a City file is confidential. Any questions about disclosure of information you work with should be directed to your department's management or Public Disclosure Officer. 

  2. I think my neighbor is a good candidate for a job in my department. Can I tell her what they are looking for? 
    Answer: You may give your neighbor information that is available to other candidates for the position. However, before you share information about rating criteria with an applicant, or information regarding a City promotional exam with someone who plans to take the exam, you should confirm with your manager that the information is publicly available. You may not give your friends, relatives, or anyone "inside information" that is not available to everyone else.

For the Ethics Code regulations on confidential information, see SMC 4.16.070 or contact the SEEC for advice.

Contractor and Client Information

Explanation of the City's Ethics Code for Contractors, Vendors, Customers, and Clients

The Seattle Ethics Code is the City's commitment to the values of integrity, accountability, stewardship, and independence in the performance of our jobs. The Code sets ethical standards about work activities, business relationships, and the use of City resources that apply to all City employees, elected officials, members of most City boards and commissions, and City contractors and vendors who provide more than 1,000 hours of service to the City in any 12 month period. Here are some examples of issues that arise in official dealings with individuals covered by the Ethics Code. For more information, please contact the SEEC. You may also download a brochure, in PDF format, that explains the Code. Click or scroll down for answers regarding the following topics.

  • Gifts
  • Soliciting Items
  • No Free Meals
  • Refreshments at Meetings
  • Use of City Facilities and Resources
  • Conflict of Interest
  • Advertising
  • Invitations to Seminars & Conferences
  • After Leaving City Employment
  • Ethics Complaints and Consequences


In 2006 the Commission adopted an interpretive rule that describes some circumstances under which gifts accepted by City employees and officials would not violate the Code. It also sets some parameters for accepting gifts. You may download the "Gift Rule" (PDF) for guidance in your dealings with City employees and officials. Covered Individuals who are offered gifts outside of the "safe harbors" described in the Rule should either decline the gift or call the Commission office for guidance.

  1. Question: I would like to deliver a large basket of fruit and candy to a City work group thanking them for the work we've done together. Is this permitted?
    Answer: If you want to appreciate people you've worked with, it is permissible for you to send tokens of appreciation that are valued at $25 or less and can be shared in the workplace, such as a box of candy or flowers. Elaborate bouquets or gift baskets exceeding that value are not appropriate. Moreover, the cumulative value of such items must not exceed $50 from a single source in a calendar year.

    City employees may not accept gifts, entertainment, loans, favors, or other things of value that appear to be given to influence future City actions. If you want to thank a City employee, the best way is to write a letter of praise to the employee's supervisor or department head.

    Employees cannot receive gifts or premiums for the City orders they place, and they cannot purchase items for their personal use under the City's discount. Be sure that any special discounts you offer to City employees are vetted through the City's process. Contact us for more information.

  2. Question: Is it okay to invite a City workgroup to an open house at our office to celebrate the work we've done together?
    Answer: This situation is not one of the "safe harbors" described in the Gift Rule for Covered Individuals who participate in "contractual or regulatory decisions" with a consultant or vendor. The answer depends on the nature of the work that you do and that the City workers do, and the nature of the event. Covered Individuals are encouraged to turn down such invitations or contact the SEEC for advice.


  1. Question: Is it OK for an employee to ask me for a donation to a charity auction?
    Answer: City employees may not ask people with whom they do City business to donate items, whether for personal, charitable, or other purposes. Nor can they accept unsolicited items from you for charitable purposes.

    Employees also cannot ask businesses they regulate or inspect for donations of meeting spaces or supplies or for any other item of value.


  1. Question: When I'm meeting with City employees over lunch, I'd like to treat them out of my expense account. Is this ok?
    Answer: No, Covered Individuals may not accept free meals from people with whom they do City business, or who wish to do business with the City. The Covered Individual should pay their own way each time.


  1. Question: Are we prohibited from offering City employees refreshments during a meeting in our office?
    Answer: No. City employees may accept basic refreshments--such as coffee, tea, soft drinks, doughnuts, or cookies--when attending meetings in your office. If the meeting spans mealtime, you may provide a simple meal, such as box lunches. Otherwise, whether meeting in your office or in a restaurant, employees must pay for their own meals.

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  1. Question: Can we use the City's tools for our project?
    Answer: If your contract with the City calls for the City to provide tools, then of course you may. However, City property, including City paid time, vehicles, tools, and equipment may only be used for a City purpose. A Covered Individual may not use them or loan them for private use.


  1. Question: Our City project manager's spouse has just hired on with our company. Is there any problem with this?
    Answer: It depends on several factors. If the spouse stands to gain from the project manager's City duties, the employee must stop working on your project. We encourage you or the employee to contact the SEEC for advice.

    The Ethics Code says that a Covered Individual may not take part in City business where any of the following have a financial interest:
    i) the Covered Individual;
    ii) an immediate family member of the Covered Individual;
    iii) an individual residing with the Covered Individual;
    iv) a person the Covered Individual serves as an officer, director, trustee, partner or employee;
    v) a person with which the Covered Individual is seeking or has an arrangement concerning future employment. 

    Even if they do not have actual financial interests in your project, Covered Individuals also are prohibited from taking part in City business where their outside activities or relationships would appear to have impair their judgment, unless they disclose the situation to their department head and the SEEC Executive Director. This gives management and the public an opportunity to weigh in on the appropriateness of the Covered Individual being involved.

    This includes selection processes. City employees must withdraw from a vendor selection process if one of the competitors is a relative or household member, or if a competitor has been the employee's business partner or client within the last twelve months, or if the employee's relationship with the candidate would appear to a reasonable person to impair the employee's judgment.
  2. Question: I'd like to hire the City employee I deal with all the time. May I offer her a job?

    Answer: You may offer the employee a job. Be aware, though, that once you open discussions about prospective employment with a City employee, that employee cannot be involved in City matters affecting your business. A reasonable person will believe that your discussions have created a conflict of interest, and will influence the employee's dealings with you. See below for limits on a former employee's activities after leaving City employment.


  1. Question: People who use the City's services could also use mine. Is it ok for me to give a supply of brochures to the City employees I deal with?
    Answer: Employees cannot use their positions for anyone's private gain, or use City resources for a non-City purpose. Therefore, they cannot hand out or post advertising materials, including your discount coupons or other promotional items.

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  1. Question: My company would like to fly the City employee I deal with to our head office for some training. Can we?
    Answer: City employees may attend conferences paid for by City vendors or potential vendors only under limited conditions outlined in Section III.4.c. of the Gift Rule: 1) the gift complies with City and departmental policies for accepting gifts, 2) the expenses are reimbursable under the City's Travel Policies and Procedures, 3) the City--not the donor--determines who will use the gift, and 4) the City's receipt of the gift is documented appropriately.

    Neither the City nor the employee can accept reimbursement for expenses incurred that are not allowable under the City's Travel Policies and Procedures. In all cases, the event must serve a City purpose. If you are required by contract to provide training or education to City employees, the employee's attendance is subject to the above conditions.

    Remember, reimbursement for travel and lodging must be made to the City, not to the individual. And the employee cannot accept your treat for special events connected with the conference trip, such as a golf game or night on the town.

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  1. Question: I'd like to hire an employee I've dealt with at the City. May I?
    Answer: You may hire a current or former City employee. Keep in mind, however, that the Ethics Code places some restrictions on that employee's activities following separation from the City: 
    For two years after leaving City office or employment, City officers and employees cannot assist anyone on a matter in which they participated while employed by the City. 
    For one year former City officers or employees cannot communicate on behalf of any person on a matter involving the City, with an employee of the agency with which he or she was previously employed. 
    For one year a Covered Individual cannot participate as a competitor in any competitive selection process for a City contract in which he or she assisted in determining the project or work to be done or the process to be used in selecting the contractor.
    The Covered Individual is also prohibited from sharing or using confidential information that is not otherwise available to the public. This prohibition has no time limit.

    Please also see #8 under Conflict of Interests above, regarding limitations on the activities of a current employee receiving a job offer from a City contractor.

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  1. Question: What do I do if I see inappropriate action by a City employee?
    Answer: Anyone who feels a City officer or employee has violated the Ethics Code may bring it to the attention of the Ethics and Elections Commission. Commission staff will investigate whether there is a Code violation.

    If the Commission finds that an employee or official violated the City's Ethics Code, it may fine that person up to $5,000 per violation, plus costs and restitution. The Commission may also recommend disciplinary action, including suspension or discharge. A complaint may be dismissed if investigation finds no violation of the Code or if the violation is minor and inadvertent or has already been remedied.

    See the questions and answers about "Complaint Procedures" and "Penalties" for more information. Potential fines for members of Advisory Boards and Commissions differ from those for employees.

For the more information, see the Ethics Code, SMC 4.16, or contact the SEEC.

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Contractors, Vendors, and Consultants Covered by the Ethics Code

Effective October 20, 2009 provisions of the Ethics Code also apply to contractors, vendors, and consultants who provide over 1,000 hours of services to the City of Seattle within a twelve month period. Most of the City's Ethics Code applies to their activities in the same way as it does to City employees, elected officials and volunteers. 

This change was included in amendments to the Code which became effective June 22, 2009, and allowed an additional three months before City contractors become "Covered Individuals." 

To help explain these provisions, we developed these FAQs and the "Top of the Crop" brochure. 

Please contact the SEEC if you have any additional questions, and to arrange for training.

Family Members

The Ethics Code prohibits City employees from participating in any matter in which a family member (or someone in the household) has a financial interest. This means that the employee, official, or other Covered Individual cannot perform any duties or make any recommendations that might have an impact on a family member's livelihood.

"Immediate family" is defined in the Code as "a spouse or domestic partner, child, child of a spouse or domestic partner, sibling, sibling of a domestic partner, brother-in-law, sister-in-law, parent, parent of a spouse or domestic partner, a person for whom the Covered Individual is a legal guardian, or a person claimed as a dependent on the Covered Individual's most recently filed federal income tax return." Here are some common questions about working with family members:

  1. I've been assigned out of class for a day to cover for my supervisor. My son is in my crew. I won't really have responsibilities, so isn't it okay if I take the assignment? 
    Answer: No. Even for a short period, you cannot be in a position to make a difference in your son's job. 
    Whether you exercise them or not, by definition the out-of-class assignment puts you in a position with responsibility and authority. 
    You must call your management's attention to the inappropriate assignment, to avoid a violation of the Ethics Code.

  2. A lot of people in my department work with their family members. This doesn't seem right. Is it? 
    Answer: Working side by side with family members or housemates is not prohibited by the Ethics Code. It becomes a problem under the Code if one is made lead or supervisor over another family member, even for a temporary period. 
    This is not to say that the situation does not demand special attention from managers. When family members work side by side, managers must be certain that the relationship does not interfere with work, just as they must do with other potential distractions or disruptions.

  3. I have been assigned to supervise my cousin. "Cousin" is not included in the definition of "immediate family," so is it ok if I supervise him? 
    Answer: If the relative is not an "immediate family" member, you need to disclose your relationship to your department head and the SEEC Executive Director before accepting the assignment. This gives your management an opportunity to determine if the relationship causes any problems in your workplace. 

    The Ethics Code prohibits an employee from performing any official duties when it could appear to a reasonable person that the individual's judgment is impaired because of a personal or business relationship not covered under SMC 4.16.070 1.a or b, or a transaction or activity engaged in by the Covered Individual. 

    If you are already participating in work that would raise concerns, fill out the disclosure form now, before participating in any more activities, to get the facts on the record. The Ethics Code says that it is an "affirmative defense" if the individual has disclosed the relationship, transaction, or activity prior to the official act, and says that if one is charged with a violation of this provision, the burden of proof is on the individual to show that a proper notification was made. 

    So if you are assigned to participate in any work in which your cousin has a financial interest, use this disclosure form before you accept the assignment. See the FAQ on Appearances and on Financial Interests for more information.

  4. If I won't be the supervisor, is it ok for me to be on the selection committee when my relative is an applicant? 
    Answer: The same regulations apply whether you are supervising, overseeing as a lead, or participating in any other work duties in which a relative (or friend) has a financial interest. 

    You cannot be on the selection committee if someone in your "immediate family" is an applicant, and you must disclose in writing if anyone with whom you have other relationships, activities, or transactions has a financial interest in the work.

  5. One of my co-workers is married to one of our top managers, who is in our chain of command. Is that okay? 
    Answer: The manager cannot participate in matters in which their spouse has a financial interest, so while the manager may be "in your chain of command," they must be excluded from decisions involving their spouse's job. If you believe that the manager is participating in matters involving their spouse, please raise the issue with your department's management, or contact the SEEC to discuss the situation.

  6. My supervisor is a part owner of a company that is party to a contract I've been assigned to work on. I've been told not to talk with her about my work on that contract, but to talk to another supervisor if I have questions or reports to make. Is that enough? 
    Answer: No, not in this case. The Ethics Code, in SMC 4.16.070 (5)(a), prohibits a Covered Individual from holding or acquiring an interest--including through a member of his or her immediate family--in any contract made under the Covered Individual's supervision, or made by someone under their supervision. This means that work on this contract must be assigned to someone who isn't in your supervisor's chain of command.

For the Ethics Code regarding family members, see SMC 4.16.070 or contact the SEEC for advice.

Financial Interests

It doesn't happen often, but sometimes our responsibilities collide with our interests away from work. The July, 2009 amendments to the Ethics Code expanded and clarified the list of financial interests that would require a Covered Individual to disqualify him or herself from participating in City matters. A Covered Individual may not participate in a matter in which any of the following have a financial interest:

  1. the Covered Individual;
  2. an immediate family member of the Covered Individual;
  3. an individual residing with the Covered Individual;
  4. a person the Covered Individual serves as an officer, director, trustee, partner, or employee;
  5. a person with which the Covered Individual is seeking or has an arrangement concerning future employment.

There are several definitions that will help you understand the provisions regarding financial interests. Here are some situations to consider:

  1. Can I serve on a hiring panel if one of the applicants is a casual friend who once worked for me at my former job? 
    Answer: Generally, yes. A former supervisory relationship or a friendship does not automatically require you to disqualify yourself from serving on a hiring panel or from taking part in other City actions. In some cases, a former supervisory relationship can help the City better evaluate a potential employee. You should disclose the relationship to your fellow panelists. 

    However, if the closeness of your friendship, or activities or transactions you've had with the individual, would cause a reasonable person to question your fairness or impartiality, you must disclose the circumstances in writing prior to taking part in the panel. Submit this disclosure form to your department head and the SEEC Executive Director. If they either approve or do not within a week of the disclosure disqualify you from the duties, then you may proceed without being in violation of the Code. 

    Remember, you must disqualify yourself from participating on a selection panel if anyone in the list at the start of this section has a financial interest in the job or contract, or if the candidate was your former client or employer within the past year. (There is a narrow exception for dealing with past employers and past clients, so get in touch with us if that's your situation.) 

  2. My housemate owns a plumbing business and my City job is to inspect work done by plumbing companies. Can I inspect the work done by my housemate's business? 
    Answer: No. Employees may not take part in City matters in which someone in their household has a financial interest. 

  3. Can City employees serve on the boards of non-profit organizations that receive City funding? 
    Answer: Generally, yes. Employees are encouraged to be active with non-profits. However, when the employees' duties overlap with their volunteer activities, they may need to disqualify themselves from official actions. 

    Employees cannot participate on any level in a City matter in which an organization they serve as an officer, director, trustee, partner, or employee has a financial interest. If a family member, close friend, or someone in your household holds such a position with the non-profit, the employee must disclose the facts to the department head and the SEEC Executive Director before acting on the matter.

For more assistance, contact SEEC staff.

Former City Employees

Whether City employees are retiring from the City, going to new jobs, moving across the country, or laid off, they still must keep the public trust.

The Ethics Code contains rules to support this trust. We have summarized the rules in this handout: Ethics Considerations When Separating from City Service. We encourage separating employees to contact us about how the law applies to their situations.

  • After leaving, a Covered Individual can never divulge or use confidential information gained through his or her City work.
  • For the first year after leaving, a Covered Individual cannot participate in the competitive selection process for a contract in the City if -- while with the City -- he or she helped design the project, the scope of work, or the process to be used in the selection of the contractor
  • Also for the first year, a City employee can work in his or her chosen field, but cannot communicate on behalf of someone involved in a matter within the City, with anyone at the employee's old department.
  • For two years after leaving City employment, an employee cannot assist anyone on a matter in which he or she participated while with the City. Pretty much any help that could be provided would qualify as assistance under the Ethics Code. To "assist" means to act or offer to act in any way that helps, aids, advises, furnishes information or otherwise to provide assistance to another person, believing that the assistance will be of use to another person and intending it to be of assistance.
  1. Can I accept a job offer from a City contractor or vendor? 
    Answer: Yes, as an employee or former employee you may accept a position with a City contractor or vendor. However, once you begin considering changing employment, you will have to observe certain restrictions on your activities whether or not you accept the job or remain a City employee. 

    For example, as soon as you are seeking employment with the company, you cannot be involved in City business that the company has a financial interest in. You must immediately disqualify yourself from any City actions affecting the company, such as purchasing or overseeing their work. You also must inform the prospective employer that you are no longer involved in the company's dealings with the City in any way. 

    If either of you ends the employment discussion, you still may not immediately resume an official role in relation to the company without first disclosing the situation in writing to your department head and the SEEC Executive Director. 

    If you do take the job, for two years after you leave the City you cannot assist your new employer on any matter that you worked on as a City employee, and for one year after you leave you cannot communicate on behalf of your new employer with anyone in your former department. And you may never use or share with your new employer any confidential information that you acquired in the course of your City job. 

    If a company makes you a job offer but you are genuinely not interested and inform them immediately, then you may continue to have official dealings with the company, but must disclose the offer to your management. 

  2. Can a former City employee bid on a contract with his or her former division or department? 
    Answer: Yes, an employee can be hired on contract to work for his or her former department unless it is a competitive selection process for the contract and during the previous twelve months the former employee participated in development of the project, the scope of work, or the selection process. See the Department of Finance and Administrative Services for City contracting rules.

For more information, read Ethics Considerations When Separating From City Service, or contact SEEC staff for advice.

Working with Former Clients and Employers

  1. Can I continue to work for current and former clients of my consulting business after I've accepted a job with the City? 
    Answer: Generally, yes, so long as you do not use City paid time or facilities to conduct your private business, and as long as your outside business does not overlap with your City responsibilities. 

  2. I was hired to work on the contract that the City has with my former employer. I've heard that I cannot do that. Do I have to find another job? 
    Answer: Probably not, but the Code may require temporary modifications of your job. The Code prohibits you (or any Covered Individual) from participating on a City matter in which a person who has employed you or retained you or your firm, within the past 12 months, has a financial interest. 

    In 2009, amendments to the Code provided the possibility of a waiver of this provision. If your department head submits to the SEEC Executive Director a written determination that there is a compelling City need for you to participate in matters in which your former employer or client has a financial interest, with a written plan showing how management will safeguard the City's interests, and the Executive Director agrees that the plan is satisfactory, a waiver may be granted. 

    If the plan is not approved, or your department head determines that your assignment does not serve a compelling City need, you may need to work on different duties until 12 months has passed.

For assistance, contact the SEEC.

Gifts and other things of value

The Ethics Code prohibits a Covered Individual from soliciting or receiving items of monetary value where it would appear to a reasonable person that the item was given with intent to gain influence or special consideration. The Code also prohibits Covered Individuals from using their official positions for private benefit.

In 2009, amendments replaced the word "gift" with "any retainer, gift, loan, entertainment, favor, or other thing of monetary value" to eliminate any doubt that discounts, meals, invitations, or other things of value that don't come in neatly wrapped packages are also barred under the Ethics Code. To help sort gifts from token appreciations, the Commission adopted an Interpretive Rule regarding gifts, called the "Gift Rule." The Gift Rule identifies some items that are acceptable and sets new limits. Individuals who are offered gifts outside of the "safe harbors" described in the Rule should either decline the item or call the Commission office for guidance. Covered Individuals should be tuned into the myriad ways that people who want to influence City actions might try to win your favor. Contact the SEEC for advice about how to respond. These FAQs cover just some examples of how items of value are offered to employees.

  1. I am a City employee. Can I accept promotional or logo items, such as hats or coffee mugs, from City contractors and vendors? 
    Answer: This is one of the safe harbors, so you do not need to contact the SEEC every time a token advertising item is offered to you. If you or your department purchase from, license, inspect, or monitor the giver, you may accept token advertising items like these if they are worth less than $25, with a total of less than $50 from one source in a year. 

    The acceptance of logo items worth more than $25, or other items for personal use, can send the wrong message. Even acceptance of low-value advertising items may raise other issues you need to be aware of.

  2. May we keep flowers, chocolates, or similar gifts or treats given to our office by a customer or vendor? 
    Answer: Generally, yes, if they are valued at $25 or less and shared with your co-workers or the public. This is the other "safe harbor" when you get gifts from your customer, vendors, or contractors. Large, elaborate baskets or bouquets beyond the $25 limit should be returned to the donor, with the explanation that the Ethic's Code prohibits your accepting it. 

    Do not simply donate the item to a charity without telling the donor not to give them in the future. It's up to you to let the donor know you are prohibited from accepting gifts. Explain that our customers expect employees to provide responsive public service without inappropriate influence. 

    See the next question about the aggregate limit of $50 total value for perishable items from a single source in a calendar year.

  3. Is there any limit to the number of bouquets we can accept from the customer or vendor? 
    Answer: Yes. The "Gift Rule" sets an annual maximum of $50 total value of gifts received from one source over a calendar year, including gifts that are properly shared, when they are given by someone with whom you have regulatory, contractual, or purchasing business. You are responsible for keeping track of gifts, and returning to the sender any gifts--including perishable gifts--that exceed this total.

  4. Can my crew accept coffee offered to them by neighbors of the project we're working on? 
    Answer: Yes. Generally, you may accept minor refreshments that would not appear to be given with intent to influence your actions as a City employee.

  5. Can my workgroup accept lunch from a contractor that we are meeting with to discuss our project? 
    Answer: Employees may accept basic refreshments, including box lunches, when attending meetings in a contractor or vendor's office, and the meeting carries over the lunch hour. If your meeting ends before or begins after the lunch hour, and you choose to eat lunch, you should pay for your part of the meal. Similarly, if you are meeting with a consultant in a restaurant, you should pay your own bill every time.

  6. A contractor is holding an open house to celebrate their new headquarters. Can our team attend? 
    Answer: Be very thoughtful about the possible issues before you accept an invitation like this. If you are invited to an event by an entity you or your department has contractual or regulatory business with, you should decline the invitation or contact the SEEC for advice based on the specific circumstances. 

    Your team may be able attend if this is truly an open house or hosted reception, or a barbecue open to all passers-by, and not a party directed toward your work group or the City, or to your crew because of your role with the City. If delicate business is looming, such as a Request for Proposals or a project inspection, or if your department expects to continue to have regulatory or contractual responsibilities with the host, you should decline the invitation or pay the fair cost of attending. 

    The Gift Rule allows attendance at "hosted receptions" when you are not in a contractual, purchasing, or regulatory role with the host. A "hosted reception" is defined as a social function that is attended by a diverse group of no fewer than 20 people, has attendees that are not limited to City officers or employees and the hosts, and that does not involve a sit-down meal. If this is an invitation to a hosted reception, you may be able to attend. But, again, if you or your department has official dealings with the host, you or your department should pay a fair value for your participation.

  7. A local store has offered me a discount because I'm a City employee. Is it okay for me to accept the discount? 
    Answer: No, it is not okay for you to accept a discount--which is an item of value--that is offered to you because you are a City employee. This is true even if it is appreciation for your good work as a public servant. 

    Under no circumstances should you show your City identification in order to get a discount or other premium. And even if you are not asked to show your ID, because you are known to the vendor, you still may not accept a special discount offered because of your City job. That would be improper use of your position for your own private gain. 

    Similarly, employees cannot accept a discounted bid for labor from a contractor that the employee knows from work. If this is truly a promotional discount that is being offered to the general public, you may accept the reduced rate. But if it is offered to you because of your City job, you must decline the discount and pay the going rate. 

    Employees also may not receive the City's negotiated rate for their private purchases. Pay attention to how you are being charged. It is not okay to receive the City's discount for anything but the City's purchases. 

    The only discounts that City employees may accept because of their employment are those that are offered to all employees via the City's internal bulletin board, or are part of the City's negotiated purchase agreements. Other special rates offered to City employees or officials for private purchases are often improper gifts. Contact us for advice about your own situation.

  8. A vendor has sent me a plaque and a pen with their logo in appreciation of years of purchases. Can I keep them? 
    Answer: Yes, in general, acceptance of unsolicited tokens or awards of appreciation in the form of a plaque, trophy, desk item, wall memento, or similar items is not a violation of the Code. 

    Other than these, keep in mind that you cannot receive gifts or premiums from vendors for the City orders you place.

  9. A supplier has invited me to attend an educational program at their expense. The information would benefit the City, but we have no budget for the trip. Can I accept the plane ticket and lodging so that I can attend? 
    Answer: No, but your department may. It is not appropriate for an employee to receive lodging or travel tickets or reimbursement from someone who does--or would like to do--business with the employee's department. But the department may accept such payments under certain circumstances. 

    If attendance at the event serves a City purpose, the department may pay for the travel and lodging according to applicable travel policies, and be reimbursed by the vendor. The vendor cannot specify that you are the one to attend. It is management's decision who is the appropriate attendee. 

    If your conference attendance would be underwritten by a person or entity that is not a City contractor or vendor, but a foundation or some other government or non-profit agency, the best course still is to have the matter handled as a reimbursement to the department. Contact the SEEC for further advice.

  10. A friend of mine is a City contractor. My family has gone to the contractor's cabin every summer for years. Can we continue to go? 
    Answer: Yes, it is okay for you continue to accept an invitation which has been historically given to you by your friend. However, if you are assigned to work on your friend's dealings with the City, there are other implications. In that case, before you participate on any level in your friend's City matters, you will need to disclose this relationship to your Department Head and the SEEC Executive Director. See the FAQ on "Appearances" and contact the SEEC for advice. Here is the disclosure form to use. 

    If a contractor or vendor or someone you regulate invites you to a trip, of course you cannot accept the invitation.

Find the Ethics Code section on prohibited conduct.

See SMC 4.16.070
Read the Gift Rule.

For assistance, contact the SEEC.


  1. What punishments can the Commission impose for violating the Code? 
    Answer: If the Commission determines that a Covered Individual violated the Ethics Code, it may impose a fine of up to $5,000 per violation or three times the value of the violation, order restitution, and/or recommend discipline. Rather than face formal charges and penalties, the Covered Individual may enter into a settlement agreement with the Executive Director, stipulating to pertinent facts and negotiating specific remedies. 

    In the case of volunteer members of advisory committees, the ceilings on fines depend on the violation. For advisory committee members, the Commission may impose a monetary fine of up to $1,000 for failure to disqualify themselves from matters in which they have financial interests; $250 for failure to disclose apparent impaired judgment in the performance of advisory committee duties; and $5,000 per violation for other violations of the Ethics Code, including improper use of official position for private gain, improper use of City resources, accepting or soliciting items of value, and use or disclosure of confidential information for other than a City purpose. 

    In each circumstance, the Commission may require reimbursement of damages and costs, and may recommend censure or removal from the committee as well as cancellation of the decision made that the volunteer improperly participated in. 

  2. Can the Commission fire me for violating the Code? 
    Answer: No. The Commission has no authority to discipline employees. Only the hiring authority -- in most cases the Department Head -- has authority to discipline employees or terminate employment. 

    Your department does not have to follow the Commission's recommendation for discipline. If discipline is carried out, personnel procedures for the disciplinary action must be followed and the outcome reported to the Commission.

See the Ethics Code, SMC 4.16.100 or contact the SEEC for more information.

Employee Political Activity

City employees have a right to be actively involved in political campaigns, and many are. These rights, however, may be restricted while at work, when representing the City, and in some rare instances when in conflict with an employee's official duties. Both City and Washington State laws limit the use of public facilities and resources for campaign purposes. The City's Ethics Code also prohibits City employees from using their position for private benefit, and prohibits them using City funds and facilities for a non-City purpose. These FAQs highlight common issues encountered by City employees who are or wish to be active in political campaigns. The same restrictions apply to activities on behalf of candidates or supporting or opposing ballot propositions.It is important to know, also, that, absent any conflict with official duties, City employees may not be treated differently because of their political activity outside the workplace.

  1. If a City employee wants to run for public office or be active in a campaign, what restrictions apply? 
    Answer: City employees cannot use City resources for campaign purposes. For example, they cannot do campaign work at their City work stations or using City equipment, make campaign calls when they are on City time or in the workplace, place bumper stickers on City cars, display campaign signs or buttons in public work areas, or solicit contributions on City time or premises. 

  2. Aren't elected officials subject to the same laws as City employees? They often publicly campaign for ballot issues. 
    Answer: City elected officials are subject to the same laws as all City employees. However, the law sets certain exceptions for elected officials. Under the law, a City elected official can make a statement in support of or opposition to a ballot issue at an open press conference or in response to a specific inquiry. 

    The City Council may take public actions such as passing motions, resolutions, or ordinances stating positions on ballot propositions and the mayor can concur in a resolution. Also, a City elected official's title can be published on campaign literature or in the voters' pamphlet as an endorser of a ballot proposition. City elected officials may not use City resources to work on a campaign, including their own, and cannot knowingly solicit campaign contributions from City employees. 

  3. Can City employees wear campaign buttons while on the job? 
    Answer: City employees who are in publicly visible jobs may not wear campaign buttons on the job. Other employees may, unless prohibited by other policies or workplace rules. The same rules may apply to campaign t-shirts being worn on the job. 

  4. Some City departments are closely involved with ballot issues. How can they draw the line when something that is normally part of their work is now on the ballot? 
    Answer: Employees who may discuss certain issues in the regular course of their jobs are subject to limitations when the issue officially becomes a ballot proposition. Before then, a department may continue the full range of its work involving that issue. 

    For example, if the City is developing a levy to present to voters, a department may assign employees to develop proposals for how the money would be used. However, as soon as the issue is put on the ballot, the activities of the department's management and employees are limited, and they may not support or oppose the proposition in their official capacities. 

    Departments are encouraged to develop fact sheets to assist employees in responding to customers' questions once an issue is on the ballot. SEEC staff can assist with this process and provide tailored training to help staff prepare. 

  5. When does a measure become a ballot proposition? Since any issue may some day be on the ballot, when do the legal limits go into effect? 
    Answer: The timing depends on the type of ballot proposition. An issue becomes a ballot proposition when:
  1. Proponents of an initiative submit a proposed form of petition to the City Clerk;
  2. Proponents of a City Charter Amendment begin collecting signatures;
  3. The City Council votes to place a measure on the ballot; or
  4. Application for a statewide initiative ballot title is made to the Secretary of State or the Legislature votes to put a question to the public on the ballot.
  1. Can an employee answer a question about an upcoming ballot issue, including his or her opinion of it? 
    Answer: In response to inquiries, employees may share factual information that they communicate in the normal and regular course of their jobs. They cannot, however, express their opinion on a ballot proposition when they are representing the City or using City resources. The law prohibits City employees from using City time or other resources, or their positions, to support or oppose a campaign. 

    In most cases, employees should refer inquires from the media or requests for public documents to their department's Public Information Officer. 

  2. Can City employees give out or fax information to campaign committees? 
    Answer: Yes, employees may give information that is requested by campaigns if it is the employees' normal and regular job activity to do so. The information that is provided must be information that would be provided to any member of the general public who requests it. Information should not be developed for the exclusive use of a campaign. 

  3. When an employee is at a community meeting as part of the job, is it OK for the employee to answer a question about an upcoming election after the meeting? 
    Answer: It is not appropriate for a City employee to express personal campaign opinions when attending a community meeting for work. When the employee is at a meeting in an official capacity, the employee should decline to express an opinion. If the employee is at a meeting as a private citizen and not as a representative of the City, the employee may express a personal opinion. The employee should make it clear that this is a personal opinion and not the position of the City or the department. 

  4. If a community group asks an employee to come to a meeting to discuss a ballot proposition, can the employee go? What if the employee is also working on the campaign? 
    Answer: An employee may attend and answer questions and share non-biased factual information with groups, and may also bring City-produced brochures, flyers, and reports to the presentation, if the items are available to the public as part of the department's normal course of duties. The employee may not express a personal opinion about the proposition while representing the City. 

  5. How should an employee go about documenting work time, if he or she wants to do campaign work during normal work hours? 
    Answer: Since campaign activities, like City jobs, occur during all hours of the day and night, it is recommended that employees who are active in campaigns be diligent about maintaining a clearly marked calendar or log that identifies the time spent working on the job and the periods that the employee is on legitimate personal, flexed, or leave time. This is especially recommended for employees who work non-standard shifts or are performing campaign work during normal business hours. It is not necessary that the log identify every activity, but should show the blocks of time the employee is off work. 

  6. Can campaigns send event invitations to employees at their City work addresses? 
    Answer: Delivery of postal mail is protected by federal law, so City employees may not interfere with it. However, since employees are prohibited by State and City laws from using City resources--including fax and e-mail--for campaign purposes, they should not give their work addresses to campaigns, and should discourage their use by campaign committees. 

  7. The City owns meeting spaces that are available to the public for use. Can campaigns also use those spaces? 
    Answer: Yes. If City facilities are available to the public for use, then candidates and ballot issue committees must have the same access to those facilities and under the same terms that the public does. 

    If a department has interest in a ballot measure and allows a group that supports the ballot measure to use its public space, it must also allow a group that has the opposite position to use the space. This does not mean that if one group asks to use the facility, the department must try to find the opposing side. The City is only required to allow equal access to the facility.

For more information read

Public Employee Rights in the Political Process or contact SEEC staff for advice.

For the Seattle Elections Code prohibition on use of facilities see Seattle Municipal Code (SMC) 2.04.300 and the Revised Code of Washington, RCW 42.17A.555, for the State law.

Please note that these regulations pertain to candidates and propositions that are on the ballot, and not other issues and controversies that are often called "political." Other regulations and policies may apply. See also the Seattle Ethics Code FAQs regarding "Use of City Resources" and "Use of City Position," to the left, or contact your department's Human Resources office or SEEC staff for advice.

Use of City Position

The Ethics Code prohibit a Covered Individuals from using his or her position for anyone's private benefit, rather than primarily for the benefit of the City.

  1. Is it OK for me to hand out my private business card while I'm on my City job? What about giving my card to citizens who ask for it? 

    When I'm working on the counter, I often see people who could use my services. And when I'm out in the field doing my City job, I am frequently approached by the public asking me if they might hire me to do similar work for them, privately.

    ANSWER: No, it is not ok for you to promote your private business while on your City job. Using your City job or City time to gain customers for your private business would be an improper use of your official position for private gain. 

    Handing out your business cards could also imply to customers that the City is endorsing your private business, which is not a City purpose. 

    A reminder: You cannot, under any circumstances, put your City identification on your private business card. This includes your City title, phone number, address, fax, pager, e-mail address, etc. You can, however, include your City experience on your business brochure, just like anyone can list work experience on a resume. 

    If your outside business overlaps or conflicts with your City job, it is best to contact SEEC staff for advice on how to avoid prohibited conduct under the ethics law. 

  2. A neighborhood organization has offered to hire me to provide services that are similar to what I do in my job. Is it ok for me to do the work for them on my own time? 
    Answer: If you have been offered money to perform a service that you might otherwise provide in the course of your job, you must first ask your manager for a written determination that your department will not be providing this service. When you receive this determination, then you may go ahead and accept the offer. 

    Employees cannot be privately paid to do work that they might otherwise be assigned to do. If you have received an offer to perform your regular City work for an outside organization, contact the SEEC for advice. 

  3. Is it ok if I help my neighbor apply for a City contract or permit? 
    Answer: The answer to this depends on the nature of your City job and the nature of the contract in question. The Ethics Code prohibits a Covered Individual from assisting any person in a City matter involving the Covered Individual's department. If you work in the department that is awarding the contract, you may not assist persons with the application. You may give your neighbor information that has been made public, and then step out of the process so as not to appear to give your neighbor an edge in the competition. 

    If your job is to assist citizens or groups in applying for City funds or permits, you may provide your neighbor the same assistance that you normally and regularly provide to any other citizen. You should be neutral and unbiased in the assistance you provide, and you must not participate in awarding the grants or permits. 

    In any case, you must not attempt to influence a City decision to contract with -- or the conduct of any city business with a person in which any of the following has a financial interest:
  1. the Covered Individual;
  2. an immediate family member of the Covered Individual;
  3. an individual residing with the Covered Individual;
  4. a person the Covered Individual serves as an officer, director, trustee, partner or employee;
  5. a person with which the Covered Individual is seeking or has an arrangement concerning future employment.

It is not a violation of this section of the Code for a City contractor to attempt to obtain other contracts with the City. For assistance, contact the SEEC.

Use of City Resources

The Ethics Code provides assurances to taxpayers and utility ratepayers that City resources, including funds, property, and staff, are being used for City purposes. 

Limited use of communications equipment for personal purposes may be permitted by management, as long as they are within basic parameters of reasonable use. 

It is not appropriate to use City resources to manage or promote a private business or for campaign purposes.

  1. Can I use a City telephone or email to make appointments or take care of other personal matters? 
    Answer: Generally yes. City telephones or email may be used for calls to meet the demands of daily living. Personal use should be limited and occasional, and should not cost the City money or interfere with City work. 

    For example, an employee may use a City telephone or email to make a doctor's appointment or a lunch date, check in with a family member, or arrange for transportation. However, supervisors and departments may have more strict policies on telephone and email use. 

  2. Can I use a City telephone for calls concerning my outside business? 
    Answer: No. City equipment is provided to City employees for their public responsibilities and cannot be used to conduct a private business. Any City employee with a second job or private business must conduct it on their own time, using their own equipment and supplies, and away from the workplace. 

    Employees also cannot use their personal laptops or cell phones in the City workplace to manage their outside business or campaign activities. The worksite is also a public resource. To promote or manage your outside business you must go to a public place. Field workers must separate themselves from their work site. 

  3. Can I use my City computer to send personal emails or to look up personal information on the Internet? 
    Answer: As with the telephone, the Commission interprets the Code to allow occasional internet usage on a City computer, so long as it does not disrupt work and is compatible with management policies. Sending an occasional personal email or reading an on-line newspaper over your lunch break would not violate the Ethics Code. 

    Here again, departments, managers, and supervisors may have more restrictive policies on computer use. Employees should know that the City does monitor some -- and has the capability to monitor all -- computer, email, and Internet use, and that personal emails may be subject to public records disclosure. 

  4. Can I use the City computer to access the Internet to check my personal investments or make an investment? 
    Answer: Just like with other occasional personal uses, using your City computer and Internet access to check your bank account or investments would not violate the Ethics Code. 

  5. Can our crew use the City truck to drive to a restaurant at lunch time? 
    Answer: When you are working in the field, you may use a City vehicle to stop at a nearby eating establishment, as long as this use is consistent with management and department policy, and the location is reasonable. 

    Use of City vehicles for personal errands, including lunch, is prohibited. If you believe that extenuating circumstances warrant your using the City vehicle for an unusual purpose, contact the SEEC in advance for advice. 

  6. No one is using our tools over the weekend. Isn't it all right for me to take them home to use on my home project? 
    Answer: No. Employees cannot use City tools, equipment, or supplies, except for phones and computers within the above limits, for personal purposes. Use of other tools or equipment costs the City in wear and tear. If the equipment is not available to the public on the same terms, employees cannot use it. 

  7. Can I put a flyer for my business on the employee bulletin board at work? 
    Answer: If the bulletin board is available for public use, such as at City-run community centers, employees may use the board subject to the same regulations that the public must follow. But departmental bulletin boards, including on-line bulletin boards, cannot be used to promote a private business. 

    The Commission has said that use of the work-site bulletin boards for communication between employees is permissible, including offering used personal items for sale or posting notice of a school fund-raiser, but promotion of a private business is prohibited. 

    These rules apply to direct selling catalogs, as well, which should not be listed on department bulletin boards or placed in internal lunchrooms.

For the Ethics Code regarding Use of City Resources, see SMC 4.16.070 or contact the SEEC for advice.

Soliciting for Charities

  1. Can I ask vendors and contractors I work with to donate money or items for charity or other non-profit causes? 
    Answer: No. To do so could pressure the vendor or contractor to donate out of concern that City business will be withheld if a donation is not made. Likewise, the contractor may feel that more or other City business will be given in return for the donation. In purchasing and contracting, the City strives to retain contractors and vendors based on the merits of their products or services, not due to favors given to City employees. It is important that contractors and vendors feel that their only obligations to the City are clearly spelled out in their contractual agreements. 

    Similarly, consultants, contractors, and vendors who are subject to the Code (who provide more than 1,000 hours of service to the City in a 12 month period) must not use their positions and City relationships to solicit donations or other items. 

  2. Can I circulate a sign-up sheet to my fellow employees to sponsor me in a run for a charity, and after the run collect the money they pledged? 
    Answer: Yes, under the Ethics Code you are permitted to do this if the activity does not interfere with work, does not cost the City money, and has management approval. The Commission has said that under these conditions such activities for charitable causes may be allowed.


  1. Is it ok for an employee to be assigned as a temporary crew chief over a unit in which his brother-in-law works? 
    Answer: No, even for a short period it is not appropriate for an employee to be in an oversight role over an immediate family member. "Immediate family" is broadly defined in the Ethics Code:
    "Immediate family" means a spouse or domestic partner, child, child of a spouse or domestic partner, sibling, sibling of a domestic partner, brother-in-law, sister-in-law, parent, parent of a spouse or domestic partner, a person for whom the Covered Individual is a legal guardian, or a person claimed as a dependent on the Covered Individual's most recently filed federal income tax return.
    Even if a temporary or as-needed crew chief does not have occasion to participate in a critical decision during a short assignment, the oversight position puts him or her in a role that is incompatible with the Code. One of the individuals will need to be reassigned for the duration of the out-of-class period. The same is true if the employee will be overseeing the work of anyone in the following list:

    1. an immediate family member;
    2. an individual residing with the employee;
    3. a person the employee serves as an officer, director, trustee, partner, or employee;
    4. a person with which the employee is seeking or has an arrangement concerning future employment.

    If a person in the crew is not in the above list but a personal or business relationship, activities, or other transactions might cause a reasonable person to question whether the employee's judgment is impaired, then the employee needs to disclose the circumstances in writing to their department head and to the SEEC Executive Director asap. This puts it on the public record, gives management an opportunity to evaluate the potential conflict and take any action it deems appropriate, and protects the employee from violating the Code. Here is a disclosure form to use.

  2. Can I serve on a hiring panel if one of the applicants is a casual friend who I supervised in my former job? 
    Answer: Generally, yes. A former supervisory relationship or a friendship does not automatically require you to disqualify yourself from serving on a hiring panel or from taking part in other City actions. In some cases, a former supervisory relationship can help the City better evaluate a potential employee. 

    You should disclose the relationship to your fellow panelists, your department head, and the SEEC and, depending on circumstances, you may need to disqualify yourself from the panel if your department makes the determination that your service on the hiring panel would be inappropriate. If you feel that you cannot be impartial, you should make that clear to management and avoid involvement in the process. Here is a disclosure form to use. 

    However, you must disqualify yourself from participating on a selection panel if you or anyone in the above list (see Question 1) has a financial interest in the job or contract or if the candidate is your former client or employer within the past year. (There is a narrow exception for dealing with past employers and past clients, so get in touch with us if that's your situation.)

  3. My family business has a contract that is now assigned to my work unit. Is it ok for me to have one of my employees oversee the contract? 
    Answer: City supervisors and managers cannot have an interest in any contract, even indirect or through an immediate family member, that is under their chain of command. Your department will need to ensure that the administration of the contract is taken out of your chain of command.

For more assistance, contact SEEC staff.

Ethics and Elections Commission

Address: 700 5th Ave, Suite 4010, Seattle, WA, 98104
Mailing Address: PO Box 94729, Seattle, WA, 98124-4729
Phone: (206) 684-8500

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The Seattle Ethics and Elections Commission (SEEC) helps foster public confidence in the integrity of Seattle City government by providing education, training, and enforcement of the City's Code of Ethics and Whistle blower Code.