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LARKIN, HOFFMAN, DALY& LINDGREN, LTD. <br /> Mr. Bill Rubin, Executive Director <br /> Economic Development Authority <br /> (rune 7, 1994 <br /> Page 5 <br /> (1) Having an interest in any business which has contacts or <br /> other direct dealing with the City. <br /> President Gongoll ' s employer, and its subsidiary entities, <br /> are clearly businesses which have contacts and direct <br /> dealings with the City. However, I believe the City Council <br /> intended "having an interest" in such a business to mean <br /> having an ownership or financial interest, as opposed to <br /> being an employee. If President Gongoll does not have an <br /> ownership interest in Riverside or any of its subsidiary <br /> entities, and is an employee who is paid a fixed salary <br /> regardless of the outcome of any of Riverside' s dealings with <br /> the City, this provision would be complied with. On the <br /> other hand, if President Gongoll ' s compensation is dependent <br /> on the outcome of Riverside ' s dealings with the City, then he <br /> would potentially have an "interest" in the business and <br /> violate this provision. <br /> (4) Using an official ' s or employee's authority, influence, or <br /> City position for the purpose of private or personal <br /> financial gain. <br /> • This provision prohibits President Gongoll from using his <br /> position for the financial gain of himself or any other <br /> private entity, including his employer. I recommend that <br /> President Gongoll scrupulously avoid acting on any matter <br /> which could affect his or his employer' s interests, either <br /> positively or negatively, to ensure that this guideline is <br /> complied with. <br /> (7) Entering into a business transaction when it involves using <br /> confidential information gained in the course of employment <br /> or is with an individual or entity that has contacts or other <br /> direct dealings with the City. <br /> This provision prohibits the use of confidential information <br /> gained in the course of President Gongoll ' s service as <br /> President of the EDA. The most effective way to address the <br /> issue of "confidential information" is to simply not provide <br /> confidential information to the members of the EDA, as <br /> recommended above. <br /> The language in this provision prohibiting an official from <br /> entering into a "business transaction" with an entity that <br /> has contacts or other direct dealings with the City does not <br /> prohibit a City official from accepting employment with an <br /> entity that has contacts or other direct dealings with the <br /> City unless the employment, or the compensation for that <br /> • <br />