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<br />LARKIN, HOFFMAN, DALY & LINDGREN, LTD. <br /> <br />Mr. Bill Rubin, Executive Director <br />~conomic Development Authority <br />,-une 7, 1994 <br />Page 5 <br /> <br />C>< (1) <br /> <br />e <br /> <br />e <br /> <br />Having an interest in any business which has contacts or <br />other direct dealing with the City. <br /> <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 /> <br />(4) Using an official's or em~loyee's authority. influence. or <br />City position for the purpose of private or personal <br />financial gain. <br /> <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 /> <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 /> <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 inforrriation" is to simply not provide <br />confidential information to the members of the EDA, as <br />recommended above. <br /> <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 />