Conflicts of Interest

Overview

Ordinance Number 71493 is a charter amendment approved by City voters at an election held Tuesday, April 5, 2022. It has requirements for both Ward Redistricting (The People’s Commission) and Conflict of Interest Reporting and Responsibilities for members of the St. Louis Board of Aldermen.

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Conflicts of Interest (Section 31)

A member of the Board of Aldermen or employee of the Board of Aldermen may not use his or her official position or office, or take or fail to take any action, or influence others to take or fail to take any action, in a manner which he or she knows, or has reason to believe, may result in a personal or financial benefit for himself or herself; anyone related to the Alderperson or employee in the fourth degree of consanguinity or affinity; or a nongovernmental civic group, union, social, charitable, or religious organization of which the Alderperson or employee (or his or her spouse or registered domestic partner) is an officer, director, or board member, or which he or she holds any other position on the organization’s administrative or governing body.

An Alderperson or employee serving as a member of a board, commission, or any other entity as a representative of the City shall not have a conflict of interest when the business of that entity is before the City. An Alderperson or employee serving as a member of a board, commission, or any other entity not as a representative of the City but as a private citizen, even if the board, commission, or entity seeks out an Alderperson or employee to serve on such board, commission, or entity because of their position within the City, shall have a conflict of interest when matters touching upon the business of the board, commission, or any other entity comes before the City.

An Alderperson or employee has a conflict of interest with respect to any labor contract to which he or she, or his or her spouse, may be a party.

An Alderperson or employee must declare, on a form provided by the Clerk of the Board of Aldermen, conflict of interest under this Section. The Alderperson or employee must complete and deliver such form to the Legal Counsel to the Board of Aldermen within ninety-six (96) hours of the introduction of any ordinance, resolution, order, or other matter in the Board of Aldermen in which the Alderperson or employee has a potential conflict.

To the extent an Alderperson or employee believes that despite the existence of the circumstances described in this Section, they do not have a conflict of interest, they may request an opinion from the Legal Counsel of the Board of Aldermen to determine whether there is a conflict. Such opinions shall be made publicly available on the Board of Aldermen’ website within one day of the Legal Counsel issuing the opinion.

Any Alderperson with a conflict of interest on any matter shall abstain from voting but shall be counted present for the purposes of a quorum.

Any individual may file a complaint against any Alderperson or employee for failing to comply with this Section. A complaint shall be filed with the Legal Counsel of the Board of Aldermen on a form provided by the Clerk of the Board of Aldermen.

The Legal Counsel to the Board of Aldermen has the power to seek a fee in the Municipal Court of the City of St. Louis of no less than $500 dollars and no greater than $5000 dollars per incident against any Alderperson or employee the Legal Counsel finds to be in violation of this Section.

The Legal Counsel to the Board of Aldermen is hereby authorized to establish procedures to implement this Section.

Outside Employment (Section 32)

An Alderperson or an employee of the Board of Aldermen shall not accept employment or enter into a contract that:

• Interferes with the discharge of their public duty; or
• Creates a conflict of interest, as described in Section 31 of this Article, that would materially impair their ability to serve the City.

An Alderperson or an employee of the Board of Aldermen shall not accept employment or enter into a contract with any party or beneficiary relating to:

• A pending or existing City contract if the Alderperson or employee participated in the negotiation, development, awarding, or management of that contract; or
• Any other matter before the Board of Aldermen.

An Alderperson or employee shall not solicit or accept any money or other thing of value in return for advice or assistance on matters concerning the operation or business of City government or any matter before the Board of Aldermen.

An Alderperson or employee shall not represent any person or organization for a fee or any other thing of value before the Mayor, Board of Aldermen, member of the Board of Aldermen, any department of the City, or any City board, agency, commission, or committee of a City board, agency or commission.

An Alderperson or employee shall notify the Legal Counsel of the Board of Aldermen before accepting outside employment or entering into a contract for providing services. Such notification shall be submitted annually on the last Monday of January of each year that the outside employment or contract for services exists. The notification shall be in writing on a form provided by the Clerk of the Board of Aldermen

Notifications described in Subsection E shall be made available for public inspection and copying within five (5) days of receipt by the Legal Counsel to the Board of Aldermen. Notifications shall also be made publicly available on the Board of Aldermen website. If the Legal Counsel determines the notification needs curing, the Legal Counsel shall allow the Alderperson or employee 72 hours to amend and return the form prior to public inspection.

Any individual may file a complaint against any Alderperson or employee for failing to comply with this Section. A complaint shall be filed with the Legal Counsel to the Board of Aldermen on a form provided by the Clerk of the Board of Aldermen.

The Legal Counsel to the Board of Aldermen has the power to seek a fee in the Municipal Court of the City of St. Louis of no less than $500 dollars and no greater than $5000 dollars against any member or employee the Legal Counsel to the Board of Aldermen finds to be in violation of this Section.

The Legal Counsel to the Board of Aldermen is hereby authorized to establish procedures to implement this Section.

Prohibited Activities (Section 33)

After November 12, 2021, no Alderperson or employee of the Board of Aldermen shall act, serve, or register as a lobbyist to directly or indirectly influence a decision of the City or any department or agency thereof until one year after termination of their service or employment.

After November 12, 2021, no Alderperson or employee of the Board of Aldermen, until the expiration of five calendar years after the conclusion of the aldermanic session in which the Alderperson or employee last served, shall attempt to directly or indirectly influence any action in front of any department or agency of St. Louis City, or any court, on behalf of any other person in connection with a particular matter:

1. In which the City of St. Louis is a party or has a direct and substantial interest;
2. In which the Alderperson or employee participated during their term of service or employment at the Board of Aldermen; and
3. Which involved a specific party or specific parties at the time of such participation.

After November 12, 2021, no Alderperson or employee of the Board of Aldermen, until the expiration of five calendar years after the conclusion of the aldermanic session in which the Alderperson or employee last served, shall attempt to directly or indirectly influence any action in front of any department or agency of St. Louis City, or any court, on behalf of any other person in connection with a particular matter:

1. In which the City of St. Louis is a party or has a direct and substantial interest;
2. In which the Alderperson or employee knows or reasonably should know was actually pending under his or her official responsibility as such officer or employee within a period of one (1) year before the termination of his or her service or employment with the Board of Aldermen; and
3. Which involved a specific party or specific parties at the time it was so pending.

Any individual may file a complaint against any Alderperson or employee for failing to comply with this Section. A complaint shall be filed with the Legal Counsel of the Board of Aldermen on a form provided by the Clerk to the Board of Aldermen.

The Legal Counsel to the Board of Aldermen has the power to seek a fee in the Municipal Court of the City of St. Louis of no less than $500 dollars and no greater than $5000 dollars against any member or employee the Legal Counsel to the Board of Aldermen finds to be in violation of this Section.

The Legal Counsel to the Board of Aldermen is hereby authorized to establish procedures to implement this Section.

Violation Report Forms