Provide training to those responsible for reviewing statements of economic interests regarding how to identify conflicts of interests and when to consult with legal counsel.
The Water Board reported that in February 2017 it distributed a memo prepared by its chief counsel that explained the importance of conflict-of-interest reviews, when to consult counsel for advice, and the Water Board's new review process to help avoid conflict-of-interest violations. In addition, the Water Board stated that it would develop a training module for its supervisors and managers to review annually on its intranet site.
The Water Board reported that due to the timing of developing a best practices memo, it determined that it was impractical to train all supervisors and managers before the annual due date for the annual statement of economic interests. Thus, the Water Board distributed the best practices memo with instructions for supervisors and managers to contact the Water Board's legal staff with any questions. It also provided executive management with instructions on implementing these procedures. Further, the Water Board stated that, as part of developing a training curriculum for supervisors on best practices for human resources-related issues, it would include the review processes in this future training.
The Water Board reported that its new process is in place and being implemented. However, the Water Board has not described to us how it will provide training to staff responsible for reviewing statements of economic interests.
The Water Board informed us that its Division of Administrative Services management will perform an initial screening of all statements of economic interests that staff submit. If division management notes potential conflicts of interest, the Water Board will refer the issue to the appropriate highest level manager for resolution.