HomeMy WebLinkAbout2015 05-26 City Council Workshop PacketPPLLEEAASSEE NNOOTTEE SSTTAARRTT TTIIMMEE IISS 66::0000PPMM
AGENDA
MAPLEWOOD CITY COUNCIL
MANAGER WORKSHOP
6:00 P.M. Tuesday, May 26, 2015
City Hall, Council Chambers
A. CALL TO ORDER
B. ROLL CALL
C. APPROVAL OF AGENDA
D. UNFINISHED BUSINESS
None
E. NEW BUSINESS
1. Solicitation Policy Discussion
F. ADJOURNMENT
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AMENDED MEMORANDUM
TO: City Council
FROM: Melinda Coleman, City Manager
H. Alan Kantrud, City Attorney
DATE: May 26, 2015
SUBJECT: Solicitation Policy Discussion
Introduction and Background
The City of Maplewood, as all cities can, and Maplewood does, authorize the acceptance of gifts
to the City pursuant to State Law. However the City does not specifically authorize, and thus
does not have a policy regarding, the solicitation of gifts. This memorandum and its attachments
attempt to provide, for discussion and consideration, a policy for the City to go beyond the mere
acceptance of gifts and to authorize, pursuant to a defined policy, the solicitation of gifts and
contributions to the City for defined purposes and with clear intent.
In this environment of increasing private investment, combined with the power of cities to
harness greater members of the public to advance common goals and initiatives, the City would
like to articulate a policy for, and ability to, solicit funds for programs and initiatives beyond the
confines of the City’s general fund. The ability to seek solicitations, on behalf of the City, is
therefore intended to advance identified public purposes and create stronger ties to the
community while still staying within the confines of the Statutory laws of the State.
Discussion
The City has the ability to accept gifts and contributions pursuant to state law. Minnesota
Statutes section 465.03 authorizes the acceptance of gifts and contributions to governmental
entities and puts various procedural requirements on their acceptance. While not specifically
authorized, the ability to solicit those gifts and contributions are implied.
That being said, the City wishes to have a policy regarding the solicitation of gifts in an organized
and regulated manner and staff provides this memorandum and attachments to begin that
discussion.
Pursuant to that discussion, the attached Resolution is provided as a proposed policy.
(Attachment A).
Staff was most concerned with the concept of conflict of interest and the spectre of undue
influence. This is a real concern to staff as the concept of ‘solicitation of funds’ may suggest to
the public that the City may be putting itself into an untenable position with entities that are
approached.
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The Policy recommended attempts to address those issues. This Policy is intended to
encourage and allow the City (specifically certain members thereof) to approach potential donors
with the clear intention that, as emissaries of the City, they seek to solicit and collect funds for
clearly identified and publicly beneficial projects or programs that otherwise may be available to
support, but are not readily apparent to those potential donors.
The distinction of the Department Heads are called out due to their unique and critically
important roles for the City. Those department heads represent the core of the City’s mission
and in staff’s opinion deserve to also be included in those limited number of individuals beyond
the elected officials who will be able to encourage civic giving. This respects the commitment
that the City makes to Public Safety and Governance and would thereby allow those individuals
to solicit as if they were elected officials.
Departments themselves can, and are encouraged to, engage civic entities/businesses but only
through their Department Heads and only with clear authority from the City Manager and will be
subject to the same policy; no direct solicitation by staff is allowed in this Policy.
A further distinction is made with respect to businesses and entities that wish to support civic
functions and activities regardless of their status, assuming they are not currently, actively,
seeking approval of the Council for any reason. Staff supports this, as it allows current license-
holders and other city-regulated businesses to participate in civic events, celebrations and
initiatives, through their direct participation without running afoul of this policy. Nothing in this
policy is intended to discourage or otherwise limit participation in the way the City has conducted
those activities historically and the policy is intended to reflect that.
Staff has considered the conflict of interest as it relates to the concept of allowing public safety
officials also being solicitors of funds and has determined that with adoption of the policy, this
concern is addressed.
Two examples of the manner in which this policy has been handled are provided herewith to
give Council perspective on the issue. These are provided for perspective, and the staff is
confident that the proposed policy is consistent with the concerns articulated in the materials.
The theme in each is consistent: prevent undue influence; but allow the reasonable opportunity
to reach out to those entities that would likely support civic needs, initiatives and programs that
better the community.
The Atlanta policy (attachment B) is very succinct and merely provides guidance; the Missouri
policy (attachment C) is in keeping with the theme presented here, but goes into greater detail
and parses value and types of donations. These are complimentary yet contrasting positions.
The one you are considering takes a middle-ground approach and leaves some of the detail to
staff to handle without categorizing based on value.
Several national organizations have been consulted on this topic through the thoughtful
comments of the Minneapolis City Attorney who was consulted on this matter and who
graciously advised staff this on this issue. Their input has been considered in the Policy.
Staff supports this Policy not as a general fund revenue enhancement mechanism but as a way
to allow targeted giving and the opportunity for those that can give, to give, and to reinvest in
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programs they can support and want to support. Many supporters exist, and want to do what
they can, and this policy will give cover for the City to seek them out, identify the programs that
they can support, and allow the City to garner it.
Recommendation
Staff asks that the Council approve this conceptual policy of solicitation with any amendments
and modifications and to further direct staff to bring the policy back for consideration and
adoption at a regular meeting for approval.
Attachments
1) Solicitation Policy
2) Atlanta Ethics Policy
3) Wentzville City Ordinance
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RESOLUTION
Of Maplewood City Council:By
ESTABLISHING GUIDELINES FOR THE SOLICITATION AND ACCEPTANCE OF
GIFTS ON BEHALF OF THE CITY.
WHEREAS, Section 465.03 of Minnesota Statutes states:
“Any city, county, school district or town may accept a
grant or devise of real or personal property and maintain such
property for the benefit of its citizens in accordance with the
terms prescribed by the donor. Nothing herein shall authorize
such acceptance or use for religious or sectarian purposes.
Every such acceptance shall be by resolution of the governing
body adopted by a two-thirds majority of its members,
expressing such terms in full .”
and
WHEREAS, the statute requires the City Council to formally accept a gift of
cash or tangible property before it may be accepted, expended, and or used by a
city department, board, commission, official, or employee; and
WHEREAS, the City Manager and City Attorney were charged to analyze
solicitation practices and recommend options; and
WHEREAS, the City Manager and City Attorney now recommend this
policy to permit solicitation for city purposes if pre-approved by the City Council or
conducted pursuant to a City Council approved solicitation policy; and
WHEREAS, gifts to the City are beneficial because they promote or assist
public programs and projects and reduce the need for expenditure of public funds;
and
WHEREAS, despite the public benefits, gifts solicited or offered to the City
must be scrutinized to assure that they do not raise conflict of interest problems,
special treatment concerns, or other ethical issues and;
NOW, THEREFORE, BE IT RESOLVED that the City Council
approves the attached Exhibit A as the City’s policy for the solicitation and
receipt of gifts to the City; and
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BE IT FURTHER RESOLVED that this Resolution shall take
effect on July 1, 2015; and
BE IT FINALLY RESOLVED that the City Clerk is directed to transmit
certified copies of this Resolution to every elected or appointed local official
andother department head.
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EXHIBIT A
POLICY ON
SOLICITATION AND ACCEPTANCE
OF GIFTS ON BEHALF OF THE CITY FOR CITY PURPOSES
Part 1. SOLICITATION OF GIFTS ON BEHALF OF THE CITY FOR CITY PURPOSES
a. General Conditions
1. A Council Member, or appointed local official or employee shall
not solicit any gift to the City under circumstances that in fact or in
appearance:
(a) Rewards, influences, or tends to impair the judgment of any
elected local official, or appointed local official or employee
in the performance of the official's or employee's official
duties; or
(b) Provides special consideration, treatment, advantage,
privilege, or exemption for, or coerces, a potential donor.
2. OfficialEmployees with enforcement powers, such as inspectors,
regulators, police and prosecutors, excluding the Chief of Police
and Fire Chief and Department Heads, should not solicit gifts from
any source;
3. OfficialEmployees with direct discretionary authority over any
permit or application should not solicit gifts from any source.
4. No gift from an anonymous donor shall be solicited under any
circumstance. Unsolicited anonymous gifts may be accepted
pursuant to Minn. Stat. 456.03the Gifts to the City Policy.
5. No gift shall be solicited from a lobbyist or principal as defined in
Minnesota Statutes, section 10A.01 Subd. 21 and 33. and the
Minneapolis Ethics in Government Code, Chapter 15.
6. No gift shall be solicited from an interested person. For purposes
of this Policy, interested person shall have the meaning given by
Minnesota Statutes, section 471.895 Subd. 1(c) and the
Minneapolis Ethics in Government Code supplemented by the
following:
(a) Current City vendors and contractors;
(b) Vendors, contractors, entities or individuals who have had
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contracts or submitted proposals or bids within the last 12
months;
(c) Vendors, contractors, entities or individuals reasonably
anticipated to have business with the Ccity within the next 3
months.
(d) Persons or entities actively promoting or opposing active,
pending, Ccity legislation.
(e) Persons or entities with matters pending before thea Ccity
Council, or one of its Ddepartments, Bboards or
Ccommissions.
(f) This section shall not apply to the solicitation of support,
gifts, prizes or discounted services obtained from vendors,
licensees or businesses in furtherance of any civic
celebration or initiative for which the Council accepts
pursuant to State Law and for which no requirements of
use or expenditure is attached, implied or required and
otherwise complies with the limitations imposed generally
to gifts in this section.
7. No gift shall be solicited if its intended use is inconsistent with or
otherwise seeks to circumvent laws, regulations or policies of the
City, County or State.
8. No gift shall be solicited if such gift reasonably may be viewed as
funding for political activities.
9. No gift shall be solicited that will impose an onerous requirement
for its acceptance, maintenance, or eventual disposition by the
city, including but not limited to the approval of land-use,
development or redevelopment projects unless such gift is
intended to enhance public spaces associated therewith.
10. Requests to the general public, rather than selected individuals or
businesses, are recommended to be made in writing and contain
a statement that government action regarding the donor will not
be affected by whether or not a contribution is made. ?
b. Solicitation by Departments, Boards, Commissions and Advisory
Committees or their designee
1. When a department desires to solicit gifts, the head of the
department shall submit a completed Request to Solicit Gifts form
(Form A) to the City ManagerCoordinator with a copy to the Ethics
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Officer. The department shall not engage in any solicitation effort
until the Request to Solicit Gifts form (Form A) is approved by the
City ManagerCoordinator. Once approved or denied, the Request
to Solicit Gifts form (Form A) shall be filed by the City
ManagerCoordinator with the City Clerk with a copy to the
department. All gifts received pursuant to the approved solicitation
may be accepted pursuant to the Gifts to the City Policy and
approved by the City Council pursuant to Minn. Stat. 465.03.
2. When a board, commission or advisory committee, or designated
employee desires to solicit gifts, the head of the board, commission
or advisory committee shall submit a completed Request to Solicit
Gifts form (Form A) to its assigned department for approval by the
department head. If the department head approves the proposed
solicitation, the department head shall submit Request to Solicit
Gifts form (Form A) to the City Coordinator with a copy to the Ethics
Officer. The board, commission or advisory committee shall not
engage in any solicitation effort until the Request to Solicit Gifts
form (Form A) is approved by the City Coordinator. Once approved
or denied, the Request to Solicit Gifts form (Form A) shall be filed
by the City Coordinator with the City Clerk with a copy to the
department. All gifts received pursuant to the approved solicitation
may be accepted pursuant to the Gifts to the City Policy.
3. When a department desires to solicit gifts valued at more than
$2015,000.00 such solicitation must not occur until a resolution,
approving the solicitation and naming the Department Head as
designee of the City Council, has been approved by a two-thirds
vote of the City Council.
34. All appointed local officials and employees soliciting gifts for the
City shall submit a Quarterly Solicitation Report (Form B) to the City
Clerk with copies to the City ManagerCoordinator and the Ethics
Officer.. Quarterly Solicitation Reports are due 10 calendar days
after the end of the quarter.
c. Solicitation by Elected Local Officials.
1. Solicitations by the Mayor or designee or an individual City Council
member or designee of an individual City Council member or the
City Council as a whole or designee of the City Council shall
comply with General Conditions, Part 1(a).
2. All elected officials or their designees soliciting gifts for the City
shall submit a Quarterly Solicitation Report (Form B) to the City
Clerk with copies to the City ManagerCoordinator and the Ethics
Officer. Quarterly Solicitation Reports are due 10 calendar days
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after the end of the quarter.
d. Application. These provisions shall apply except where more restrictive
statutes, ordinances, rules, or administrative policies are in effect.
Part 2. ACCEPTANCE OR REJECTION OF GIFTS TO THE CITY
a. General requirements
1. Restrictions on acceptance. An elected local official or ,
appointed local official or employee shall not accept or receive
any gift to the city under circumstances that in fact or in
appearance:
(a) Rewards, influences, or tends to impair the judgment of any
elected local official, appointed local official or employee in
the performance of the official's or employee's official
duties; or
(b) Provides special consideration, treatment, advantage,
privilege, or exemption for or coerces a potential donor.
(c) Is unrelated to the responsibilities and authorized functions
of City government.
(d) Is made by a donor who has made contributions to the City
on such a frequent basis as to create an appearance of
impropriety. No donor shall make contributions that
nonetheless adhere to this policy that exceed 3
contributions in a calendar year.
Consideration of these requirements will be presented to
the entire City Council by the City Manager with their
recommendations and acceptance shall include a finding
that none of the circumstances above exist and pursuant to
Minn. Stat. 465.03.
2. Notification of prospective donor. Upon notification ofaccepting a
prospective gift, an elected local official, or appointed local official
or employee shall immediately notify the prospective donor in
writing that the gift is subject to acceptance by the City Council;,
that the gift will not result in any favored treatment for the donor in
pending or future procurement decisions; and that a gift will not
state or imply the endorsement of the City of any product, service
or entity,; except that this requirement shall not apply if the donor is
anonymous and the anonymous gift is permitted to be accepted
under this Policy. (See sample Donor Notification Letter – Form C)
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3. Endorsement prohibited. Acceptance of a gift must not state or
imply the endorsement of the City of any product, service or entity.
4. Return of Rejected Gifts Not Approved. No gift shall beIf a gift is
taken into custody by a City employee, local official or elected
official ifbut athe resolution to accept the gift is not adopted by a
two-thirds vote of the City Council, the gift shall be returned to the
prospective donor,. pursuant to Minn.Stat. 465.03.
5. Use of Gift. Use of a gift must be accounted for through record
keeping and is subject to the restriction in this Policy. The City
Clerk shall ensure that gifts and contributions to the City are utilized
pursuant to any legal restrictions imposed by donor and shall report
to the City Council annually as to their disposition.
b. Acceptance of Gifts
Acceptance by Council of gifts to the City shall be pursuant to the Gifts to the City
Policy, using the Gift Acceptance Form (Form D).
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REQUEST TO SOLICIT (FORM A)
Project for which gifts will be solicited:________________________________________
Background information on project: _________________________________________
______________________________________________________________________
Amount of money to be raised:_____________________________________________
In-kind donations sought:__________________________________________________
______________________________________________________________________
How the gifts will be used to aid or facilitate the project or otherwise carry out the
department’s responsibilities, functions or activities: ____________________________
______________________________________________________________________
______________________________________________________________________
Staff conducting the solicitations:___________________________________________
Entities or persons sought to be solicited and status of entity:
Entity or Person
.
Lobbyist Lobbyist
Principal
Interested
Person
Other
Pending
City
Business
Submitted by:____________________________ Date:_________________
Department Head
City Coordinator Use Only
___Approved through _______________________
Date
___Denied
City Coordinator to file original with City Clerk, Copy to Department
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QUARTERLY SOLICITATION REPORT (FORM B)
Report submitted for Quarter ending 3/31, 6/30, 9/30, 12/31 (circle one)
Entity or Person Item Solicited Date Solicited
Solicited
______________ ______________________________ ___________
______________ ______________________________ ___________
______________ ______________________________ ___________
______________ ______________________________ ___________
______________ ______________________________ ___________
______________ ______________________________ ___________
______________ ______________________________ ___________
Submitted by: _____________________________________________________
Name Position Dept
File original with City Clerk, Copies to City Coordinator & Ethics Officer
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DONOR LETTER (FORM C)
[Date]
[Donor Name]
Donor Address]
[City, State ZIP]
Re: [Gift of __________________]
Dear [Donor Name],
On behalf of the City of Minneapolis, I would like to thank you for your generous proposed
donation of [$_______ or describe goods] to the City [If gift comes with any restrictions, they
should be listed here. For example: on the following conditions: ___________]. Your
proposed donation is subject to acceptance by the City Council. Minnesota state law requires
that all gifts to municipalities be presented by resolution to and approved by a two-thirds vote
of the City Council. Acceptance of your donation does not state or imply the endorsement of
the City of any product, service or entity connected to you and acceptance will not result in any
favored treatment for you in pending or future procurement or other City governmental
decisions. Your donation will be submitted for approval at the [Month, date, year] City Council
meeting.
Very truly yours,
Department Head or designee
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GIFT ACCEPTANCE FORM (FORM D)
TO: Finance Officer
300M, City Hall
FROM: ____________________
Department
Description of gift (including value of gift, date received and special conditions related to
acceptance of gift, if any) _______________________________________________________
___________________________________________________________________________
___________________________________________________________________________
Name & address of entity or person making gift:
___________________________________________________________________________
Status of entity or person making gift:
Principal: Yes___ No___ Principal lobbyist: Yes___ No___
City Vendor: Yes___ No___ Other interested person: Yes___ No___
If yes to any of the above, please provide further information about give r’s status:
___________________________________________________________________________
Certifications (please initial):
____ The gift will be used by the department to fulfill an authorized function or duty;
____Any gift is consistent with the department's plans for its programs and projects;
____The gift is directly related to, and will be expended solely for, a discrete program
and/or purpose; and
____The gift is consistent with the Policy on Solicitation and Acceptance of Gifts on Behalf
of the City for City Purposes.
Funding strings for revenue and expense appropriation increases:
Revenue:____________________________________________________________
Expense:____________________________________________________________
Form Prepared by: ____________________________________________________
Name Position
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