DEPARTMENT OF HUMAN RIGHTS AND ETHICS

RANJIT HAKIM
EXECUTIVE DIRECTOR
69 W. Washington St. Suite 3040 Chicago, Illinois 60602 (312) 603-1100 Fax (312) 603-9988

September 14, 2016

TONI PRECKWINKLE
PRESIDENT
Cook County Board
of Commissioners
RICHARD R. BOYKIN
1st District
ROBERT STEELE
2nd District
JERRY BUTLER
3rd District
STANLEY MOORE
4th District
DEBORAH SIMS
5th District

VIA LEGISTAR
Members of the Board of Commissioners of Cook County
118 North Clark
Chicago, IL 60602
Honorable Members of the Cook County Board of Commissioners:
As part of the Presidents and the Board of Ethics continued commitment to increasing
transparency and accountability in County government, the Ethics Department and
representatives of the Presidents Office have come together to propose several
amendments to the Cook County Ethics Ordinance. The Ethics Ordinance amendments
being introduced at the September 14, 2016 Cook County Board meeting by President
Preckwinkle seek to amend, update and clarify numerous provisions of the Countys Code
of Conduct. The Presidents proposal:

Adds a purpose section to the Ethics Ordinance to identify various

responsibilities of Officials, Employees, and Board or Commission
appointees, such as owing a fiduciary duty to the County; putting
forth an honest effort in the performance of duties; conducting
business on behalf of the County in a financially responsible manner;
and adhering to all applicable laws and regulations. (See Sec. 2-561).

Adds and clarifies defined terms. (See Sec. 2-562).

Clarifies that the Ethics Ordinance applies to persons doing business

with the County, seeking to do business with the County or who have
done business with the County, as well as prohibited sources and
candidates for County elected office. (See Section 2-563). While
increasing the ethics obligations on persons covered by the various
provisions, the amendments also seek to reduce some of the
administrative burdens of doing business with the County by
unifying the point at which these obligations are triggered (e.g.,
unified definition of doing business would apply to the gift ban,
campaign finance rules, post-employment restrictions, etc., see 2562) and narrowing required disclosures to only information that is
relevant to the Board of Ethics compliance activities (e.g., familial
relationship disclosure will no longer ask about relatives working for
non-County governments, see 2-582(c)).

Clarifies the types of fiduciary duties that are owed by County

Officials, Employees and Board or Commission appointees. (See 2571(b)).

JOAN PATRICIA MURPHY

6th District
JESUS G. GARCIA
7th District
LUIS ARROYO, JR.
8th District
PETER N. SILVESTRI
9th District
BRIDGET GAINER
10th District
JOHN P. DALEY
11th District
JOHN A. FRITCHEY
12th District
LARRY SUFFREDIN
13th District
GREGG GOSLIN
14th District
TIMOTHY O. SCHNEIDER
15th District
JEFFREY R. TOBOLSKI
16th District
SEAN M. MORRISON
17th District

Makes the gift ban easier to understand, including the various obligations to disclose
all significant gifts received from prohibited sources, even when an exception to the
gift ban might apply. (See 2-574).

Clarifies the reporting requirements to the Board of Ethics relating to conflicts of

interest. (See 2-578).

Expands the Countys post-employment restrictions to limit County employees from

retiring on a Friday and returning to work the following Monday as independent
contractors. But also allows the Board of Ethics to waive various post-employment
restrictions if such a waiver would not result in a conflict of interest, disclosure of
confidential information or the appearance of impropriety. (See 2-580).

Expands the campaign finance provisions to limit campaign contributions by persons

seeking official action by the County, as well as persons and entities that have sought
official action within the preceding four years. (See 2-585).

Expands the types of promotional materials that should not be purchased with County
funds. (See 2-586).

And imposes sanctions for the failure to cooperate with Board of Ethics
investigations, including the imposition of fines for stonewalling against ethics
enforcement efforts. (See 2-601-02).

I look forward to discussing the proposed amendments to the Ethics Ordinance with you in the
upcoming weeks. Please do not hesitate to contact me directly to discuss the proposed
amendments or to discuss any potential comments or concerns.
Thank you in advance for your consideration.
Sincerely,

Ranjit Hakim
cc:

Brian Hamer, Chief of Staff, Office of the President

Laura Lechowicz Felicione, Special Legal Counsel, Office of the President