Each fall, the Board of Ethics publishes a summary of its activities and accomplishments over the preceding fiscal year, along with its Charter-mandated fiscal report. These annual reports are an important part of the Board's commitment to transparency. They tell the story of each fiscal year in numbers, photographs, and narrative.
The FY2022 Annual Report includes information about activities that took place from July 1, 2021 through June 30, 2022 unless otherwise noted. For information about activities outside this timeframe, please visit the Board's main website at www.ethics.pub.
On behalf of the members of the Board of Ethics, I am proud to submit this report regarding the Board’s Fiscal Year 2022 accomplishments. The energy, level of output and enthusiasm of the Board’s small staff and the quality of their work again enabled the Board to tackle its challenging mandate to administer and enforce the City’s Public Integrity Laws. These laws include the Ethics, Campaign Finance, Lobbying, and Financial Disclosure Laws, as well as the Charter restrictions on political activity by City employees. This Annual Report will describe our accomplishments in detail, but I wish to note here several projects and developments during the past year of which the Board is especially proud.
While occurring during the final days of FY2022, perhaps the most important development of the fiscal year for the Board regards the new, FY2023 budget that was signed by the Mayor on June 27, 2022. Importantly, funding necessary to enable the Board to perform its mandated duties that had been removed from the Board’s budget in prior years were restored under the FY2023 budget. With these restored funds, the Board has already begun the process of hiring two additional employees to restore its office to fuller capacity and assist current Staff members with the myriad of tasks, duties and obligations they have. These additional employees will better ensure that the Board is able to continue to provide the high levels (in both the quality and quantity) of work that the City has come to expect.
The Board commends the Mayor and City Council for appropriating these additional funds at this key time as we head into what promises to be a very busy year due to the upcoming 2023 Municipal Elections.
Also notable in FY2022 was the Board’s hiring of two attorneys to fill open positions on the Board’s Enforcement Staff. Restoring the Enforcement Staff closer to its pre-pandemic capacity was a major goal for the Board in FY2022. By adding two Senior Enforcement Staff Attorneys, the Board will be better able to fulfill its enforcement mandate during the current fiscal year – which promises to be especially eventful in view of the upcoming Municipal Elections and related and campaign finance matters. With an open seat for Mayor, every City Council seat, City Commissioners and the Sheriff, the Board is expecting 2023 to be a whirlwind of activity for the Board. There is also the possibility of Special Elections between now and May 2023 for several city offices and the Board will be administering and enforcing a recently amended Campaign Finance Law and the amended regulation recently adopted by the Board to implement that legislation. These recent developments will not only likely result in more enforcement activities but also the equally important opportunities for the Board and its staff to assist and educate candidates, campaigns and the public in complying with the law.
In addition to the budgetary and staffing matters noted above, I would like to briefly highlight certain other developments occurring in FY2022. The Board continued to expand its training programs, outreach endeavors, social media and website resources, and guidance-giving activities. Specific examples are many, but one of special note is the 9 separate Board Opinions issued by the Board in FY2022 – the second highest the Board has ever had in its 16-year, modern existence. Requests for advice are often time-sensitive and sometimes present complex and novel issues. Given the amount of time, effort and energy on the part of Board members and staff that goes into drafting these opinions, we believe this is an especially noteworthy accomplishment. In addition to Board Opinions, General Counsel Opinions are issued by our General Counsel and timely and accurate informal advice is provided by Board staff on an ongoing basis.
With a solid FY2022 now behind us, we look forward, with enthusiasm, to continuing our service to Philadelphia and the public and the upcoming challenges of the new fiscal year.
City of Philadelphia Board of Ethics
Calendar year 2022 has been a year of restoration for the Board. As Chair Reed noted in his opening message, the FY2023 budget signed by the Mayor on June 27, 2022 restored the Board’s budget that had been cut in FY2021 due to the pandemic and also restored two budgeted positions that had been cut at the same time. We recognize that not all City departments and agencies have had their budgets brought back to pre-pandemic levels yet and we are grateful that the Mayor and City Council made restoration of the Board’s budget a priority for the current fiscal year. The Board decided quickly and thoughtfully on how to use those restored resources.
As Chair Reed also explained, we were able to hire two Senior Enforcement Staff Attorneys in the Spring of 2022, thus restoring Enforcement Staff capacity well ahead of the 2023 municipal elections and possible special elections to fill vacant City offices prior to the May 2023 Primary Election.
Our new Senior Enforcement Staff attorneys have helped clear a backlog of investigations and assisted our General Counsel with amending the Board’s Campaign Finance Regulation this Summer, which gave them an excellent opportunity to get fully invested and familiarized with our campaign finance laws and regulations. Later this year, they will have an opportunity to assist in campaign finance training sessions. All this experience will prepare them for what we think may be a relatively high volume of compliance and enforcement work in what should be one of the most active and complex election years in the Board’s history.
Meanwhile, the restoration of funding and positions has enabled the Board to create a new Staff Attorney position that will report to the General Counsel and to hire into a vacant Civil Service Compliance Specialist position. As of the time of this Annual Report, the hiring process for those positions is ongoing.
Strategic Staff changes in 2022 continued with the Board’s recent promotion of Danielle Wright Gardner into the new position of Director of Training and Outreach. In this new strategic role, Dani will lead the Board’s training program and develop and disseminate educational materials in addition to providing guidance and advice. She will also manage the Board’s website and support administrative functions, including communication activities and administrative projects at my direction.
All of these changes are made possible with the restoration of resources and the timely and thoughtful planning of how to use those restored resources by the Board. We have an excellent team that we continue to build upon. I remain extremely proud of the work that we do in building public confidence in the integrity of City government.
City of Philadelphia Board of Ethics
Philadelphia's Board of Ethics was created in May 2006 by amendments to the City's Home Rule Charter. The Board interprets, administers, and enforces the ethics provisions in the Charter and City Code. These include the City's rules governing conflicts of interest, representation in City transactions, post-employment restrictions, gifts and gratuities, interests in City contracts, political activity, financial disclosure, lobbying, and campaign finance. The Board issues formal advisory opinions and promulgates regulations interpreting City ethics laws. In addition, Board Staff also provides informal advice, develops and delivers training, and offers compliance assistance. The Board also has the authority to investigate potential violations of the laws within its jurisdiction and enforce those laws through administrative adjudication or court proceedings.
Fourteen formal opinions were issued in FY2022 ⎼ nine Board opinions and five General Counsel opinions ⎼ covering a wide range of topics.
Want to know what topics are most popular with requestors? Curious about what keeps us busy during which parts of the year? We have answers.
Ethics training is required for all City officers & employees. In FY2022 we continued to expand our training offerings.
Classroom training isn't the only way to spread the word about the City's ethics rules. See what we're doing to creatively engage with stakeholders.
Manuals, blogs, explainers, oh, my! We are deploying a variety of resources to make ethics information available to everyone.
Board Chair Michael H. Reed noted in his Message that the most important development in the final days of FY2022 was the new FY2023 budget signed by the Mayor, which restored significant funds and two budgeted positions that the Board had in previous years. With careful planning and preparation, we have already hired two new staff attorneys, promoted another staff member into a new strategic position and are in the process of hiring two new staff members.
This restoration of funding will profoundly affect the Board’s efficiency and output and demonstrates how critical proper funding is to a small agency like the Board.
With these additional staff members and strategic reallocation of some existing staff made possible by the restoration of funding and positions, I remain confident that the Board will continue to fulfill its mission of promoting honesty, integrity, and transparency in City government.
Executive Director