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Welcome!
Welcome!
What you'll find in this report
What you'll find in this report
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 FY2021 Annual Report includes information about activities that took place from July 1, 2020 through June 30, 2021 unless otherwise noted. For information about activities outside this timeframe, please visit the Board's main website at www.phila.gov/departments/board-of-ethics.
Annual Messages
Annual Messages
From the Board Chair
From the Board Chair
On behalf of the Board of Ethics, I welcome this opportunity to report on the Board’s activities and accomplishments in Fiscal Year 2021. This Report describes the Board’s efforts to fulfill its Charter-mandated responsibility to administer and enforce “all provisions of . . . [the] Charter and ordinances pertaining to ethical matters.” These ethical matters, collectively known as the City’s Public Integrity Laws, include the Campaign Finance, Ethics, Lobbying, and Financial Disclosure Laws and the Charter’s political activity restrictions.
FY2021 was an exceptional year for the Board of Ethics. Like most other City governmental entities, the Board’s physical office was closed during the entirety of FY2021 due to the COVID pandemic. While certainly presenting challenges to the Board’s operation, the City Offices Shutdown also provided opportunities for the Board to improve its services in certain areas
The best example of this involves the Board’s training. For years, Board Staff has envisioned utilizing virtual trainings, but the Board’s limited resources and staff were an obstacle to building a virtual platform. COVID and the related City Offices Shutdown radically changed all of this. Suddenly, virtual networking tools were prevalent everywhere and people from all around the City – who were not working in their City offices – gained access to new and better electronic equipment and software and quickly gained a familiarity with how these new resources worked.
The Board’s long-held plan to utilize virtual trainings suddenly became completely feasible and the Board Staff seized on this new opportunity. In FY2021, Board Staff shifted entirely to virtual training presentations – creating such presentations almost completely from scratch.
The shift was an instant success as it eliminated the need for both Board Staff and attendees to make (often long) commutes to the Board’s physical office. It also allowed Board Staff to incorporate various technical features that would be difficult or impossible at a similar in-person training setting.
As a result, Board Staff found it could not only offer more trainings, but it could also offer more specialized and detailed trainings focusing on specific subject matters and specific attendees – goals, again, that Board Staff had been envisioning for years.
The success of these virtual trainings has been tremendous with both the numbers of training sessions and the total attendees nearly doubling from the previous year. As such, these virtual trainings will certainly be a mainstay feature for the Board for the foreseeable future – even when the Board’s office reopens and the COVID pandemic becomes a distant memory.
The Board is grateful to its dedicated staff whose resilience, ingenuity and resourcefulness made the enhanced services in training, outreach and other education possible during the City Offices Shutdown.
While the City Offices Shutdown drove the Board to adapt its operations in a manner that improved services in certain areas, as noted in the Message of our Executive Director, the challenges presented by inadequate resources in other areas – particularly enforcement – were exacerbated by the City Offices Shutdown.
Again, I could not be prouder of the Board and its work during FY2021. Based on this hard work, we look forward, with enthusiasm, to the new FY2022.
Michael H. Reed, Esq., Chair
Michael H. Reed, Esq., Chair
City of Philadelphia Board of Ethics
From the Executive Director
From the Executive Director
FY2021 was truly extraordinary in that the Board’s physical office was closed throughout the entire fiscal year due to the COVID pandemic. This is certainly the most significant aspect of FY2021 and will certainly impact FY2022. Indeed, we’re now well into FY2022 and our physical office remains closed -- a status which began on March 16, 2020.
As such, our Board Staff has worked and continues to work remotely (although some have ventured back to the office on their own for a few days here and there) and our monthly and Board meetings continue to be held remotely via the Zoom platform.
As Board Chair Michael H. Reed explains in his Message, the City Offices Shutdown drove the Board to adapt its operations in many significant areas. Many of these adaptations only led to improved services. For example, as detailed in this Annual Report, Board Staff were able to nearly double the number of programs offered and people trained from FY2020 to FY2021. All these training sessions were held virtually via Zoom or Microsoft Teams – two platforms that the world barely knew about at the beginning of the City Offices Shutdown, but which have since then become ubiquitous. Our General Counsel Staff have mastered these platforms for training purposes and will continue to use them even when the pandemic subsides.
In addition to training sessions, these virtual platforms have become a key aspect with almost all elements of the Board’s work, including enforcement work, monthly Board Meetings, regulatory hearings, and intra-office, personnel meetings among Board Staff.
While these virtual platforms have carried us very far, they have their limitations. For example, a growing concern of mine is the fact that the Board hasn’t faced the public in a live meeting and that Board Members and Staff haven’t been in the same room together since the public Board meeting held on February 20, 2020 – over one year and seven months ago by the time this report is published. While we have been advised by the Law Department that remote meetings via Zoom satisfy the Pennsylvania Sunshine Law, I believe that something is lost when public meetings are held remotely. That said, it does not appear to be safe for members of the public, Board Members or Board Staff to hold in-person meetings for now or in the foreseeable future due to the ongoing pandemic.
The Board is as accountable to the public as any other public body and part of that accountability is accessibility. Such accessibility includes Board meetings, but includes other areas such as enforcement matters, regulatory hearings, and informal guidance. Part of the quality of this accessibility has somehow been lost in the world of virtual platforms, but there is little that we can do to change things, at least in the near term it seems. Hopefully circumstances will change soon.
Our continuing and possibly further budget reductions present additional challenges separate and apart from the pandemic, particularly with enforcement.
From 2014-2019, the Board had a Director of Enforcement and a Staff Enforcement Attorney, who reported to the Executive Director. In 2019, the Director of Enforcement position became vacant and in 2020 (for approximately four months) we had no Enforcement Staff Attorney. While we were eventually able to fill the Enforcement Staff Attorney position after a long, virtual search, that staff member has accepted a Deputy position in the Law Department as of the publication of this report, leaving the Enforcement Staff Attorney position vacant once again.
While I am confident that we will be able to hire a new Enforcement Staff Attorney in time, the continuing FY2020-FY2021 budget cut and the proposed additional 3% budget cut for FY2022, if adopted, will likely prevent the Board from having the robust Enforcement Staff structure that it had from 2014-2019. The Board would be better served with a Director of Enforcement and an Enforcement Staff Attorney or at least two Enforcement Staff Attorneys to fulfill its enforcement mandate efficiently, but that may not be possible with the proposed 3% budget cut on top of the Board’s already reduced budget with a backdrop of stagnate funding in prior years. That said, we will do our level best to fulfill our mandate to enforce the City’s Public Integrity Laws with the resources that we have.
In closing, last year, I noted that FY2020 was an extraordinary year and FY2021 continues that unprecedented trend. No matter how wearing this pandemic has been on us all, I cannot overstate how proud I am of the excellent performance and professionalism of the Board and Board Staff throughout the ongoing COVID-19 crisis.
J. Shane Creamer, Jr., Executive Director
J. Shane Creamer, Jr., Executive Director
City of Philadelphia Board of Ethics
About the Board
About the Board
What is the Board of Ethics?
What is the 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 the 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.
Report Overview
Report Overview
Advice
Advice
FY2021 saw fifteen formal opinions ⎼ four Board opinions and eleven 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.
Training & Education
Training & Education
Ethics training is required for all City officers & employees. In FY2021 we took advantage of Zoom and Teams 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.
FY2022 Outlook
FY2022 Outlook
Looking ahead to another year of resilience...
Looking ahead to another year of resilience...
As Board Chair, Michael H. Reed, stated in his message at the beginning of this Report, in many ways, the Board met the challenges presented by the ongoing City Offices Shutdown as an opportunity to improve and expand its services in certain areas throughout FY2021. However, a continuing reduced budget with a proposed 3% further reduction in our FY2022 budget, if adopted, presents serious ongoing challenges, particularly with enforcement.
The Board is proud to do its part in this unprecedented crisis. Despite our physical remoteness, Board Members remain highly engaged, Staff Members are highly motivated and leadership at every level remains strong.
I am confident that we will weather this storm, and despite the many challenges we face, the Board will fulfill its mission of promoting honesty, integrity and transparency in City government.
J. Shane Creamer, Jr.
J. Shane Creamer, Jr.
Executive Director
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