A transaction is defined broadly under the Greenwich Code of Ethics to include the sale or furnishing of any real or personal property, materials, supplies or services to the Town directly as a vendor or prime contractor, or indirectly as a subcontractor, beneficial owner, family member or otherwise. Transactions include offers, such as bids on Town contracts, even if they are not accepted, but do not include gifts to the Town and similar arrangements where no valuable consideration is paid by the Town. Transactions with the Town include all transactions with Town boards, commissions, agencies or other entities owned or controlled by the Town.
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You can read or get your own copy of the ethics code (PDF).
The Greenwich Code of Ethics applies broadly. Under the definition of Town Officer, the Code applies to all 1) elected officials of the Town, 2) all appointed officials of the Town including members of the various Boards, Commissions, Committees and other agencies of the Town, 3) all Town employees, including employees of the Board of Education and Town owned or organized entities such as Nathaniel Witherell, Greenwich Library and the Bruce Museum, 4) any consultant to the Town or agent of the Town. The Code of Ethics also applies to Town contractors, whose contracts are generally subject to the requirement that they have not induced any of the above Town Officers to violate the Code. If you have a question about whether you are a Town Officer or how it applies to you, you may request an Advisory Opinion from the Board of Ethics.
If you are an elected or appointed Town official, a Town employee or a consultant to or agent of the Town, you are required by the Greenwich Code of Ethics to file reports disclosing certain interests in pending or active Town transactions. Such reports are required for any substantial personal financial interest in a Town transaction. For this purpose, elected officials include the 1st Selectman, the Town Clerk, the Tax Collector, the Probate Judge, any Registrar of Voters, Constable or Justice of the Peace and any member of the Board of Selectmen, the Representative Town Meeting, the Board of Education or the Board of Assessment Appeals. You are considered an appointed Town official, if you have been appointed or confirmed to a position by an elected official or a body of elected officials, such as the RTM. You are considered a Town employee if you receive payment or other compensation from the Town for full or part time services or any entity owned or controlled by the Town, such as Nathaniel Witherell, the Greenwich Library System or the Bruce Museum. An agent of, or consultant to, any entity owned or controlled by the Town is considered an agent of, or consultant to, the Town.
The Board of Ethics has provided additional information concerning ethics disclosure filings in its advisory opinions and in these FAQs.
If you require additional information please contact the Board. If you are a Town Officer, you may request an official advisory opinion from the Board.
What has to be reported
Where the aggregate value received exceeds $200 in a given Fiscal Year, the Greenwich Code of Ethics requires that Town Officers report both the nature of their interest(s) in Town transactions and the total value received as a result. Reportable interests include indirect interests, such as the interests of: 1) joint owners, general or limited partners or shareholders, 2) subcontractors and employees, or 3) spouses, children, parents or others who the reporting individual might reasonably be expected to provide financial support for. Where the financial compensation isn't a fixed amount, the individual filing a report may rely on a reasonable estimate and should file an amended report in the event that the estimate becomes materially inaccurate. Where an individual is reporting an indirect interest, reasonable reliance on the amount reported or estimated by the person with the direct interest is permitted.The Code requires the Board of Ethics to prescribe the forms on which interests are to be disclosed. In general, the Board seeks to obtain information sufficient to identify the transaction in question and the value of the reporting person's direct or indirect interest. Where the interest is indirect, such as that of a subcontractor, employee or family member, the Board seeks to obtain sufficient information to describe the relationship and the amount of value actually expected to be received by the reporting person. Estimates of dates and values may be used, subject to the filing of an amended statement if the estimate proves to be significantly different from the actual result. Where the value is uncertain, an explanation may be provided. The form provided by the Board is intended to provide for substantial compliance with the requirements of the Code. Filers who have difficulty providing the specific information requested are encouraged to file with the best information available and then contact the Board to obtain an advisory opinion with respect to the sufficiency of that information.
What does not have to be reported
Interests in transactions aggregating less than $200 a year do not need to be reported. In addition, Town Officers are not required to report on the employment agreement or other service transaction that makes them a Town Officer, such as a Town employee's employment contract or a consultant's consulting agreement. Moreover, regardless of the size of a transaction, interests in the transaction that are not financial in nature or are nominal or common to the interests of other citizens of the Town, need not be reported. Thus, the payment of taxes or assessments or a use or license fee for Town services or facilities is not required to be reported as long as, at the time it is paid, the tax, assessment or fee is generally applicable and the service generally available, to all Town citizens on equivalent terms and conditions.
For additional information concerning financial reporting requirements Click here.
The Board of Ethics has provided more detailed answers to a number of the most frequently asked questions about the Greenwich Code of Ethics. For these detailed answers please click on the subject matter that you are interested in below. If your question is not covered, you may request additional assistance from the Board by contacting a member of the Board Ethics. Click here to obtain contact information for the Board of Ethics. If you are a Town Officer, you may also request a formal opinion from the Board of Ethics as described in these FAQ's.
These FAQ's have been provided to assist Town officials and members of the public gain a general understanding of the requirements of the Code of Ethics. The application of the Code to any specific set of circumstances will depend on specific facts. While the information they contain has been drawn from the Code and the official advisory opinions and decisions of the Board, these FAQ's are not intended to serve as, nor should they be relied on, as a substitute for advisory opinions from the Board.