To ensure that the department can demonstrate compliance with the board's conflict-of-interest policy, the department should develop and implement a process by June 30, 2015, that results in a central depository of the conflict-of-interest certifications submitted by each employee.
As per this recommendation and the 60-day response a few documents were updated to better reflect and document requirements of Conflict of Interest (COI) policy established by the Board in August 2008. Here is the list of all documents updated:
1-Individual Conflict of Interest Certification Updated 9/21/2015
2-Standard Operating Procedure (SOP) No. 5b, Invitation for Bids (IFB) updated 9/29/2015
3-Standard Operating Procedure (SOP) No. 4, Request for Proposals (RFP) updated 9/29/2015
At present all COI documents for all contracts are kept at a central location before any item is submitted for the Board of Water and Power Commissioners approval.
As explained in the letter dated May 11, 2015; the LADWP understands its duty and commitment to ensure that the integrity of decision-making by the organization is not compromised by the private interests of its employees. This is accomplished through the implementation of effective procedures for the identification, disclosure, and management of any conflict-of-interest situations.
To achieve this objective, the LADWP has undertaken a thorough review of its current Conflict of Interest (COI) Policy established by the Board in August 2008. Current improvements to the policy include modification to the COI form, as well as issuance of the new Supply Chain Services Standard Operating Procedures which requires employees involved in the evaluation and award of contracts to complete a COI form at each stage of the procurement process. Further improvements will include the development of a centralized database of all employees participating in each phase of the contracting process and a central repository for all COI forms.
Agency responses received are posted verbatim.