Through training and other appropriate means, take steps to ensure the district engineer and others in similar positions do not participate in decisions involving their own economic interests.
The Water Board stated that its revised conflict-of-interest code became effective in December 2016 and has now been implemented, along with its updated training modules, regarding how to recognize a conflict of interest. It stated that more than 250 employees had taken the training module. Lastly, the Water Board reported that in February 2017, it distributed a memorandum to all managers and supervisors, explaining the importance of conflict-of-interest reviews, when to consult counsel for advice, and the Water Board's review process to help avoid conflict-of-interest code violations.
The Water Board reported in August 2016 that it learned staff in its division of drinking water were still in decision-making roles on a few remaining projects. Thus, the Water Board stated that it would transfer these responsibilities to its division of financial assistance as soon as possible, as it had previously instituted the change in responsibilities between the two divisions. In September 2016 the Water Board informed us that it completed the transfer of financial assistance contracting decisions and invoice approvals to the division of financial assistance. In addition, the Water Board revised its conflict-of-interest code in September 2016 and sent the revised code to the Fair Political Practices Commission (FPPC) for approval. After the FPPC approved the revised conflict-of-interest code, the Water Board sent the approved code to the Office of Administrative Law (OAL), which will file the code with the Secretary of State. The Water Board stated that it anticipated the new code would take effect in late November 2016. Finally, the Water Board stated that it had drafted training modules that are under review. It stated that it anticipated the training modules will be fully updated by November 2016.