Frequently asked questions
This page contains answers to common questions about integrity and ethics in City government.
Gifts, gratuities, and honoraria
If someone offers me a gift, meal, or invitation, may I accept it?
It depends on who is making the offer. As a City employee, you must act only in the City’s best interest. Your actions and decisions as a City employee must not be affected (or appear to be affected) by any gift or benefit you may receive.
All City employees and officials are subject to the City Charter, the City Ethics Code, and the State Ethics Act.
Under Section 10-105 of the City Charter, paid City officials and employees must not seek or accept any gratuity for any “act or omission” in their work. A gratuity might be a gift, meal, or invitation.
Under Section 20-604 of the City Ethics Code, City employees and officials must not:
- Ask for any gift, regardless of value.
- Accept gifts worth more than $99 total per calendar year from any person with an interest in official actions by the employee or official.
- Accept any gifts of cash from any person with an interest in official actions by the employee or official.
Under Section 1103(c) of the State Ethics Act, certain City employees must not ask for or accept anything of monetary value on the understanding that it would influence you. This includes:
- Political contributions.
- Promise of future employment.
City employees under the jurisdiction of the Mayor must also follow the Mayor’s Executive Order on Gifts, 10-16. This does not include other elected officials and their staff. Under this order, employees can’t accept gifts regardless of their value of the giver’s intentions. There are very limited exceptions.
The Chief Integrity Officer can answer questions about the order. You should also review the rules and regulations, our helpful one-page guide, and video on what to do if you receive a gift.
Good rules of thumb to keep in mind are:
- It’s always best to ask for advice from the City’s Board of Ethics or Chief Integrity Officer before you take action.
- Apply the six o’clock news test. Say “no” if you wouldn’t want it reported on the six o’clock news.
- When in doubt, just say “no, thank you.”
What if someone sends concert tickets to my office?
If someone who does business with your department sends concert tickets to your office, the answer is “No, thank you.”
If a gift or invitation is left for you at your workplace, you have three choices:
- Return the gift.
- Decline to attend.
- Pay for the gift in full.
If you return the gift or decline the invitation, you must write a note to the donor explaining why your action was necessary.
You also have to send a notice of your decision to the executive director of the Board of Ethics and your direct supervisor. Employees in the Executive Branch must also send this notice to the Chief Integrity Officer (CIO) and the Inspector General (IG).
What if someone sends flowers to my office?
If someone leaves you a perishable gift, such as a fruit basket or flowers, you have three options:
- Share it with co-workers.
- Destroy it.
- Donate it to charity.
You must do one of these within three days of receiving the gift.
If you receive something that is not practical to return or is from an anonymous donor, you must notify the head of your department, agency, office, board, or commission. They will determine a fair use for the gift. You must also send a note to the donor thanking them for the item and asking that they refrain from sending anything else.
Section 4 of the Mayor’s Executive Order on Gifts has limited exceptions to the gift prohibition. You may never accept cash or a gift card in any amount. Report cash gifts to the Inspector General immediately.
I’ve been asked to present at a conference. The event hosts have offered to pay for my attendance and travel expenses. What do I do?
In some circumstances, a gift might be considered a “gift to the City,” rather than to you personally. This usually applies to invitations to conferences or receptions, rather than tangible items. If accepting a gift or attending an event would benefit the City more than the invitee, it may not violate the gift prohibition.
If an employee or official is invited to an otherwise prohibited event, the agency or department head (or their designee) must decide if the invitee is the logical person to represent the City at the event. The approving official must provide written approval. The approval must include:
- The date that the invitation was received.
- The nature of the gift.
- Why the City should be represented at the event.
- Why the invitee is the appropriate City employee to attend.
The approving official should consider:
- Whether the event is related to the City employee’s official duties or expertise.
- If the employee will receive training or information to help perform their job better.
- Whether there are unnecessary or lavish benefits unrelated to the governmental purpose.
If you have any questions, email the Chief Integrity Officer at email@example.com or call (215) 686-2178 or (215) 686-2120.
If you work outside of the Mayor’s jurisdiction and have any questions, seek advice from the Board of Ethics by calling (215) 686-9450 or emailing BOEGCStaff@phila.gov.
If anyone offers you a gift or invitation that appears intended as a bribe, promptly email the Inspector General’s Office at firstname.lastname@example.org or call (215) 686-1770.
In some cases, you may be required to disclose a gift as part of your financial disclosure obligations as a City official or employee. Review the FAQ section on financial disclosures to learn more.
May I accept a tip for my good work?
No. As public employees, we operate under a different standard than those working in private industry. We must not appear to be affected by any expectation of a reward other than the tax dollars that pay us.
Under Section 10-105 of the City Charter, paid City officials and employees must not seek or accept any gratuity for any “act or omission” in their work. You must decline these offers, no matter how well-intended. If pressed, you can explain that accepting a tip would get you in trouble. You can suggest that the person write a note of appreciation to your supervisor instead.
If you suspect that someone is offering something intended as a bribe, email the Inspector General’s Office at email@example.com or call them at (215) 686-1770.
Can I accept an honorarium to speak in my official capacity?
Honoraria is a payment given for a professional act or service that has no formal cost. This often includes published works, appearances, speeches, and presentations.
Section 1103(d) of the State Ethics Act prohibits employees and officials from receiving honoraria. This also applies to members of City boards and commissions. You must decline any offers of honoraria.
The person offering the honorarium may suggest that it could be donated to a charity of the official’s choice. This is also prohibited because the official would still control over the money.
Plaques and small tokens of de minimis economic value (such as a pen or a mug) are not considered honoraria.
Conflicts of interest
Is it a problem if either I or a family member has a financial interest in a decision that I must make at work?
Yes. Sections 1102 and 1103(a) of the State Ethics Act and Section 20-607 of the City Ethics Code prohibit City employees and members of a City board or commission from making any decision or taking any action that could affect you or your family’s financial interests.
This could relate to:
- Awarding contracts.
- Decisions relating to the use of City property.
- Considering applications.
- Awarding licenses.
- Enforcement of City codes or rules.
- Decisions relating to litigation.
- Almost any decision you must make in your official capacity.
You must disclose the conflict of interest and disqualify yourself from any involvement in the decision. You must do this before the decision is made or action is taken.
If in doubt, seek advice from the Board of Ethics before you act.
What should I do if I, as a City employee, have a conflict of interest?
If you are in a position to take official action that could financially affect you or your family’s interests, you must file a letter disclosing that interest and disqualify yourself from taking any action on it. For conflicts not involving legislation, you must file a letter that:
- States your name, City title, and duties related to the conflict.
- Describes the financial interest or relationships at issue.
- States that you intend to be disqualified from taking official action in all matters related to the conflict.
The letter must be sent by certified or registered mail to:
- Board of Ethics
- Department of Records
- Head of your agency (e.g. Commissioner, Executive Director)
For additional information or guidance, seek advice from the Board of Ethics before you act.
May I take part in a community or charitable organization as an unpaid volunteer that has a matter before the City?
It depends. As an unpaid volunteer, you may not have a financial interest, but a conflict could exist under the State Ethics Act. Furthermore, under Section 20-602 of the City Ethics Code, City officials and employees must not represent others in City matters. This includes community or charitable organizations. You should seek advice from the Board of Ethics before you act.
May I listen to a pitch from a company or person that wants to sell a product or service to the City?
First, you’re not obligated to meet with someone who wants to make a pitch for City business.
If this is a product or service that you think might benefit the City, you are permitted to receive information about it. However, you must do so in a way that ensures the City will get the best value and is fair to prospective vendors. Your actions must also follow applicable procurement and ethics rules.
Suggest that the prospective vendor send you more information. You can also meet with the prospective vendor in your office or a virtual meeting, but more than one City employee should be present. You may not accept a meal or an invitation to an event from a prospective vendor to discuss doing business with the City. Do not reveal that the City is planning to bid for a particular product or service, and do not promise any City business to the potential vendor.
If you think that the proposed product or service would benefit the City, you must follow the City’s procurement rules. Your department must ask for bids or proposals for the product or service. Then all prospective vendors can respond to the solicitation.
Outside and post-employment
May I get a second job outside of City employment?
It depends on your role with the City, as well as the type of second job.
City officers and employees
Executive Order 12-16 sets rules for outside and self-employment. These rules ensure that your second job does not interfere with your work for the City. The executive order:
- Prohibits you from working a second job while being paid for or doing City work.
- Forbids the use of City resources for outside or self-employment. City resources include vehicles, telephones, computers, office space, equipment, and supplies.
- Prohibits outside or self-employment while on City sick or disability time.
- Requires City executive department employees to get written approval for outside or self- employment from an appointing City authority.
- Allows departments to have their own, stricter rules on outside employment.
- Requires reporting of outside employment to the City’s Office of Human Resources and to the mayor.
For more information on the executive order, seek guidance from your HR manager or the Office of the Chief Integrity Officer.
You may not use sick or injury leave from the City to perform outside employment. If you become sick, injured, or disabled because of your outside employment, you may not receive paid sick leave or injury benefits from the City. You must also disclose the compensation from your outside job on all financial disclosure forms that you are required to file.
These are general rules. As noted above, your agency or department may have a more restrictive policy on outside employment. Before seeking or accepting outside employment, make sure that it does not violate any policy of your agency or department.
Civil service employees
In addition to the executive order, civil service regulations apply to you. These regulations allow outside employment, only if:
- The work is compatible with your official duties.
- The work won’t bring disfavor or disrespect to you, your department, or the City. The authority of your office, board, or commission makes this judgment.
- The work won’t interfere with or negatively affect the performance of your City work.
All City officials and employees, including elected officials and their staff
Should you get outside/self-employment, remember the following:
- Section 10-102 of the City Charter bans you from benefiting from or having direct or indirect interests in contracts with the City. This includes subcontracting and leasing a property to the City.
- Section 20-607 of the City Ethics Code and Sections 1102 and 1103(a) of the State Ethics Act forbids you from having a personal or family financial interest, or having a financial interest in a business or other entity, that has a financial interest in your business decisions for the City. If that is the case, you must disclose the interest and disqualify yourself from any official decision or action involving that interest.
- Section 20-602 of the City Ethics Code prohibits you from representing others in matters before the City. You cannot address and remedy this situation by disclosure and disqualification. It is a flat-out prohibition.
Section 20-609 of the City Ethics Code bans you—whether a paid or unpaid, full-time or part-time employee—from directly or indirectly disclosing or making available confidential information about property, government, or affairs of the City to advance your or another’s financial interests.
May I speak with firms who do business with the City about possible future employment?
This may be a financial conflict of interest if your City employment puts you in a position to make a decision or take action about that firm. There are disclosure requirements if:
- You’ve done or said something to apply for employment.
- A potential employer has done or said something that would signal a job offer to you.
If this is the case, you must disclose your financial interest in the firm and disqualify yourself from any decision or action on it. Sections 20-607 and 20-608 of the Ethics Code require this.
The Board of Ethics has also advised that City employees are prohibited from applying for or accepting a job where the position itself would be funded by a City Contract. For more information on this guidance, review City Charter Section 10-102 or contact the Board of Ethics.
Are there any restrictions on my post-City employment?
Both State and City ethics rules ban you from using your City position to further your business interests if you stop working for the City. These laws apply regardless of whether you actually intend to exploit your former City position in your new employment.
For more information on these post-employment restrictions, please the Life after the City handout developed by the Board of Ethics, Chief Administrative Office, and the Chief Integrity Office.
Who needs to file annual financial disclosure forms?
Many City employees and officials are required to complete between one or two financial disclosure forms each year depending on their title and responsibilities. The forms cover the calendar year and are due on May 1 of the year following the year of reporting. The City’s Board of Ethics will contact you if you have to file a financial disclosure form. Staff will provide details on which form(s) you must file, when the form(s) are due, and how to complete the process.
Why do I have to file annual financial disclosure forms?
Financial disclosure forms make potential financial conflicts of interest public. The state and the City require the disclosure of direct or indirect sources of income from certain City employees and officials. You can learn more about financial disclosure on the Board of Ethics website.
Can I view financial disclosure forms submitted by City employees and officials?
Yes, you can search for financial disclosure statements using the financial disclosure statements search. Online copies of financial disclosure forms are available for:
- Elected officials.
- The mayor.
- The mayor’s cabinet.
- Senior administration officials
To view the financial disclosure forms of anyone not included in this group, contact the Department of Records.
How can I find out about contracting opportunities with the City?
To find out more about contracting with the City, visit the Procurement Department and eContractPhilly.
May I pitch my company’s product or service to the City?
Yes, City officials want to know about goods or services that could benefit the city and its residents. You may contact the appropriate City employee by email or letter with a description of your product or service. If the employee would like further information, they can ask to meet with you for more detail.
Note the following for discussion of business proposals:
- Meetings should virtually or occur in City offices.
- You may not take a City employee out for a meal, entertainment, or other event.
If the employee decides your proposed product or service might benefit the City:
- The City will not simply offer your company a contract for it.
- Except in very limited circumstances, the City must request bids or proposals for the good or service.
- Your company will have an opportunity to offer a bid or proposal in response to the City’s solicitation.
How can I express appreciation for a City employee’s work?
All City employees are subject to the Gifts Ordinance, and most are subject to the Executive Order on Gifts. These gift rules prohibit employees from accepting cash and gift cards and places additional restrictions on gifts from prohibited and restricted sources. In lieu of providing a gift, our recommendation is to send a thank you note or email to the employee. You may also notify the department or agency head.
Can I invite an administration official to an event that my company or organization is sponsoring?
It depends on the type of event, the vendor, and the role of the employee.
Executive Order 10-16 prohibits vendors from offering gifts to City employees and officers. This includes:
- Invitations to events.
- Professional development opportunities.
This prohibition applies to vendors who:
- Have or are seeking business with the employee’s department within the 12 months preceding the date of the gift.
- Are regulated by the officer or employee’s department.
- Are seeking official action from that officer or employee.
Vendors who violate this Executive Order face debarment or other sanctions.
Sometimes, individuals or organizations sponsor events that they’d like a City official or employee to attend. Examples include a business conference or the opening of an art exhibit. This type of invitation might benefit the individual official or employee. But if it’s also in the City’s interest to have the official or employee attend the event, it may be a “Gift to the City” too.
In these instances:
- The City officer or employee must seek approval from their department/commission head. That leader will then decide if the invitee is the logical person to represent the City at the event.
- This approving official must explain why the City should send someone to the event, and why the invitee is the best City representative.
- Considerations will include, but are not limited to:
- Whether the number of invitees is appropriate.
- Whether there are unnecessary (or lavish) extras unrelated to the governmental purpose.
- Whether the officer or employee will speak at the event.
Contact the Office of the Chief Integrity Officer if you have any questions or invitations for review.
What should I do if a City official or employee, a City contractor, or someone else, is suggesting that I have to provide a political contribution or other benefit (gift, service, money, etc.) to do business with or get a service from the City?
Contact the Office of the Inspector General as soon as possible. Remaining anonymous is optional when reporting fraud, waste, abuse, or mismanagement of City funds.