6-Attachment 6-Conflict of Interest - Compliance Statement 7.23.25 - Code of Ethics.pdf
PDF 440 KB Posted
- Attached to
- 2026 Fleet Purchase State and local contract opportunity
- Solicitation number
- 2026-016
- Issued by
- Allegheny County, Philadelphia City, Pennsylvania
About this file
This is a Conflict of Interest Compliance Statement and Code of Ethics Policy document issued by Pittsburgh Water and Sewer Authority for the 2026 Fleet Purchase contract opportunity in Pennsylvania. The document establishes ethical standards and conflict of interest provisions that apply to all Directors, Employees, Agents, and Contractors engaged with Pittsburgh Water. Bidders and contractors must certify compliance with the Code of Ethics Policy and disclose any actual or perceived conflicts of interest prior to contract execution. The policy requires annual review and certification, with the Ethics Officer designated to oversee compliance, training, and investigation of ethical violations.
The Code of Ethics prohibits Directors, Employees, Agents, and Contractors from engaging in conduct that constitutes conflicts of interest, accepting improper influence or gifts from interested parties, entering into contracts valued at $500 or more without open and public procurement processes, misusing authority or property, and engaging in misconduct or dishonesty. Contractors and agents are required to complete a Conflict of Interest Statement disclosing all corporate affiliations, material financial interests, business dealings with Pittsburgh Water, proposed transactions, and any other relationships that could create conflicts. Violations are subject to suspension or termination of the contractual relationship. The Ethics Officer, Frank P. Sidari, III, and Chief People & Culture Officer, Logan Carmichael, serve as designated contacts for guidance and compliance inquiries. All disclosures and complaint procedures are maintained confidentially unless Pittsburgh Water Directors determine that an ethical violation has occurred.
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Text version
Conflict of Interest - Compliance Statement
I have reviewed Pittsburgh Water’s Code of Ethics Policy, which includes
Conflict of Interest provisions, on behalf of my company. I hereby certify that the Company will comply with the Code of Ethics Policy and has no actual or perceived conflicts of interest or disclosures. Any actual or perceived conflicts of interest disclosures will be submitted for review.
Print Name
Signature
Title
Company Name
Date
1ClarkHill\81663\417958\265192045.v1-12/23/21
Effective Date: ____1-1-2023_________
Approved By: _____________________
Revision No.: ________4____________
Revision Date: ___03-31-2025_________
PITTSBURGH WATER
CODE OF ETHICS
I. INTRODUCTION
Pittsburgh Water has established this Code of Ethics to ensure that Directors, Employees, Agents and Contractors of Pittsburgh Water act, and are understood to act, independently, impartially and responsibly, without conflict of interest, in the best interest of Pittsburgh Water, its customers, and residents of the City of Pittsburgh, and with no use of their position within Pittsburgh Water for personal gain. Further, this Code of Ethics is intended to preserve the public trust and to promote public confidence in the integrity of Pittsburgh Water’s operations, and to enhance Pittsburgh Water’s efficiency.
This Code of Ethics is in addition to, and shall not in any way limit, the obligations of Directors, Employees, Agents and Contractors of Pittsburgh Water as set forth in the Pennsylvania Public Officials and Employee Ethics Act (“Public Officials and Employee Ethics Act”), as the same may be amended, 65 Pa.C.S. §§ 1101-1113 et seq.;
The terms of the Public Official and Employee Ethics Act are incorporated herein by reference.
II. DEFINITIONS
“Agent.” All agents of or persons or entities that act in a fiduciary capacity for Pittsburgh Water in connection with Contracts supported in whole or in part by funds of Pittsburgh Water; for purposes hereof, this term includes subrecipients, subgrantees, subconsultants and/or subcontractors for the benefit of Pittsburgh Water Contracts. An agent may or may not also be a “Public Employee,” as that term is defined by the Public Officials and Employee Ethics Act.
“Pittsburgh Water.” The Pittsburgh Water and Sewer Authority.
“Pittsburgh Water Employee.” Any individual employed by Pittsburgh Water in any capacity. A
Pittsburgh Water Employee may or may not also be a “Public Employee,” as that term is defined by the Public Official and Employee Ethics Act.
“Business with which he or she is associated.” Any business in which the person or a member of the person’s immediate family is a Director, Officer, Owner, Employee, Contractor or has a financial interest in.
“Contract.” An agreement or arrangement for the acquisition, use, or disposal by Pittsburgh Water of services, whether professional or other services or work, or of supplies, materials, construction, equipment, land, or other personal or real property. The term does not include an agreement or arrangement between Pittsburgh Water and the Director, Public Employee, or other Pittsburgh Water Employee concerning salary or wage, benefits, or other matters in consideration of his or her employment.
“Contractor.” A person who enters into a contractual relationship with Pittsburgh Water to provide a service, whether professional or other services or work, supplies, materials, equipment, land, or other personal or real property, product or to perform construction in expectation of compensation or financial benefit.
“Covered Person” An individual who is considered to have a significant relationship with another party including if:
(a) the other party is a family member, including a spouse, parent, sibling, child, stepchild, grandparent, grandchild, great-grandchild, in-law, or domestic partner;
Docusign Envelope ID: 96A8E019-2F44-462C-A106-CD2782D5DCB9
(b) the other party is an entity in which the Covered Person has a material financial interest.
The determination of what constitutes a material financial interest includes entities in which the Covered Person and all individuals or entities having significant relationships with the Covered Person own, in the aggregate, more than 5%; or
(c) the Covered Person is an officer, director, or trustee involved with business decisions of another party.
(d) the Covered Person receives financial compensation from another party as an employee (financial compensation includes full-time, part-time, hourly, retainer, lump sum or any other type of payment for work conducted on behalf of another party).
“Covered Transaction” includes any transaction in which there may be an actual or perceived conflict of interest, including any transaction in which the interests of a Covered Person may be seen as benefiting the Covered Person or competing with the interests of Pittsburgh Water.
“De minimis economic impact.” An economic consequence having an insignificant effect.
“Director.” Any person appointed and/or serving on the governing body of Pittsburgh Water, without limitation to any member of Pittsburgh Water’s Board of Directors or other person appointed by the Mayor and/or City Council of the City of Pittsburgh to serve Pittsburgh Water, provided that the term shall not include members of advisory boards who have no authority to expend Pittsburgh Water funds other than for reimbursement of personal expense or to otherwise exercise the powers of Pittsburgh Water.
“Ethics Officer.” The person appointed to provide training and support on ethical issues for Directors, Public Employees, Pittsburgh Water Employees, Agents and/or Contractors.
“Financial interest.” Any financial interest in a legal entity engaged in business for profit that comprises more than 5% of the equity of the business or more than 5% of the assets of the economic interest in indebtedness.
“Honorarium.” Payment made in recognition of published works, appearances, speeches, and presentations that is not intended as consideration for the value of such services, which are nonpublic occupational or professional in nature. The term does not include tokens presented or provided that are of de minimis economic impact.
“Immediate family.” A parent, spouse child, brother, or sister.
“Influence.” The proposal of, the voting on or the participation in any discussion of or attempt to influence the course of any procurement decision of Pittsburgh Water; the participation in the selection, award or administration, other than of a ministerial nature, of any contract, benefit or award to which Pittsburgh Water is a party or which is supported by any public funds administered by Pittsburgh Water; participation in any manner involving, other than on a ministerial basis, the inspection, regulation or auditing of any entity by or as required by Pittsburgh Water.
“Ministerial action.” An action that a person performed in a prescribed manner in obedience to the mandate of legal authority, without regard to or the exercise of the person’s own judgment as to the desirability of the action being taken.
"Nominal Value." Monetary value not exceeding thirty-five dollars ($35.00) based on the expected retail price of the item, regardless of actual cost.
“Person.” A business, governmental body, individual, corporation, union, association, firm, partnership, committee, club or other organization or group of persons.
“Public Employee.” A Pittsburgh Water Employee or Agent who is responsible for taking or recommending official action of a non-ministerial nature with regard to:
(a) contracting and/or procurement;
(b) administering or monitoring Pittsburgh Water funds;
(c) regulating, auditing or inspecting any person;
(d) interpreting and applying Pittsburgh Water’s Rules and Regulations; and/or
(e) any other activity where the action has an economic impact of greater than a de minimis nature on the interests of Pittsburgh Water.
III. DISCLOSURE OF INTERESTS
(1) Each Covered Person shall deliver to the Ethics Officer, or the person designated by the Ethics Officer, a Statement of Financial Interests for the preceding calendar year in the form and manner as mandated under the Pennsylvania Public Officials and Employee Ethics Act and Pittsburgh Water’s Conflict of Interest Statement. The Statement of Financial Interests and Conflict and Interest Statement shall be completed and returned to the Ethics Officer, or the person designated by the Ethics Officer, by May 1 of each year.
(2) This Code applies to transactions between Pittsburgh Water and a Covered Person, or between Pittsburgh Water and another party with which a Covered Person has a significant relationship (each, a "Covered Transaction"). When a Covered Person becomes aware of a proposed Covered Transaction, they shall have the duty to take the following actions:
(a) immediately disclose the existence and circumstances of such Covered Transaction in writing, either to the Pittsburgh Water's Board or the Ethics Officer;
(b) refrain from using their personal influence to encourage Pittsburgh Water to enter into the
Covered Transaction; and
(c) recuse themselves from participation in any discussions regarding the Covered Transaction with Directors of Pittsburgh Water and Public Employees and at Board or Committee meetings except to respond to requests for information regarding the Covered Transaction.
In order to assist Pittsburgh Water in identifying potential Covered Transactions, each Covered Person shall update their Conflict of Interest Statement as necessary to reflect changes during the year. Completed Questionnaires shall be available for inspection by the Ethics Officer, Chief Legal Officer, or Chief Executive Officer.
(3) It is explicitly the responsibility of the Covered Person or the party with which a Covered Person has a significant relationship to disclose potential conflicts of interest prior to executing a transaction with Pittsburgh Water.
IV. STANDARD OF CONDUCT
All Directors, Pittsburgh Water Employees, Agents and Contractors shall dedicate themselves to the highest ideals of honor, honesty, compliance with the applicable laws and internal policies and procedures, and integrity in all public relationships in order to merit the respect and confidence of the public. All Directors, Pittsburgh Water Employees, Agents and Contractors shall serve the best interest of the public, at all times, and seek efficient and economical ways to accomplish necessary tasks and functions.
V. STANDARD FOR APPROVAL OF COVERED TRANSACTIONS
For conflicts involving Directors or Public Employees, the Chief Executive Officer, Ethics Officer, and Chief Legal Officer shall have the authority to determine whether a Covered Transaction is permissible.
The Chief Legal Officer shall document the basis for any determinations prior to entry into a Covered Transaction and maintain a record of the determination.
VI. COMPLIANCE
All Directors, Pittsburgh Water Employees, Agents and Contractors shall dedicate themselves to comply with Pittsburgh Water’s policies and any and all laws, regulations and permit requirements applicable to health, safety, security, water quality and environmental compliance.
VII. PROHIBITED ACTIVITIES
(1) Conflict of interest. No Director, Pittsburgh Water Employee, or Agent shall engage in conduct that constitutes a conflict of interest with Pittsburgh Water.
(a) A conflict of interest exists where a Director, Pittsburgh Water Employee, or Agent uses his or her office or employment, or any confidential information received because of his or her office or employment, for the private benefit of himself or herself, a member of his or her immediate family, or a business with which s/he or a member or his or her immediate family is associated.
(b) There is no conflict of interest where the Director’s, Pittsburgh Water Employee’s, or Agent’s action has a de minimis economic impact, or where the action has the same effect on the general public or some large segment of the general public of which the official, employee, agent or his or her family member is a part.
(2) Accepting improper influence. No Director, Pittsburgh Water Employee, or Agent shall solicit or accept anything of monetary value, including a gift or loan, reward or promise of future employment, based on any understanding that the vote, official action, or judgment of the Director, Pittsburgh Water Employee, or Agent would be influenced thereby.
(3) Gifts and favors. No Director, Pittsburgh Water Employee or Agent shall solicit or accept anything of value, including but not limited to gifts, paid admission to cultural or athletic events, gift cards, loans, rewards, promise of future employment, from an Interested Party, with the following exceptions:
(a) gift(s) from immediate family members;
(b) non-pecuniary award(s) publicly presented, in recognition of public service;
(c) an occasional non-pecuniary gift of nominal value;
(d) reasonable expenses for travel and accommodation for official purposes;
(e) admission to charitable, civic, political, professional organization, or other public events;
and/or
(f) complimentary meals and/or refreshments of nominal value, not to exceed four (4) times per year from the same individual or organization.
Note: Disclosure requirements under the Public Official and Employee Ethics Act are applicable for Pittsburgh Water Directors and Public Employees, including the reporting of gifts in aggregate of $250 or more and transportation, lodging, and hospitality expenses in aggregate of $650 or more per year.
(4) Honorarium. No Director, Pittsburgh Water Employee, or Agent shall accept an honorarium.
(5) Contract. No Director, Pittsburgh Water Employee or Agent, or his or her immediate family or any business in which the person or his immediate family is associated shall enter into any contract valued at $500 or more with Pittsburgh Water or any subcontract valued at $500 or more with any person or firm who has been awarded a contract with Pittsburgh Water, unless the contract has been awarded through an open and public process, including prior public notice and subsequent public disclosure of all proposals considered and contracts awarded.
(a) Should such a Contract be awarded after full disclosure and compliance with all statutes, regulations, and Pittsburgh Water policies, the Director, Pittsburgh Water Employee, or Agent shall have no supervisory or overall responsibility for the implementation or administration of the Contract.
(6) Voting or Approval conflict. Any Director, Pittsburgh Water Employee or Agent, who in the discharge of his or her official duties, would be required to vote on or approve a matter that presents a conflict of interest shall abstain from voting or approving. Prior to the vote being taken, the Director or Public Employee shall publicly announce and disclose the nature of his or her conflict of interest either by written memorandum filed with the person responsible for recording the minutes of the meeting or orally on the record at the public meeting at which the vote is taken.
(a) If the number of Directors required to abstain from voting are such that the required vote of approval is unattainable, then such Director(s) shall be permitted to vote if disclosures of the conflicts of interest are made.
(7) Misuse of authority and property. No Director, Pittsburgh Water Employee, or Agent shall:
(a) appear for compensation on behalf of any private person or entity, other than him- or herself or his or her immediate family, before any judicial or quasi-judicial tribunal.
(b) accept a fee for referring a matter to another person for action, when the Director or Pittsburgh Water Employee is barred by law, Pittsburgh Water’s rules and regulations or these policies from taking action directly;
(c) use or permit the use of his or her title or position in connection with any private business from which s/he receives compensation; and/or
(d) use or allow the use of any Pittsburgh Water property, facilities, staff or information obtained in the course of his or her position or employment for personal use other than would be generally available to the public at large.
(8) Misconduct and Dishonesty. All Directors, Pittsburgh Water Employees, Agents and
Contractors are prohibited from engaging in misconduct or dishonesty, which shall include, but is not limited to: violation of Pittsburgh Water’s Policies and Procedures or the Employee Code of Conduct; theft or other misappropriation of assets, including assets of Pittsburgh Water, its customers, suppliers or others with whom Pittsburgh Water has a business relationship;
misstatements; and/or other irregularities in Pittsburgh Water records, including the intentional misstatement of the test results or the results of operations, wrongdoing, forgery or other alteration of documents, fraud and other unlawful acts.
(9) Solicitation, political activity, and campaign contributions. Pittsburgh Water Employees and Agents are prohibited from engaging in political activity during working hours. Directors, Pittsburgh Water Employees, Agents and Contractors are prohibited from engaging in political activity at all times in Pittsburgh Water offices. Although not exhaustive of the political activity prohibitions applicable hereunder, Pittsburgh Water follows the prohibited activities set forth in 71 Pa.C.S.A. §2705(b). Nothing contained herein shall affect the rights of Directors, Pittsburgh Water Employees, Agents and Contractors to support a political party, to vote as they choose, to hold political office or to express publicly and privately their opinions on political subjects, to attend political meetings or to engage in other activities as provided in 71 Pa.C.S.A. §2705(c).
(10) Employment or appointment of relatives.
(a) No Director or Pittsburgh Water Employee shall appoint, hire, advance, or advocate the appointing, hiring, or advancing of a member of his or her immediate family to a position with Pittsburgh Water.
(b) No Director’s or Pittsburgh Water Employee’s immediate family member shall be appointed, hired, or advanced to a position under the direct supervision or control of the official or employee.
(c) The prohibitions of this Section 10 may be waived by Pittsburgh Water Directors, or their respective designee(s), upon a finding that the public interest would not be harmed in light of the appointee’s or applicant’s qualifications and the responsibility of the position.
(11) Post employment restrictions. For a period of twelve (12) months following termination of her or his position or employment with Pittsburgh Water, no Director or Public Employee shall represent (with or without compensation) a person or entity with respect to any matter with which he or she has been associated during the course of his or her service or employment with Pittsburgh Water.
VIII. ETHICS SANCTIONS
(1) Any Director who violates any provision of this Code of Ethics will be subject to removal, suspension or termination in accordance with the applicable law.
(2) Any Pittsburgh Water Employee who violates any provision of this Code of Ethics will be subject to discipline, up to and including termination of the relationship with Pittsburgh Water.
(3) Any Pittsburgh Water Agent or Contractor who violates any provision of this Code of Ethics will be subject to suspension or termination of the contractual relationship with Pittsburgh Water.
(4) Any effort made by or on behalf of an individual or entity to influence a Director, Pittsburgh Water
Employee, Contractor or Agent to breach the ethical standards of this Code of Ethics is prohibited and may be referred to the appropriate authorities for civil enforcement or criminal prosecution.
IX. ETHICS OFFICER
(1) Pittsburgh Water Directors, at their sole and absolute discretion, shall appoint an Ethics Officer, whose duties shall include:
(a) training, in conjunction with Pittsburgh Water’s Human Resources Department, of all new
Pittsburgh Water Employees on ethical issues including this Code of Ethics;
(b) administering compliance with preparation and submission of Statements of Financial
Interests required under the Pennsylvania Public Officials and Employee Ethics Law;
(c) Reviewing completed Conflict of Interest Questionnaires, receiving and reviewing disclosures of proposed Covered Transactions and making recommendations to the Chief Executive Officer and Chief Legal Officer on Covered Transactions;
(d) annual training of all Pittsburgh Water Employees on the prevention against criminal and/or unethical behavior and practice;
(e) coordinating and working with legal counsel for ethics opinions; and
(f) addressing ethics questions, concerns and investigations as provided in Part X below.
(2) Ethics training shall include in-person, webcast or similar training for each Director, Pittsburgh Water Employee, and Agent each year; and written notices of any changes in ethical requirements or other issues of broad concern.
X. COMPLAINT PROCEDURES
(1) Any Director, Pittsburgh Water Employee, Agent or Contractor may request an opinion from the
Ethics Officer on any of the matters set forth in this Code of Ethics. The Ethics Officer shall provide a written opinion to the requesting Director, Pittsburgh Water Employee, Agent or Contractor. The Ethics Officer may, acting within the Ethics Officer’s discretion, publish the opinion (without identifying the requesting individual) if such opinion would be of interest to Pittsburgh Water Directors, Pittsburgh Water Employees, Agents or Contractors.
(2) Any person may file a complaint regarding or request an investigation of, to the Ethics Officer, a violation or perceived violation of any of the policies contained in this Code of Ethics. Any person shall file a complaint regarding or request an investigation of, to the Ethics Officer, any conduct that a person considers or believes to be criminal in nature. The referring person must reasonably believe in the truth of the facts on which the claim is based.
Directors, Employees, Agents and Contractors shall refer to The Whistleblower Policy should they wish to file a complaint or request an investigation. The Whistleblower Policy is intended to cover serious concerns that could have a large impact on Pittsburgh Water, such as actions that include:
Ethical Violations Falsification of Reports and Records Improper Conduct Wrongful Environmental Discharge Violation of Company Policy Regulation or Permit Violations Misuse of Company Property Chemical Incidents Conflict of Interest Drinking Water Quality Fraud Unsafe Working Conditions Compliance Violations Improper Equipment Operation
Business and employment matters not relating to environmental compliance, safety, or ethics should be directed to a supervisor or Human Resources and are not addressed by The Whistleblower Policy. Environmental compliance, safety, or ethics reports not requiring anonymity may also be reported directly (in-person, phone, or email) to the Ethics Officer.
(3) The Ethics Officer shall acknowledge receipt of the complaint within ten (10) days of receipt. The
Ethics Officer shall have the authority to conduct interviews, take statements, receive and inspect documents and records and otherwise obtain evidence and gather information by lawful means, including subpoena power. The Ethics Officer shall have free and unrestricted access to all Pittsburgh Water records and premises, whether owned or rented.
(4) Within sixty (60) days of commencing an investigation, the Ethics Officer shall (a) terminate the investigation and notify the complainant and respondent, (b) extend the investigation for a period deemed appropriate by the Ethics Officer, or (c) issue a finding report that sets forth the pertinent facts and affords the respondent an opportunity to reply to the finding and to request a hearing.
All reports of or related to alleged ethical violations shall be in writing and shall be marked and maintained as confidential documents.
(5) After the Ethics Officer issues an opinion, a party has the right to appeal such opinion within ten
(10) days of such decision. The opinion of the Ethics Office shall be appealed to the Chief Executive Officer. The Chief Executive Officer shall review all information submitted and issue a decision. After the Chief Executive Officer issues a decision, a party has the right to appeal to the Directors, within ten (10) days of the decision of the Chief Executive Officer. The failure to appeal within the time limits set forth herein shall constitute a waiver of the right to appeal.
(6) If the Chief Executive Officer’s decision is appealed, the Directors shall appoint an individual to conduct a hearing, which shall be held within a reasonable period of time from the appeal. The hearing shall be conducted in a manner to protect the rights, privileges, processes and procedures of the parties. Other than the exchange of relevant documents and records, no discovery shall be permitted. The Directors’ appointee may establish such rules of conduct for the hearing as deemed advisable within the normal procedures for due process. After the hearing, the Director’s appointee shall issue a report and recommendation to the Directors identifying any findings, conclusions and recommendations. By a majority decision, the Directors shall approve, reject or modify the report and recommendation. A party has the right to file an appeal, within thirty (30) days of the Directors’ decision, to the Court of Common Pleas of Allegheny County, Pennsylvania, in accordance with applicable law.
(7) Any appeal taken outside of the time period set forth herein shall be deemed waived. Appeals must be in writing, must include a copy of the original complaint and the decision being appealed, and if the complaining person submits any additional facts, he or she must sign the writing under penalty of perjury.
(8) If the subject of the alleged ethical violation is the Ethics Officer, then the complaint shall be submitted to the Chief Executive Officer, and the decision of the Chief Executive Officer may be appealed to the Directors. If the subject of the alleged ethical violation is the Chief Executive Officer, then the complaint shall be submitted to Pittsburgh Water Chief Legal Officer, and the decision of Pittsburgh Water Chief Legal Officer may be appealed to Pittsburgh Water Directors.
Otherwise, all procedures set forth in the Section VI shall remain the same.
XI. PROTECTION FOR COMPLAINANTS AND OTHERS
(1) No Director, Pittsburgh Water Employee, Agent or Contractor may be penalized in any way for the good-faith filing of a complaint or for providing information in connection with a complaint.
(2) Pittsburgh Water has a No Discrimination/No Harassment/No Retaliation Policy that prohibits retaliation against any Director, Employee, Agent or Contractor. This includes any form of retaliation for making reports of known or suspected violations of: the Code of Ethics; internal policies or procedures; federal, state, or local laws, regulations, or permitting requirements; or otherwise raising an issue related to compliance, safety, or ethics.
(3) Ethical complaints shall be maintained in complete confidence unless and until Pittsburgh Water
Directors determine that an ethical violation has occurred, and then shall be published only as the Directors may direct. No person who is absolved of responsibility for an ethical violation, at any stage of the complaint process, shall be penalized in any way, nor shall the existence of the complaint be published or made known by any public official or public officer involved in its review.
XII. AT-WILL EMPLOYMENT
Nothing in this policy should be deemed to alter the “at-will” nature of employment with Pittsburgh Water.
This policy does not create a contract of employment, and employees may be terminated by Pittsburgh Water at any time, for any reason or no reason.
XIII. MISCELLANEOUS
This Code of Ethics shall be made available to Pittsburgh Water Directors, Employees, Agents, and Contractors.
To seek guidance in making proper decisions when faced with operational or ethical issues contact:
Frank P. Sidari, III, P.E., BCEE Chief Environmental Compliance & Ethics Officer 900 Freeport Road Pittsburgh, PA 15238 412-529-0217
Any questions concerning this policy should be directed to:
Logan Carmichael, PHR, SHRM-CP Chief People & Culture Officer 1200 Penn Avenue Pittsburgh, PA 15222
(412) 255-8800 x 6122 lcarmichael@pgh2o.com
Pittsburgh Water reserves the right to modify or amend this Code of Ethics at any time as it may deem necessary.
mailto:lcarmichael@pgh2o.com
CONFLICT OF INTEREST STATEMENT
Pittsburgh Water requires each Director and Public Employee annually or when any changes in status occur during the year:
(1) to review the Pittsburgh Water's Code of Ethics
(2) to disclose any possible personal, familial, or business relationship that reasonably could give rise to a conflict of interest or the appearance of a conflict of interest; and
(3) to acknowledge by his or her signature that he or she is acting in accordance with the letter and spirit of the Code of Ethics. The information provided on this form shall be available for inspection by members of the Board, Chief Executive Officer, Ethics Officer, and Chief Legal Officer, but shall otherwise be held in confidence except when, after consultation with the same it is determined that Pittsburgh Water's best interest would be served by disclosure.
CONFLICT OF INTEREST STATEMENT
1 Please list all corporations, partnerships, associations, or other organizations of which you are an officer, director, trustee, partner, or employee and describe your affiliation with such entity.
Click or tap here to enter text.
2 Please list all corporations, partnerships, or other entities in which you have a material financial interest as defined in the Policy.
3 Please list all business dealings that you, your family members, and/or entities listed in paragraphs 1-2 above have had with Pittsburgh Water in the past year.
4 Please list any proposed business dealings between Pittsburgh Water and you, your family members, and/or entities listed in paragraphs 1-2 above. Describe each such relationship listed and the actual and potential financial benefits as you can best estimate them.
5 Are you aware of any other relationships, arrangements, transactions, or matters that could create a conflict of interest or the appearance of conflict? If so, please describe.
By typing my name below and emailing this form to the Ethics Officer, I affirm that the foregoing information is true and correct to the best of my knowledge and that I have received and read Pittsburgh Water’s Code of Ethics. I am currently, and agree to remain, in compliance with the code.
Name: Click or tap here to enter text. Date: Click or tap to enter a date.
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