County ethics adviser reviews gift ban, conflicts and campaign rules in mandatory training

DuPage County’s ethics adviser, Dan Hanlon, led the board’s required annual ethics training during the Aug. 26 meeting and reviewed the ordinance’s key provisions, answer­ing members’ questions about gifts, travel, honoraria and conflicts of interest.

Hanlon summarized the ordinance’s gift rules: a prohibited source is generally any person or entity that does business with the county; permissible exceptions include close friends or relatives, educational travel authorized as job-related, and items with cumulative value below the calendar-year statutory threshold. He said the ordinance does not define value in every case and advised caution: when in doubt, decline or return the gift.

On political contributions and activity, Hanlon reviewed that campaign contributions may not be solicited or accepted on public property and noted the county also follows the Illinois Election Code limits (he cited current statutory contribution ceilings as informational). He explained that public employees and officials should avoid certain political activity during compensated time and that elected officials have a different treatment in the ordinance (they are not treated the same as hourly employees for on-duty restrictions).

Regarding conflicts of interest, Hanlon instructed members to notify him in writing when they suspect a conflict, so he may issue a written opinion. “If I determine a conflict exists, you must abstain from discussion and deliberation and may not vote on any contract with the person or entity involved in the conflict,” Hanlon said. He emphasized that his written opinions are protected by attorney-client privilege when members seek his guidance.

Hanlon also reviewed the ethics office structure: the investigator general (vacant at the time) evaluates complaints, may investigate and can present formal complaints to the ethics commission; the ethics commission may hold evidentiary hearings and impose fines up to $5,000. He noted that, historically, formal complaints have rarely advanced to hearings.

He ran through hypothetical scenarios about gifts (a covered example involved a green fee paid by a developer that would exceed the calendar-year gift threshold and should be refunded or remedied) and clarified travel and educational-expenditure exceptions may apply depending on whether the trip was county-approved and job-related. Members asked whether complimentary vendor invitations to conferences would be permissible; Hanlon said such invitations “could be” allowed when the travel is an educational expense related to the official’s duties and when approvals and other factors align.

The training closed with an invitation to contact the ethics adviser for written guidance on specific situations and a reminder that county officials must consider how actions would look if reported publicly.