Ethics Commission — Portland, ME
Date: 2026-02-24
Time: 17:30

ETHICS COMMISSION MEMBERS
 Carolyn Braun
 Peter Goldman
Tuesday, February 24, 2026 at 5:30 PM Jennifer Goodwin
Anita LaChance Conference Room 209, William Hayward
 Maria Maffucci
City Hall, 2nd Floor. Rosemary Paine
 Jennifer Wriggins




The Ethics Commission will conduct this meeting in person in The Anita LaChance Conference Room 209,
City Hall, 2nd Floor



PUBLIC COMMENT INFORMATION:
To submit written public comment on an agenda item, email ethics@portlandmaine.gov. Submissions must be
received by 12:00 pm the day before the Ethics Commission meeting to guarantee their inclusion in the agenda
packet. All submissions must include the commenter's name and legal address. To help ensure your comment is
submitted for the correct item, please include the name of the agenda item (see below).


AGENDA:

1. Call To Order

2. Roll Call

3. Approval of Minutes from Previous Meeting

 i. Ethics Commission Meeting Minute 1.27.2026
4. Unfinished Business

 i. Drafting Ethics Code
 a. Conflict of Interest Policy
 b. Conflict of Interest Outline
 c. Preamble
 d. Confidentiality Policy
5. Hour Mark-10 Minute Recess

6. New Business

 i. Update - Information from other Ethics Commissions
7. Next Meeting Date
 1
8. Adjourn




 2

ETHICS COMMISSION MEMBERS
 Carolyn Braun
 Peter Goldman
Tuesday, February 24, 2026 at 5:30 PM Jennifer Goodwin
Anita LaChance Conference Room 209, William Hayward
 Maria Maffucci
City Hall, 2nd Floor. Rosemary Paine
 Jennifer Wriggins




The Ethics Commission will conduct this meeting in person in The Anita LaChance Conference Room 209,
City Hall, 2nd Floor



PUBLIC COMMENT INFORMATION:
To submit written public comment on an agenda item, email ethics@portlandmaine.gov. Submissions must be
received by 12:00 pm the day before the Ethics Commission meeting to guarantee their inclusion in the agenda
packet. All submissions must include the commenter's name and legal address. To help ensure your comment is
submitted for the correct item, please include the name of the agenda item (see below).


AGENDA:

1. Call To Order

2. Roll Call

3. Approval of Minutes from Previous Meeting

 i. Ethics Commission Meeting Minute 1.27.2026
4. Unfinished Business

 i. Drafting Ethics Code
 a. Conflict of Interest Policy
 b. Conflict of Interest Outline
 c. Preamble
 d. Confidentiality Policy
5. Hour Mark-10 Minute Recess

6. New Business

 i. Update - Information from other Ethics Commissions
7. Next Meeting Date
 1

 Page 1
8. Adjourn




 2

 Page 2
ETHICS COMMISSION
Tuesday, January 27, 2026, at 5:30 PM
Anita LaChance Conference Room 209
City Hall, 2nd Floor.

MINUTES:

1. Call to Order 5:30 pm
 Peter Goldman

2. Members in Attendance:
 Carolyn Braun
 Peter Goldman
 Jennifer Goodwin
 William Hayward
 Maria Maffucci - Not present
 Rosemary Paine
 Jennifer Wriggins

 City Personnel:
 Rachel Millette (Associate Corporation Council), Abbey Lombard (Interim City Clerk)

 Members of the Public: none present

3. Approval of Minutes from 12/30/2025
 Motion to approve: Carolyn Braun
 Seconded: Rosemary Paine

 Discussion:
 Suggestion to add and upload the Preamble and Conflict-of-Interest Outline to the Ethics
 Commission Page on the City website

 Motion to amend Paragraph 3: change “has been uploaded” to “will be uploaded”
 Moved - Peter Goldman
 Seconded - Will Hayward
 Amendment approved by all members present
 Minutes approved by all members present

4. Executive session (moved from #7)
 Moved - Jenny Wriggins
 Seconded - Will Hayward
 Approved unanimously

 Motion to authorize Rachel Millette (Counsel) to respond to material submitted




 Page 3
 Moved - Will Hayward
 Seconded - Jenny Wriggins
 Approved unanimously

5. Hour Mark-10 Minute Recess
 No recess

6. Old Business
 I. Confidentiality Policy
 Discussion

 Action Items:
 Rachel will craft a Definition of “Confidential Information” to prevent
 conflicts with current City rules and regulations
 Rachel will research the draft definition of “Insider Information” to assure it
 presents no conflicts with current City rules and regulations
 Rachel will review the current draft definition of “Irreparable Harm” (1d) to
 assure it presents no conflicts with current City rules and regulations

 II. Conflict of Interest Policy
 Discussion

 Action Items:
 The draft of the overarching policy will be uploaded to the Ethics
 Commission Page on the City website
 Rachel will create the body of a draft Conflict of Interest policy based on
 Rose’s and Will’s December 30 outline and on the Commission’s
 recommendations during its discussion of the outline

7. New Business: Will briefly reviewed his discussions with members of other Ethics
Commissions both in and out-of-state.

 Action Item:
 Will will review his discussions with other Ethics Commissions (under Old
 Business next meeting)

8. Next Meeting: Feb 24, 2026 @ 5:30 in person

9. Adjourn
 Motion to adjourn: Carolyn Braun
 Seconded; William Hayward
 Approved unanimously
 Adjourned 7:35pm




 Page 4
 Chapter X CODE OF ETHICS



 ARTICLE I. IN GENERAL

Sec. X-1. Preamble.



Sec. X-2. Definitions.

 a. Confidential Information. The term "confidential information" shall mean any information,
 oral or written, which comes to the attention of, or is available to, a public servant only
 because of their position with the City and is not a matter of public record, including, but
 not limited to information received and discussed during an executive session pursuant Commented [1]: We can include more examples here
 to 1 M.R.S. § 405 et seq., information exempt from the definition of “public records” that might be applicable to various departments if you'd
 like.
 pursuant to 1 M.R.S. § 402(3), and information otherwise designated confidential by
 statute.

 b. Financial Interest. The term “financial interest” shall include any interest with a value
 equal or greater than $2,500 or 5% interest in a company, whichever is less.

 c. Public Servant. The term “public servant” shall include officials, officers and employees
 of the city, including elected and appointed officials, members of boards and
 committees, and volunteers, whether paid or unpaid.

 d. Relative. The term “relative” shall mean an individual’s spouse, domestic partner, parent,
 child, or person residing in the same household as the individual with whom the
 individual has a personal relationship.



 ARTICLE II. CONFLICT OF INTEREST



Sec. X-3. Financial Interests.

 A public servant shall disclose any financial interest that they or their relative has with
respect to a matter within the scope of the public servant’s duties. A public servant is expected Commented [2]: How do you want to handle issues
to disclose the financial interest immediately upon becoming aware of it to their supervisor or in that are broadly applicable? Like the overall City
 budget which might impact property tax rates or
a public meeting and to recuse themselves from participation related to that financial interest. A collective bargaining agreements? Do we specify in the
public servant must file a written disclosure of the financial interest to the City Clerk within five definition that a financial interest is something particular
 to the individual or their relative?
(5) business days of when they knew or reasonably should have become aware of the interest,
whichever is sooner. Commented [3]: Until further action can be taken? Or
 is this a complete ban on participating in these
 matters?




 Page 5
Sec. X-4. Gifts.

 A public servant shall not accept any gifts from a person or entity who has a contract, Commented [4]: Who should this section apply to? Do
license, or permit with the City or is seeking a contract, license, or permit from the City. A public we want to include volunteers?
servant shall not accept from any person or entity any gifts given in relation to the public
servant’s official duties with a total cumulative value of more than $50 in the course of a 12 Commented [5]: Added to avoid prohibiting gifts given
month period. for entirely personal reasons (birthdays, christmas,
 etc.)
Sec. X-5. Outside Employment.



Sec. X-6. Privileges or Special Treatment.



Sec. X-7. Post-Employment Restrictions.



Sec. X-8. Use of City Property and Resources.

 Except where otherwise available to the general public, a public servant shall not use
City facilities or equipment for outside employment. Commented [6]: Just employment, or other personal
 uses? Is there any exception for de minimis uses?
Sec. X-9. Political Activity.



Sec. X-10. Loans.



 ARTICLE III. CONFIDENTIALITY



Sec. X- Commented [7]: At least one code also makes
 mention of "advance" information - separate from
 confidential information, which seemed akin to the
 discussion we had about "insider information"




 Page 6
 Conflict-of-Interest Policy

City personnel shall avoid any conflict of interest. A conflict exists when their loyalties or
actions are divided between their interests and the interests of the City.

In addition, City personnel must avoid the appearance of a conflict of interest.




“Personnel” is defined in a footnote:

As used in this Policy the word “personnel” means any person who acts for or on behalf of the
City regardless whether they are paid or unpaid, elected or appointed or voluntary.




 Page 7
Ethic Commission Meeting, Dec. 30, 2025
CODE OF ETHICS
Conflict of Interest

• Financial

 No financial interest in decisions

 Disclosure of interests of individuals and relatives

 Lobbyist must disclose

 City officials must disclosure financial interests as soon as they are aware and no later
 than three (3) business days after discovering the conflict (agreed unanimously at
 meeting)

▪ Determine method of disclosure

▪ File Statement of Economic Interest

 Do we need to set a dollar amount that should be disclosed? Or any amount
 should be disclosed? $25.00 (agreed unanimously at meeting)

• Gifts

 Do not accept/solicit gifts

 Exceptions: less than $25.00 in value (agreed unanimously at meeting)

• Outside employment

 Cannot accept employment that interferes with public duty

▪ Creates COI that would impair ability to serve the city

 Cannot use city facilities or equipment for outside work

• Privileges or Special Treatment

 Cannot use position to solicit special privileges

• Post Employment Restrictions

 Cannot use information gained by city employment after employment

• City Property and resources




 Page 8
 Cannot use or destroy city property, fund resources

• Political Activity

 Cannot use city position to compel political activity, contribution or membership

• Loans

 Cannot apply for loan with business that is doing business with the city.




 Page 9
 City of Portland Maine
 Code of Ethics

Overview/Preamble


Portland’s government exists to serve the people. In order to do so effectively,
those who live or work in Portland must have confidence and trust in the
integrity of those in positions of service. The people of the City of Portland
deserve elected and appointed officials and city employees who maintain the
highest ethical principles, promote elevated standards of conduct, and avoid
conflicts of interest, real or perceived.


It is with this intent that the City of Portland Maine has created the following
Code of Ethics, predicated on the values of honesty, fairness, equitable
treatment and balancing the needs of the community with those of the
individual. Democracy depends on a government that is impartial, transparent,
and accountable to its constituents.


A code of ethics is a set of rules that outlines clear expectations for
organizational business practices and behaviors. Such codes are based on
values intended to guide the employees and elected or appointed officials and
to ensure that they conduct themselves with honesty and integrity. Municipal
codes of ethics strive to establish principles that reflect a city’s core values, and
define standards of conduct.


This Code of Ethics is designed to foster an honorable culture throughout
municipal governance. It sets clear, minimum expectations for performance
in the service of the City of Portland. Inherently, ethical standards may
require conditions more rigorous than city or state laws and statutes.




 Page 10
 DRAFT FOR DISCUSSION ONLY


 CITY OF PORTLAND, MAINE

 CONFIDENTIALITY POLICY



1. Confidential Information.
 a. Disclosure Prohibited. The unauthorized disclosure of the City’s
 Confidential Information or using Confidential Information for personal profit
 or advantage is prohibited.

 b. Definition of Confidential Information. “Confidential Information”
 shall mean

 TO BE SUPPLIED BY RACHEL MILLETTE


 and any documents or things marked “CONFIDENTIAL”.

 c. Non-fixed Media. Confidential Information can and often does exist
 in forms not fixed in any medium, such as conversations and discussions. To
 be clear, it is the content of the information, not its form, that determines
 whether the information is Confidential Information.


 d. Irreparable Harm. All City personnel acknowledge that the
 Confidential Information is the valuable property of the City. All City personnel
 further acknowledge that any disclosure or unauthorized use of the City’s
 Confidential Information will cause irreparable harm and loss to the City, or to the
 party entrusting the Confidential Information to the City, for which monetary
 damages would be inadequate compensation.

 e. Duty of Confidentiality. All City personnel understand and agree that
 by executing this Confidentiality Policy they are entering into a special relationship
 with the City imposing a duty of confidentiality upon them.




 DRAFT FOR DISCUSSION ONLY
 PORTLAND
 Confidentiality Policy
 Page 1 of 2



 Page 11
 DRAFT FOR DISCUSSION ONLY




2. Insider Information.

RACHEL MILLETTE WILL VET THIS PROVISION TO ASSURE ITS
APPLICABILITY


“Insider Information” is a form of Confidential Information. Insider Information
is non-public information which comes to City personnel during their employment
or during the course of their association with the City. City personnel shall not use
any Insider Information, or reveal it to others who may use it, in connection with
business transactions related to the City or contemplated by the City. This applies
not only to non-public information relating to the City, but also to non-public
information relating to third parties such as individuals or businesses.




 DRAFT FOR DISCUSSION ONLY
 PORTLAND
 Confidentiality Policy
 Page 2 of 2



 Page 12