Local Codes of Ethics
This page provides examples of ethics codes that have been adopted by cities, counties, and special purpose districts in Washington State, highlighting common ethics and conflict of interest concerns.
For information on state laws prohibiting certain conflicts of interest and unethical behavior, see our Ethics and Conflicts of Interest page.
While state law prohibits municipal officers from engaging in certain conflicts of interest and unethical behavior (see our page on Ethics and Conflicts of Interest), some local governments adopt their own ethics codes that include additional restrictions. These policies cannot conflict with state law, but they can supplement it. There are several good reasons to adopt a local ethics code:
- It allows the municipality to further explain what is covered by state law;
- It can cover employees as well as officers; and
- It can address ethical issues not covered by state law.
Sometimes these ethics codes are adopted as part of an employee handbook or policy, but often they are codified. Below are some of the most common topics addressed by local ethics codes as well as examples of different policy approaches for each. It is up to each jurisdiction to determine what topics—if any—should be addressed in its ethics code.
Nepotism provisions aim to keep family patronage out of local government. Examples of local nepotism code provisions are listed below. For more information, see our page on Nepotism.
- Bainbridge Island Code of Conduct and Ethics Program Article II (G) (2022) – Generally prohibits elected officials from hiring or appointing immediate family members for any type of city employment. However, the policy provides a waiver procedure.
- Chelan County Employee Handbook Sec. 1.20.210 – Well-organized, clear, and concise; includes a policy explanation for prohibiting nepotism.
- Port of Seattle Employee Code of Conduct CC-12 – Bars an employee from supervising, appointing, or disciplining a relative who is a port employee or consultant performing work for the port.
- Vancouver Employee Ethics Policies Sec. 504 (2008) – Applies to all eligible city employees unless otherwise addressed by a current collective bargaining agreement or public safety policy.
RCW 42.23.070(2) prohibits municipal officers from receiving gifts from a source other than their employer for a matter connected with or related to their public service. Several local government entities have chosen to go into more detail on the nuances of gifting. The examples below provide specific discussion on where to draw the line on gifts to public employees or officers.
- Clallam County Code Sec. 3.01.030(2) – Contains a provision that prohibits private individuals from offering, and public officials, employees, and candidates from accepting, anything of value based on an agreement that the public official, employee, or candidate would take official action in a certain manner.
- Lynnwood Municipal Code Sec. 2.94.050 – Very detailed acceptance of gifts section.
- Renton Municipal Code Sec. 1-6-4 – Standard and concise example.
Prohibited Contract Interests
RCW 42.23.030 generally prohibits a municipal officer from directly or indirectly receiving a financial benefit from a public contract. For more information, see our page on Ethics and Conflicts of Interest.
But deciding where to draw the line on interests in a public contract can be tough, so many local governments have supplemented state law with their own codes of ethics. Below are some examples.
- Cowlitz County PUD No. 1 Board of Commissioners Governance Policy Art. XIV Sec. 2(c) – Prohibits members of the governing body from having a financial interest in property that the district acquires as well as direct or indirect financial interests in an entity with which the district does business.
- Richland Municipal Code Sec. 2.26.060 – Primarily focuses on public disclosure of such interests.
- SeaTac Municipal Code Sec. 2.90.030(A)(2)-(3) – Includes sections on “remote interests” and “influence in contract selection.”
Misuse of Public Resources or Property
Misuse of public resources or property by employees or officers of a local government could implicate several provisions of state law, such as RCW 42.20.090 or the Washington State Constitution’s prohibition on gifts of public funds. Some local governments have chosen to provide further detail on this subject in their local ethics code.
- Grandview Municipal Code Sec. 2.90.030(A) – Provides a few examples of public officials and employees who are allowed to take city vehicles home after hours.
- Kirkland Municipal Code Sec. 3.14.030(c) – Generally prohibits city officials from using public resources not available to the general public, but allows for infrequent use that is at little or no cost to the city.
Misuse of Public Position
RCW 42.23.070 prohibits misuse of a municipal officer’s position to gain special privileges or exemptions for themselves or others. The codes below address improper influence or leveraging of a government position for personal gain.
- Lynnwood Municipal Code Sec. 2.94.030 – Provides a mechanism through which the mayor may adopt rules regarding the nature, scope, and extent to which city officials and employees may provide in-kind and other assistance to a particular activity or event.
- Pierce County Code Sec. 3.12.030(A) – Prohibits county "personnel" (defined broadly to include "any employee or elected or appointed official") from using their position, county resources, or other employees to secure any personal gain.
- Port of Seattle Employee Code of Conduct CC-01(III) – Detailed explanation of prohibited uses of a public position.
- Snoqualmie Municipal Code Sec. 2.80.030(B)(1) – Well-written and concise example.
Representation of Third Parties
Many local governments have limited their officers and employees from representing a private person in proceeding in which the local government is a party due to the conflicts of interest such behavior could raise. Below are some examples of codes that go into detail on this ethics issue.
- King County Code Sec. 3.04.030(D) – Detailed section on third party representation that is similar to what many local governments use.
- Tacoma Municipal Code Sec. 1.46.030(C) – Clear, concise, standard example that is similar to provisions adopted by other local government entities.
- Whatcom County Code Sec. 2.104.070(C) – Focused on representation by former county employees.
Disclosure of Confidential Information
RCW 42.23.070(4) prohibits municipal officers from disclosing confidential information gained by reason of their position, but doesn’t specify what information should be considered “confidential.” The code provisions listed below try to solve this issue by providing a clearer definition of what information is considered confidential.
- Concrete Municipal Code Sec. 2.56.050 – Provides an extended analysis of what information is “confidential” as well as a nonexclusive list of information that would be confidential.
- Kirkland Municipal Code Sec. 3.14.030(g) – Concise example, distinguishing between disclosing generalized information and specific confidential information.
- Lynnwood Municipal Code Sec. 2.94.070 – Very detailed example that specifies who can determine what information is confidential in different situations.
- San Juan County PHD No. 1 Board of Commissioners Code of Ethics Sec. V(K) – Generally prohibits commissioners from disclosing “confidential information,” defined as being information that is confidential pursuant to local, state, or federal law.
The Doctrine of Incompatible offices limits an individual from simultaneously holding two “public offices” that are incompatible with one another. While state statute is largely silent on this issue, courts and the Attorney General’s Office have weighed in on a number of situations. For more information, see our page on Incompatible Offices.
However, some local codes specifically address the extent to which officers or employees can simultaneously hold two or more public offices.
- East County Fire & Rescue Governing Rules and Ethics Policy 13.4.12 – Prohibits sitting fire commissioners from accepting appointment or election to a public office that is incompatible with the office of fire commissioner.
- King County Code Sec. 3.04.030(B)(9) – Concise example.
- Pierce County Charter Sec. 9.45 – Prohibits elected officials from holding any other elected office except political party precinct committee officer.
- SeaTac Municipal Code Sec. 2.90.030(A)(5) – Prohibits elected officials from simultaneously holding any other elected public office, regardless of whether the Doctrine of Incompatible Offices would apply. It also prohibits elected officials from engaging in employment or providing services for any interest that would be incompatible with the proper discharge of their official duties.
Private Employment or Outside Employment
When local government employees perform outside work, sometimes known as "moonlighting," some conflict of interest questions may arise. Some local governments have addressed this issue by adopting policies limiting private employment for public employees, as well as laying out procedures for disclosure of outside employment or interests.
- King County Code Sec. 3.04.030(B)(6)-(10) – Extensive discussion of the extent to which county employees may engage in private or outside employment while working for the county.
- Renton Municipal Code Sec. 1-6-6 – Good, basic model.
- Vancouver Employee Ethics Policies Sec. 502 (2008) – Allows employees to engage in paid outside employment, consulting work, or self-employment only if the work does not compete with or create a conflict of interest with the employee’s duties to the city. The policy then defines what it means to “compete” or create a “conflict of interest” with city employment.
Whistleblower protection policies assure government employees reporting ethics violations that the process will be handled equitably and there will not be repercussions. Chapter 42.41 RCW provides protection for whistleblowers, but some local governments have supplemented state law with more specific guidelines and definitions. For more information, see our page on Whistleblowing.
- Chelan County Employee Handbook Sec. 1.20.200 – Generally mirrors state law, but provides an alternative reporting procedure for district court employees.
- Cowlitz County PUD No. 1 Board of Commissioners Governance Policy Art. XIII Sec. 2(i) – Prohibits retaliatory actions against district employees or officials, including action taken as a result of whistleblowing.
- King County Code Ch. 3.42 – Very detailed and discusses the powers of officials investigating the reported misconduct, as well as the procedure for reporting improper governmental action.
- Vancouver Employee Ethics Policies Sec. 508 (2008) – Protects employees who make good faith reports of improper governmental action from “intimidation” or “retaliation.” The policy defines these terms and establishes a procedure for reporting and appealing.
Employment/Conduct after Leaving Office
Some local governments have adopted code provisions that address potential conflicts of interest related to public employees’ conduct after leaving public employment.
- Clallam County Code Sec. 3.01.030(7) – Standard policy example with moderate level of detail. Includes a provision allowing the Board of Commissioners, when requested, to make an exception if there is no real conflict.
- Edmonds Municipal Code Sec. 3.70.010 – Detailed section provides that a former official, officer, or employee generally may not receive compensation from an employer within a period of one year after leaving city employment if that employer has a contract with the city worth more than $10,000, and the former official, officer, or employee helped negotiate or administer the contract while employed by the city.
- Grant County PUD Code of Ethics Policy 3 – Post-employment representation policy bars employment that may require disclosure of confidential information, without prior commission approval.
- King County Code Sec. 3.04.035 – Very detailed provisions limiting the ability of former employees and former members of county boards, commissions, and committees from engaging in certain activities within one year of terminating service to the county.
- Tacoma Municipal Code Sec. 1.46.030(N)(3) – Includes a duty to inform the city manager when a current city officer wishes to contract with a former city officer or employee within one year of ending employment.
Appearance of Fairness
Chapter 42.36 RCW discusses the application and limitations of the Appearance of Fairness Doctrine, a rule extending due process protections to quasi-judicial decisions. For more information, see our page on the Appearance of Fairness Doctrine.
Local governments that wish to prioritize procedural fairness may supplement state law through their local ethics code.
- Grandview Municipal Code Sec. 2.90.030(B)(10)-(11) – Requires any employee whose participation in a discussion could violate the Appearance of Fairness Doctrine to excuse themselves from the discussion.
- San Juan County PHD No. 1 Board of Commissioners Code of Ethics Sec. V(B) and (C) – Requires commissioners to conduct their official duties objectively and without improper outside influence.
- Snohomish County Code Sec. 2.50.020 – Explicitly identifies some quasi-judicial hearings to which the Appearance of Fairness Doctrine applies.
Disclosure of Personal Investment Interests
In order to ensure transparency and equity, several local governments have policies requiring the regular disclosure of investments and real property interests of its officers. Here are some examples of such policies.
- Kirkland Municipal Code Sec. 3.14.040 – Requires that all city officials file an annual disclosure of investments, real property, income, and creditors.
- Lakehaven Water & Sewer District Code of Ethical Standards Sec. 5 – Requires disclosure of financial interests that might create a conflict, as well as a duty to report other members’ conflicting interests.
- Renton Municipal Code Sec. 1-6-7 – Requires every elected city official with a financial, private, or personal interest in any ordinance, resolution, contract, proceeding, or other action pending before the city council to disclose such interest.
- Richland Municipal Code Sec. 2.26.060 – Requires councilmembers with a financial, private, or personal interest in action pending before the city council to disclose the nature and extent of the interest. However, disclosure is not required if the councilmember disqualifies themselves from participating in any discussion and vote on the matter under consideration.
RCW 42.17A.555 sets the rules for use of public facilities during campaigns, but local governments can supplement state law regarding campaigning activities in order to avoid any conflicts of interest or inequality in campaigns.
- Grant County Personnel Policy Sec. 507.2.2 – Prohibits county employees that meet with or may be observed by the public from wearing political buttons or badges while performing their regular duties for the county. The policy also prohibits county employees from campaigning while on county time, in a county uniform, or while representing the county in any manner.
- Lynnwood Municipal Code Sec. 2.94.060 – Concise example.
- Pierce County Code Sec. 3.12.030(C) – Addresses political contributions, use of public facilities, and restrictions on mailings by elected or appointed officials.
- Port of Seattle Employee Code of Conduct CC-13 – Prohibits use of district facilities for campaign activities; also prohibits communications that might be construed as an official endorsement by the district.
Beneficial/Private Interest in Legislation
RCW 42.23.030 prohibits any private or beneficial interest in contracts, but many local governments have taken this a step further to prohibit employees or officers from having a personal interest in legislation. Below is an example.
- SeaTac Municipal Code Sec. 2.90.030(A)(6) – Prohibits elected officials from having a financial interest in any legislation coming before the council unless such interest is a remote interest.
When drafting a code of ethics, local governments should include procedures for enforcement of the code so that expectations are clear for public officers and employees. Here are some examples of how local governments have chosen to enforce their ethics codes.
- Cowlitz County PUD No. 1 Board of Commissioners Governance Policy Art. XVI – Detailed section covering authority to enforce, procedure for enforcing, and potential consequences for violations.
- Kirkland Municipal Code Sec. 3.14.060-.080 – Creates an ethics officer position to issue advisory opinions and receive, investigate, and resolve ethics complaints.
- Lynnwood Municipal Code Sec. 2.94.080 – Creates an appointed three-member board of ethics and also provides for the appointment of a “qualified individual or firm” as independent legal counsel to the ethics board, separate from the city attorney.
- Tacoma Municipal Code Sec. 1.46.045 – Very detailed example. Creates an appointed five-member board of ethics, requires an annual report from the board, sets out complaint processes and penalties, and allows for review by Pierce County Superior Court.
Examples of Local Codes of Ethics
Below are some sample codes of ethics from a variety of cities, counties, and special purpose districts, including all of the examples cited earlier on this page.
Cities/Towns under 10,000 Population
Cities of 10,000 to 50,000 Population
- Bainbridge Island Ethics Program (2022)
- Ferndale City Council Rules of Procedure and Ethics Handbook (2022)
- Grandview Municipal Code Ch. 2.90 – Applies to all elected and appointed officials and city employees
- Edmonds Municipal Code Ch. 3.70 – Conflicts of interest, including detailed section on conduct after leaving office
- Lynnwood Municipal Code Ch. 2.94
- SeaTac Municipal Code:
- Snoqualmie Municipal Code Ch. 2.80
- Tumwater Employee Code of Ethics and Whistleblower Policy (2011)
Cities over 50,000 Population
- Federal Way Code of Ethics (2020) – Applies to councilmembers, mayor, and employees
- Kirkland Municipal Code Ch. 3.14
- Renton Municipal Code Title 1, Ch. 6
- Richland Municipal Code Ch. 2.26
- Tacoma Municipal Code Ch. 1.46
- Yakima Code of Ethics for City Council Members (2009) – Brief, one-page document for councilmembers to sign
- Chelan County Employee Handbook – see Articles II and III
- Clallam County Code Ch. 3.01
- Grant County:
- Employee Handbook – Includes one-page code of ethics and also addresses other topics such as conflicts of interest, employment of relatives, and political activities
- Management Handbook and Code of Ethics (2002) – Applies to elected officials, department heads, managers, and supervisors
- King County Code Ch. 3.04 – Employee code of ethics
- Jefferson County Code of Ethics Policy and Procedures (2021) – Applies to all employees and “quasi employees”
- Pierce County Code Ch. 3.12
- Snohomish County Code Ch. 2.50
- Whatcom County Code Ch. 2.104
Special Purpose Districts
- Cowlitz County Public Utility District No. 1 Board of Commissioners Governance Policy (2015) – see Section XIII on Board Member Code of Conduct
- C-TRAN Board of Directors Code of Ethics (2020) – Applies to board members and includes a good section on Avoidance of Appearance of impropriety
- East County Fire & Rescue Board of Commissioners Governing Rules and Ethics Policy (2015)
- Grant County Public Utility District Code of Ethics (2014) – Applies to all commissioners, officers, and employees
- Lakehaven Water & Sewer District Code of Ethical Standards (2022) – Applies to commissioners and employees
- Port of Seattle Employee Code of Conduct (2018) – Includes sections on employees, former employees, and consultants
- San Juan Public Hospital District No. 1 Board of Commissioners Code of Ethics (2014)
- Washington State Municipal Attorneys Association: Public Law Ethics Primer (2010) – Ethics guide for municipal attorneys