Ohio Police & Fire Pension Fund

Board Ethics Policy

Approved May 25, 2005

Policy Statement

It is the policy of this Ohio Police and Fire Pension Fund Board to carry out its mission in accordance with the strictest ethical guidelines and to ensure that Board Trustees and employees conduct themselves in a manner that fosters public confidence in the integrity of the Retirement System, its processes, and its accomplishments.

General Standards of Ethical Conduct

OP&F Board Trustees and employees must, at all times, abide by protections to the public embodied in Ohio's ethics laws, as found in Chapters 102.and 2921.of the Ohio Revised Code, and as interpreted by the Ohio Ethics Commission and Ohio courts. (A copy of these laws is provided by the Retirement System, and receipt acknowledged, as required in R.C. 102.09(D)). Board Trustees and employees must conduct themselves, at all times, in a manner that avoids favoritism, bias, and the appearance of impropriety.

A general summary of the restraints upon the conduct of all Board Trustees and employees includes, but is not limited to, those listed below. No Board Trustee or employee shall:

  • Solicit or accept anything of value from anyone doing business with the Board or System;
  • Solicit or accept employment from anyone doing business with the Board or System, unless the Board Trustee or employee completely withdraws from any Board and System discretionary or decision-making activity regarding the party offering employment, and the Board approves the withdrawal in the case of a Board Trustee or the Executive Director of the System, and the Executive Director approves the withdrawal in the case of another employee;
  • Use his or her public position to obtain benefits for the Board Trustee or employee, a family member, or anyone with whom the Board Trustee or employee has a business or employment relationship;
  • Be paid or accept any form of compensation for personal services rendered on a matter before, or sell goods or services to, the Board or System;
  • Be paid or accept any form of compensation for personal services rendered on a matter before, or sell (except by competitive bid) goods or services to, any state agency other than the Board or System, unless the Board Trustee or employee first discloses the services or sales and withdraws from matters before the Board or System that directly affect officials and employees of the other state agency, as directed in R. C. 102.04;
  • Hold or benefit from a contract with, authorized by, or approved by, the Board or System (the Ethics Law does except some limited stockholdings, and some contracts objectively shown as the lowest cost services, where all criteria under R.C. 2921.42 are met);
  • Vote, authorize, recommend, or in any other way use his or her position to secure approval of a Board or System contract (including employment or personal services) in which the Board Trustee or employee, a family member, or anyone with whom the Board Trustee or employee has a business or employment relationship, has an interest;
  • Solicit or accept honoraria (see R.C. 102.01(H) and 102.03(H)), except that employees who are not financial disclosure filers may receive an honorarium only if the honorarium is paid in recognition of a demonstrable business, professional, or esthetic interest of the employee that exists apart from public office or employment, and is not paid by any person or other entity, or by a representative or association of those persons or entities, doing business with the Board or System;
  • During public service, and for one year after leaving public service, represent any person, in any fashion, before any public agency, with respect to a matter in which the Board Trustee or employee personally participated while serving with the Board or System;
  • Use or disclose confidential information protected by law, unless appropriately authorized;
  • Use, or authorize the use of, his or her title, the name of the OP&F, or the OP&F logo in a manner that suggests impropriety, favoritism, or bias by the Board or System, or the Board Trustee or employee;
  • Solicit or accept any compensation, except as allowed by law, to perform his or her official duties or any act or service in his or her official capacity; and
  • No Board Trustee, state retirement system investment officer, or an employee of the OP&F whose position involves substantial and material exercise of discretion in the investment of retirement system funds shall solicit or accept from any person, including a partnership of which the System is a partner, payment of actual travel expenses, including expenses incurred with the travel for lodging, meals, food, and beverages.

In addition to complying with the restrictions in the Ethics Law and related statutes, no Board Trustee of the Ohio Police and Fire Pension Fund who is running for a position on the OP&F Board shall:

  • Solicit or accept campaign contributions, from any person or entity that the Board Trustee knows or has reason to know: (1) has a contract related to investment of the System's funds; (2) is marketing or otherwise attempting to secure business involving the System's funds; or (3) is an agent or acting on behalf of any person or entity described in (1) or (2). Campaign contributions include contributions made to a campaign committee, political party, legislative campaign fund, political action committee, or political contributing entity on behalf of the Board Trustee.

For purposes of this policy:

  • "Anything of value" includes anything of monetary value, including, but not limited to, money, loans, gifts, food or beverages, social event tickets and expenses, travel expenses, golf outings, consulting fees, compensation, or employment. "Value" means worth greater than de minimis or nominal.
  • "Anyone doing business with the Board or System" includes, but is not limited to, any person, corporation, or other party that is doing or seeking to business with, regulated by, or has interests before the Board or System, including anyone who is known or should be known to be an agent or acting on behalf of such a party, including any partnership of which the system is a partner, any person or entity that has a contract related to investment of the System's funds, and any person marketing or otherwise attempting to secure business involving the System's funds.

Financial Disclosure

Every Board Trustee or employee required to file a financial disclosure statement must file a complete and accurate statement with the Ethics Commission by April 15 of each year. Any Board Trustee or employee appointed, or employed to a filing position after February 15 and required to file a financial disclosure statement must file a statement within ninety days of appointment or employment.

Assistance

The Ethics Commission is available to provide advice and assistance regarding the application of the Ethics Laws and related statutes. The Commission can be contacted at (614) 466-7090. The Commission's web site address is: www.ethics.ohio.gov. Ohio Retirement System counsel are available to answer questions regarding this policy.

Penalties

Failure of any Board Trustee or employee to abide by this Ethics policy, or to comply with the Ethics Laws and related statutes, will result in discipline, which may include dismissal, as well as any potential civil or criminal sanctions under the law.

Evaluation and Changes

This policy shall be evaluated for effectiveness by the Board of the Ohio Police and Fire Pension Fund no less than biennially. The policy may be changed only by a majority vote of the Board, after approval by the Ethics Commission and review by the Ohio Retirement Study Council.

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