CITY OF CHICAGO
GOVERNMENTAL ETHICS ORDINANCE
CHAPTER 2-156, MUNICIPAL CODE OF CHICAGO
(as amended, effective January 17, 2018*, February 19, 2018*, March 28,
2018*, March 13, 2019*, May 29, 2019*, September 28, 2019*, December
17, 2019*, January 1, 2020*, and April 14, 2020* )

Board of Ethics
740 N. Sedgwick, Suite 500
Chicago, IL 60654
312.744.9660

Lori Lightfoot, Mayor
William F. Conlon, Chair, Board of Ethics
www.cityofchicago.org/ethics
Steven I. Berlin, Executive Director
@ChicagoEthicsBd
Email: steve.berlin@cityofchicago.org
*Red text in red indicates amendments effective January 17, 2018
*Green text indicates amendments effective February 19, 2018
*Purple text indicates amendments effective March 28, 2018
*Brick text indicates amendments effective March 13, 2019
*Blue text indicates amendments effective May 29, 2019
*Violet text indicates amendments effective September 28, 2019
*Brown text indicates amendments effective December 17, 2019
*Teal text indicates amendments effective January 1, 2020
*Magenta text indicates amendments effective April 14, 2020

 (f)

The remedies set forth in paragraphs (c) and (d) of this section shall be the sole and
exclusive remedies for any violations of this section.

Part 2. Conflicts of Interest and Improper Influence.
2-156-020. Fiduciary duty. Officials and employees shall at all times in the performance of their public
duties owe a fiduciary duty to the city.
2-156-030. Improper influence.
(a)
No official or employee shall make, participate in making or in any way attempt to use his position
to influence any city governmental decision or action in which he knows or has reason to know
that he has any financial interest distinguishable from its effect on the public generally, or from
which he has derived any income or compensation during the preceding twelve months or from
which he reasonably expects to derive any income or compensation in the following twelve
months.
(b)

No elected official, or any person acting at the direction of such official, shall contact either orally
or in writing any other city official or employee with respect to any matter involving any person
with whom the elected official has any business relationship that creates a financial interest on the
part of the official, or the domestic partner or spouse of the official, or from whom or which he
has derived any income or compensation during the preceding twelve months or from whom or
which he reasonably expects to derive any income or compensation in the following twelve
months. In addition, no elected official may preside over or participate in any discussion in any
City Council Committee hearing, or participate in any discussion in any city council meeting or
vote on any matter involving the person with whom the elected official has any business
relationship that creates a financial interest on the part of the official, or the domestic partner or
spouse of the official, or from whom or which he has derived any income or compensation during
the preceding twelve months or from whom or which he reasonably expects to derive any income
or compensation in the following twelve months.

2-156-060. City-owned property. No official or employee shall engage in or permit the unauthorized use
of any real or personal property owned or leased by the City for City business.
2-156-070. Use or disclosure of confidential information.
(a)
Except as otherwise provided in subsection (b) or (c) of this section, no current or former official
or employee, including any current or former official or employee of the board or the inspector
general, shall use or disclose, other than in the performance of his official duties and
responsibilities, or as may be required by law, confidential information or any non-public
information, including the identity of the subject of an investigation, gained in the course of an
investigation or by reason of his position or employment.
(b)

If any person requests the opinion of the board of regarding past or ongoing conduct, and if the
board determines, pursuant to its rules, that the conduct involves a minor violation of this chapter,
the board may issue such person a letter of warning or admonition for the first such violation.
However, if the board determines, pursuant to its rules, that the conduct involves a violation of this
chapter which is not a minor violation or that the conduct involves a subsequent violation of the
same conduct for which the person has been issued a letter of warning or admonition, the board
shall advise such person to stop the conduct and inform the person of this subsection’s timeline for
self-reporting. Such person may, if the person wishes, self-report the violation to the inspector
general authority within 14 days. If the board finds that the person did not self-report the violation
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 within 14 days, the board shall provide the person’s name, the violation reported, and all related
information the board deems relevant, to the inspector general. Except for purposes of
investigations for subsequent violations of the same conduct, a letter of warning or admonition
issued to a subject pursuant to this section shall be kept confidential. This subsection applies to
conduct that occurred or is occurring on or after July 1, 2013.
(c)

Any person may use an advisory opinion issued by the board regarding such person’s future
conduct as evidence supporting the person’s position or as otherwise appropriate in any
investigation or disciplinary proceeding. Once the person uses the board’s opinion in accordance
with this subsection, the board, if requested in writing citing this subsection by the person or one
of the entities referred to in this subsection, shall disclose all confidential or non-public
information related to the advisory opinion that does not compromise a third party’s
confidentiality to the inspector general or any city department or agency conducting the
investigation or disciplinary proceeding.

2-156-080. Conflicts of interest; appearance of impropriety.
(a)
No official or employee shall make or participate in the making of any governmental decision with
respect to any matter in which he has any financial interest distinguishable from that of the general
public, or from which he has derived any income or compensation during the preceding twelve
months or from which he reasonably expects to derive any income or compensation in the
following twelve months.
(b)

(1)

With regard to any matter pending before the City Council or any City Council committee,
any member of the city council who has any financial interest that is either (1) distinguishable
from that of the general public or all aldermen, or (2) from which the member has derived
any income or compensation during the preceding twelve months or from which the member
reasonably expects to derive any income or compensation in the following twelve months
shall publicly disclose in detail the nature and extent of such interest, including when such
interest commenced, on the records of proceedings of the City Council, and City Council
Committee, and shall also notify, with the same detail, the Board of Ethics of such interest
within 96 hours of delivery by the Clerk to the member, of the introduction of any ordinance,
resolution, order or other matter in the city council, or as soon thereafter as the member is or
should be aware of such potential conflict of interest. If a disclosing member believes that
disclosure of any required detail is prohibited by applicable privacy law or a confidentiality
requirement, that member shall include a statement of the pertinent basis for non-disclosure,
and otherwise disclose fully. The Board of Ethics shall review any disclosure made under
this subsection and shall determine whether the member has provided sufficient detail
regarding the conflict of interests, and may request more detail if it deems that is necessary.
The Board of Ethics shall give the member one opportunity to correct the defect in the
disclosure within seven days from the date of such request. The Board of Ethics shall make
post such disclosures, including any additional detail submitted by the member, on the Board
of Ethics website, in a searchable format, available for public inspection and copying
immediately upon receipt. The member shall abstain from participating in any discussion
concerning and voting on the matter but shall be counted present for purposes of a
quorum. The obligation to report a potential conflict of interest under this subsection arises
as soon as the member of the City Council is or should be aware of such potential conflict.

(2)

To avoid even an appearance of impropriety, any member of the City Council who has any
business relationship with a person or entity with a matter pending before the City Council
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 or any City Council Committee: (i) that creates a financial interest on the part of such
member, or the domestic partner or spouse of such member, or (ii) from whom or which the
member has derived any income or compensation during the preceding twelve months or
from whom or which the member reasonably expects to derive any income or compensation
in the following twelve months, shall publicly disclose in detail the nature of such business
relationship or income or compensation, including when such relationship commenced, on
the records of proceedings of the City Council and the City Council Committee, and shall
also notify, with the same detail, the Board of Ethics of such relationship within 96 hours of
delivery by the Clerk to the member, of the introduction of any ordinance, resolution, order
or other matter in the city council, or as soon thereafter as the member is or should be aware
of such potential conflict of interest. If a disclosing member believes that disclosure of any
required detail is prohibited by applicable privacy law or a confidentiality requirement, that
member shall include a statement of the pertinent basis for non-disclosure, and otherwise
disclose fully. The Board of Ethics shall review any disclosure made under this subsection
and shall determine whether the member has provided sufficient detail regarding the conflict
of interests, and may request more detail if it deems that is necessary. The Board of Ethics
shall give the member one opportunity to correct the defect in the disclosure within seven
days from the date of such request. The Board of Ethics shall make post such disclosures,
including any additional detail submitted by the member, on the Board of Ethics website, in
a searchable format, available for public inspection and copying immediately upon
receipt. The member shall abstain from participating in any discussion concerning and
voting on the matter but shall be counted present for purposes of a quorum. The obligation
to report a potential conflict of interest under this subsection arises as soon as the member of
the city council is or should be aware of such potential conflict. For purposes of this
subsection (2) only: "matter pending before the City Council or any City Council Committee"
shall refer to City Council action involving the award of loan funds, grant funds or bond
proceeds, bond inducement ordinances, leases, land sales, zoning matters, the creation of tax
increment financing districts, concession agreements or the establishment of a Class 6(b)
Cook County property tax classification.

(c)

(3)

Any Chairman of a City Council Committee who makes, pursuant to subsection (b)(1) or
(b)(2) of this section, more than three conflict of interest disclosures within a 12-month
period pertaining to distinct matters before or reported by that Committee, shall eliminate the
conflict of interest or terminate the business relationship that caused such member to make
such disclosures, or resign from serving as the Chairman of the Committee.

(4)

Any member who fails to provide additional details regarding a disclosed conflict of interest
or business relationship if requested by the Board of Ethics, or who otherwise violates this
subsection, in addition to any other applicable penalty, shall be subject to a fine of not less
than $500 and not more than $2,000 for each offense. Each day that a violation continues
shall constitute a separate and distinct offense to which a separate fine shall apply.

Any official or employee who has a financial interest in any matter pending before any city agency
shall disclose the nature of such interest to the board of ethics and, if the matter is pending in his
own agency, to the head of the agency, except as provided by subsection (b). The obligation to
report under this subsection arises as soon as the official or employee is or should be aware of the
pendency of the matter. This subsection does not apply to applications for health, disability or
worker's compensation benefits.
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 2-156-090. Representation of other persons.
(a)
No elected official or employee may represent, or derive any income or compensation from the
representation of, any person other than the city in any formal or informal proceeding or transaction
before any city agency in which the agency's action or non-action is of a nonministerial nature;
provided that nothing in this subsection shall preclude any employee from performing the duties of
his employment, or any elected official from appearing without compensation before any city
agency on behalf of his constituents in the course of his duties as an elected official.
(b)

No elected official or employee may represent or derive any income, or compensation or other
tangible benefit from the representation of, any person, in any judicial, or quasi-judicial or other
proceeding before any administrative agency or court: (i) in which the cCity is an adverse party; or
(ii) that may result in an adverse effect on city revenue, city finances, or the health, safety, welfare
or relative tax burden of any city residents. and that person's interest is adverse to that of the city.

(c)

No elected official or employee may lobby the State, the County, or any other unit of local
government in the State, or derive any income or compensation from lobbying the State, the County,
or any other unit of local government in the State, on behalf of any person; provided that nothing
in this Section shall preclude (1) any employee from performing the duties of their employment,
(2) any elected official from appearing before any unit of government on behalf of the City, the
State, or the County within compensation or on behalf of their constituents in the course of their
duties as an elected official, (3) subject to the limitation of subsection (b) of this Section, an
employee or elected official who is an attorney from providing legal representation to any person
seeking judicial, quasi-judicial, administrative or legislative action, or (4) any elected official or
employee from engaging in political activity. For the purposes of this Section, “lobby” or
“lobbying” means, as applicable, any action that would require the person to register as a lobbyist
under the Illinois Lobbyist Registration Act, the Cook County Lobbyist Registration Ordinance, or
any applicable lobbyist registration ordinance adopted by a unit of local government in the State.

(cd)

No appointed official may represent any person in the circumstances described in subsection (a), or
(b), or (c) unless the matter is wholly unrelated to the official's city duties and responsibilities. (Prior
Code §26.2-9)

(de)

No official or employee may derive any income, compensation or other tangible benefit from
providing opinion evidence as an expert against the interests of the city in any judicial or quasijudicial proceeding before any administrative agency or court.

2-156-100. Post-employment restrictions on assistance and representation.
(a)
No former official or employee shall assist or represent any person other than the city in any
judicial or administrative proceeding involving the city or any of its agencies, if the official or
employee was counsel of record or participated personally and substantially in the proceeding
during his term of office or employment.
(b)

No former official or employee shall, for a period of one year after the termination of the
official's or employee's term of office or employment, assist or represent any person in any
business transaction involving the city or any of its agencies, if the official or employee
participated personally and substantially in the subject matter of the transaction during his term
of office or employment; provided, that if the official or employee exercised contract
management authority with respect to a contract this prohibition shall be permanent as to that
contract.
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 (c)

Nothing in this section shall be construed to restrict a former official’s or employee’s activities
on behalf of, and while employed by, another government agency.

2-156-105. Post-employment restrictions on lobbying.
(a-1) Starting on January 1, 2014, an alderman shall be prohibited from lobbying the City of Chicago or
any city department, board or other city agency for a period of one year after leaving that position.
(a)

Any person who serves as (i) a non-clerical employee of the Office of the Mayor, or (ii) a
department head, shall be prohibited from lobbying the City of Chicago or any city department,
board or other city agency for a period of two years after leaving that position.

(b)

Any employee who holds an exempt position in a city department, board or other city agency on or
after May 16, 2011, other than a person described in subsection (a) of this section, shall be
prohibited from lobbying the department, board or agency in which he or she was employed for a
period of two years after that employment ends.

(c)

Any person who is appointed by the mayor to the board of any board, commission, authority or
agency, on or after May 16, 2011, shall be prohibited from lobbying that board, commission,
authority or agency for a period of two years after the date on which his or her service on the board
ends.

(d)

The prohibitions on lobbying set forth in this section shall not apply to any person who (i) occupied
the position before May 16, 2011, and (ii) resigned from that position before November 16,
2011. Nothing in this section shall be construed to prohibit a person from lobbying on behalf of,
and while employed by, another government agency.

2-156-110. Interest in city business
(a)
Except with respect to the participation of Eligible Persons in Eligible Programs, no elected official
or employee shall have a financial interest in his own name or in the name of any other person in
any contract, work or business of the city, or in the sale of any article, whenever the expense, price
or consideration of the contract, work, business or sale is paid with funds belonging to or
administered by the city, or is authorized by ordinance; provided, however, for purposes of this
subsection, any of the following shall not constitute a financial interest in any contract, work or
business of the city:
(i) compensation for property taken pursuant to the city's eminent domain power; and
(ii) any interest of a relative which interest is related to or derived from the relative’s
independent occupation, business or profession.
(b)

Notwithstanding anything to the contrary in this section, no city official or employee who has
contract management authority over any contract, work or business of the city shall have a financial
interest in any entity which is a contractor, subcontractor, or otherwise a party to that contract, work
or business.

(c)

Unless sold pursuant to a process of competitive bidding following public notice, no elected official
or employee shall have a financial interest in the purchase of any property that: (i) belongs to the
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 city, or (ii) is sold for taxes or assessments, or (iii) is sold by virtue of legal process at the suit of
the city.
(d)

Except with respect to the participation of Eligible Persons in Eligible Programs, no appointed
official shall engage in a transaction described in this section unless the matter is wholly unrelated
to the official's city duties and responsibilities.

(e)

As used in this section, the terms “Eligible Persons” and “Eligible Programs” have the meanings
provided in Section 2-45-130 and shall be determined by the department of housing and economic
development.

2-156-111. Prohibited conduct.
(a)
No elected official or employee or the spouse or domestic partner of such official or employee, or
any entity in which such official or employee or his or her spouse or domestic partner has a financial
interest, shall apply for, solicit, accept or receive a loan of any amount from any lobbyist or person
who is either doing business or seeking to do business with the city; provided, however, that nothing
in this section prohibits application for, solicitation for, acceptance of or receipt of a loan from a
financial lending institution, if the loan is negotiated at arm's length and is made at a market rate in
the ordinary course of the lender's business. This subsection shall not apply to an entity in which
the only financial interest of the official or employee or his or her spouse or domestic partner is
related to the spouse's or domestic partner’s independent occupation, profession or employment.
(b)

No elected official, or the head of any city department or agency, shall retain or hire as a city
employee or city contractor any person with whom any elected city official has any business
relationship that creates a financial interest on the part of the official, or city department or agency
head, or the domestic partner or spouse of the official, or city department or agency head.

(c)

No city employee or official shall knowingly negotiate the possibility of future employment with
any person, except with a government agency, that has a matter currently pending before such
employee or official.

(d)

(1)

No city employee or official shall make or participate in the making of any governmental
decision for a period of two years from the date of employment or becoming a city
official, in a matter that benefits his or her immediate former employer or immediate
former client who the employee or official represented or on whose behalf he or she acted
as a consultant or lobbyist prior to commencing his or her city employment or prior to
becoming a city official, unless such employee or official has completely severed any ties
with that former employer or client that would confer, or have the potential to confer, a
monetary benefit on the employee or official. For purposes of this subsection, publicly
traded securities or income therefrom, and vested benefits in a retirement plan, shall not
be considered a monetary benefit.

(2)

No City employee of official shall personally participate in any capacity in a matter on
behalf of the City if the official or employee participated personally and substantially in
that matter for his or her immediate former business or immediate former employer or
immediate former client who the employee or official represented or on whose behalf he
or she acted as a consultant or lobbyist, prior to commencing his or her City employment
or prior to becoming a City official.
2-156-115. Time records for aldermanic staff.
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 Each alderman shall maintain a daily record of the attendance of his or her personal employees. The record
shall be certified as correct by the alderman or by any employee designated by the alderman. Records
required under this section shall be available for inspection in the offices of the respective aldermen in
accordance with the Illinois Freedom of Information Act, as amended.
2-156-120. Contract inducements.
No payment, gratuity or offer of employment shall be made in connection with any city contract, by or on
behalf of a subcontractor to the prime contractor or higher-tier subcontractor or any person associated
therewith, as an inducement for the award of a subcontract or order. This prohibition shall be set forth in
every city contract and solicitation therefor [sic] [thereof].
2-156-130. Employment of relatives or domestic partners.
(a)
No official or employee shall employ or advocate for employment, in any city agency in which said
official or employee serves or over which he exercises authority, supervision, or control, any person
(i) who is a relative or domestic partner of said official or employee, or (ii) in exchange for or in
consideration of the employment of any of said official's or employee's relatives or his domestic
partner by any other official or employee; provided that the prohibition in (i) applies to city council
committee staff and independent contractors who are paid from funds appropriated to the Alderman
for contractual services provided that those individuals who are relatives and are currently retained
as contractors shall be allowed to continue to renew their service contract on an ongoing and annual
basis; but not to personal staff of an alderman.
(b)

No official or employee shall exercise contract management authority where any relative or the
domestic partner of the official or employee is employed by or has contracts with persons doing
city work over which the city official or employee has or exercises contract management authority.

(c)

No official or employee shall use or permit the use of his position to assist any relative, or his
domestic partner in securing employment or contracts with persons over whom the employee or
official exercises contract management authority. The employment of or contracting with a relative
or domestic partner of such a city official or employee by such a person within six months prior to,
during the term of, or six months subsequent to the period of a city contract shall be evidence that
said employment or contract was obtained in violation of this chapter.

2-156-135. Prohibited political activities.
(a)
No employee shall intentionally perform any prohibited political activity during any compensated
time.
(b)

No official or employee shall intentionally misappropriate any city property or resources of the city
in connection with any prohibited political activity; provided, however, any official or employee
may reserve and rent a city-owned facility at a fair market value before any such activity or event
connected therewith.

(c)

No official or employee shall intentionally misappropriate the services of any officer or employee
by requiring any other official or employee to perform any prohibited political activity: (i) as part
of the other official’s or employee’s duties; (ii) as a condition of employment; or (iii) during any
compensated time off.

(d)

No official or employee shall be required at any time to participate in any prohibited political
activity in consideration of additional compensation or any other benefit, including a salary
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