Greenburgh Board of Ethics Internal Rules and Regulations
Town of Greenburgh, NY Board of Ethics
Internal Rules and Regulations
These rules and regulations are intended to provide for the efficient working of the Board of Ethics (BOE).
1. Quorum. A quorum shall be three voting members of the BOE.
2. Action. An affirmative vote of three members shall be required to approve any action except as otherwise provided herein. Actions may be taken between meetings by the Chair, upon such consultation with members as she/he deems appropriate under the circumstances, on scheduling and procedural matters and on requests under the Freedom of Information Law. All such actions regarding scheduling and procedural matters shall be stated at the next meeting of the BOE.
3. Rules of Order. For procedures not covered herein, Robert’s Rule of Order for Small Organizations shall govern.
a. Frequency. The Board of Ethics shall hold meetings at least monthly if specific business is pending. However, it is not required to schedule meetings in the months of August and December but may do so by a vote of a majority of the members. The Board of Ethics shall hold at least two meetings per year.
b. Duration. Meetings shall be scheduled to last two hours. The duration of a specific meeting may be extended by a majority vote of the members present.
c. Time. Meetings may be scheduled in the afternoon or evening. At least one meeting per year shall be held in the evening.
d. Location. Meetings shall be held at either Town Hall or at the Multipurpose Center at AFV Park.
e. Scheduling. The next meeting shall be scheduled at the end of each meeting. If it is necessary to schedule a meeting prior to the next scheduled meeting, such meeting may be called by the Chair or by any two members acting in concert. If it is necessary to reschedule a meeting by reason of inclement weather, unavailability of the meeting site, request of one or more Board members, lack of a quorum or in the interests of the general public the Chair or acting Chair may cancel or adjourn the meeting unless two other members of the BOE decide the meeting should be held at the previously schedule date and time.
f. Announcement. The date, time, location and proposed agenda of a meeting shall be posted on the Town Website at least 4 days prior to the meeting. If a meeting is scheduled not more than one week in advance, the date, time, location and proposed agenda shall be posted on the Town website as soon as practical.
g. Minutes. Unless otherwise required by law, within two weeks after a meeting is held, the Secretary of the Board of Ethics shall post approved minutes on the Town Website. If any corrections are required in the posted minutes, they will be noted in the minutes of the next meeting. If substantial changes are made, corrected minutes will be reposted on the Town Website.
h. Presiding Officer. The Chairman shall preside over meetings. If the Chairman is absent, the members shall choose one of their members present to serve as acting chairman for the duration of the meeting.
i. Agenda. The Chairman shall develop a proposed agenda for each meeting. Among the items that the Chairman shall consider in developing the proposed agenda shall be agenda items agreed to at the previous meeting, items proposed by members of the Board of Ethics, and new business concerning matters raised with or referred to the Board of Ethics since the previous meeting. One of the first items of business at each meeting shall be the acceptance or modification of the proposed agenda.
j. Public Participation. The public may and is encouraged to attend open meetings of the Board of Ethics. The public does not attend when the BOE convenes in Executive Session. At open meetings, allowing the public to speak is within the discretion of the BOE. However, it is the intent of the BOE, subject to reasonable rules as it may impose, to allow the public to speak. A public comment period may be scheduled on the agenda. Public comment is subject to the necessary rule of avoiding excessive repetition, obstructionism or personal attacks. The Chairman or a majority of the members present may rule that a speaker is out-of order.
5. Handling requests for determinations concerning alleged violations of the Code of Ethics (RRVs). The Board of Ethics is authorized to receive requests regarding alleged violations of the Code of Ethics (COE) from four sources: the Town Board; Public Officials of the Town; Town residents, property owners, or lessees (hereafter this entire class will be referred to simply as “residents”); and the BOE itself. (570-11). In all phases of its investigations of RRVs from any of these sources, the BOE has an affirmative fact-finding duty.
a. A written RRV by Town Board will be handled in accordance with the following procedures:
1. The BOE recommends, but does not require, use of the RRV form, which is available from the Town Clerk or on the Town website.
2. The BOE must investigate all RRVs “presented by the Town Board.” (570-11-D). The BOE interprets this to mean a formal RRV supported by a majority of the Town Board and submitted to the BOE as an official action of the Town Board.
3. Initial Determination of Good Cause to Proceed is bypassed in handling RRVs from the Town Board (570-11-E). RRVs from this source go directly to Phase 1 Investigation.
b. A written RRV by a Public Officer will be handled in accordance with the following procedures:
1. The BOE recommends, but does not require, use of RRV Form which is available from the Town Clerk or on the Town website.
2. RRVs lodged by one or more individual members of the Town Board (but less than a majority) are subject to an Initial Determination of Good Cause to Proceed. When an elected Town official is the subject of an alleged ethics violation, and the RRV is brought by one or more individual members of the Town Board acting as individuals, the BOE of ethics will require that the individual(s) making the request submit a verified RRV, as provided for in the case of Town residents. (570-11-D-3).
3. Notification. The BOE will notify the Town Board when a request from a Town official is received by the BOE. The BOE requests that the Town Clerk will provide the Town Board with a copy (written or electronic) of the RRV or verified resident complaint.
c. A written RRV by a Town resident (i.e. a “complaint”) will be handled in accordance with the following procedures:
1. Residents may submit a verified complaint with respect to violations of the Greenburgh Town Code of Ethics or Article 18 of New York State Municipal Law. Verified complaints are to be filed with the Town Clerk.
(i.) Residents filing a complaint shall use either the Code of Ethics Citizen Complaint Form, which is available from the Town Clerk and on the Town website, or an equivalent written document that contains at least the information specified in the Citizen Complaint Form.
(ii) Filers should specify in the verified complaint the section(s) of the Code of Ethics they assert has been violated and a brief statement as to why the section(s) was violated by the facts described in the verified complaint. Although the Board of Ethics may, in its discretion, consider other sections, it is under no obligation to consider violations of sections not specified in the verified complaint.
2. The BOE requests that the Town Clerk should determine that the resident complaint has been properly sworn and submitted in accordance with the COE (“verified”) and should forward to the BOE only those resident complaints that are properly verified. If the Town Clerk finds that a complaint is not properly verified, the Town Clerk should return the complaint to the resident who submitted it.
3. When the BOE receives a verified complaint from the Town Clerk, the BOE may make its own determination concerning whether or not a resident complaint is sufficiently clear and complete to proceed. Incomplete, unclear or inadequately documented resident complaint may be returned or dismissed at BOE discretion. (570-11-D.3; 570-11-C).
4. Notification. The BOE will notify the Town Board when a verified complaint from a resident is received by the BOE. The BOE requests that the Town Clerk will provide the Town Board with a copy (written or electronic) of the RRV or verified resident complaint.
d. BOE initiated investigations will be handled in accordance with the following procedures:
1. To initiate such investigations requires a majority vote of the BOE.
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2. In general the BOE will exercise this statutory function with restraint.
3. The BOE may draw upon this authority to extend the scope of a request made by another party (or initiate a separate investigation) if necessary to ensure that a questionable practice is fully investigated.
4. Notification. The BOE will notify the Town Board when it initiates an investigation and will notify those parties who come within the purview of such an investigation.
e. Other procedures pertaining to the receipt of RRVs include:
1. BOE will notify the person(s) named in an RRV received by the BOE. The BOE requests that the Town Clerk will provide that person(s) with a print or electronic copy of the RRV in question.
2. In recognition of the need to properly address issues bought to the BOE, particularly if a member of the Town Board is the subject of an inquiry, and depending on the scope and complexity of a given RRV, the BOE may request the Town Board to provide it with outside counsel recommended by it pursuant to General Municipal Law 808.
3. The Board of Ethics will use its best efforts to avoid interference with criminal investigations and will refrain from acting while a criminal investigation known to it is pending.
f. Any procedural request such as a request for a stay, adjournment of a meeting or hearing, extension of time to submit papers requested by the Board (excluding the phase 1 information requests) made by the parties or their counsel in a pending Ethics investigation, shall make such request either by email or correspondence on notice to the opposing party at least eight days before the next scheduled meeting of the BOE. The opposing party shall have four days to respond to the request upon notice to all parties by email or by delivery of a written response to the Town Clerk on or before the fifth day. Failure to make a request upon proper notice to all parties shall be grounds for denial of the request. The BOE upon a failure by a party to respond to a request upon proper notice or in a timely manner may act upon the request without consideration of the response. The Chair upon review of the submissions shall after consultation with the Board and upon approval by a majority of the Board may act on the request. Any request addressed and acted upon shall be noted at the next scheduled meeting and the Board’s actions regarding the request will be made a part of the minutes.
! 4. Any request made by or on behalf of a complainant or respondent to a complaint for action by the BOE shall be made by email to all Board of Ethics members and counsel, and the requesting party shall concurrently copy all other complainants and respondents on the email request.
6. Conducting investigations of RRVs. Once a determination has been made that a RRV has been properly filed in accordance with the COE and BOE policies, there are three aspects of the BOE investigation process: (a) Preliminary determination on the RRV to either dismiss or proceed; (b) Phase 1 investigation of charges and evidence; and (c) Phase 2 investigation of charges and evidence (570-11-I; 570-11-J). In conducting investigations, the BOE is guided by the principle that a person accused of a violation is presumed to be innocent until proven guilty of the violation. (570-11-I; 570-11-J; 570-11-C; 570-11-E; 570-11-J; 570-12).
a. The BOE will make a preliminary determination on RRVs in accordance with the following procedures:
1. As soon as possible after it has received a properly verified and appropriately clear and complete RRV, the BOE will review the RRV to see if there is good cause to proceed.
2. In making a Determination of Good Cause to Proceed, the factors that the BOE will consider include, but are not limited to:
(i.) a determination that the complaining party has standing
(ii.) a determination that the RRV does implicate one or more sections of the COE in force when the alleged violation(s) occurred
(iii.) a determination that the RRV arises out of the same or substantially the same operative facts that result in a finding of no violation as in a previous complaint, or a determination that the RRV is covered by a conclusion or interpretation of the Code of Ethics in a previous opinion of the Board of Ethics; or
(iv.) a determination that the evidence provided has potential relevance, or warrants further investigation; or there is reasonable cause to believe that potentially relevant evidence will be forthcoming upon further investigation.
3. If there is not good cause to proceed, the BOE will issue an opinion to that effect and will send the opinion to the interested parties and will file it with the Town Board and the Town Clerk, it will be placed it on the Town Website or, instead of issuing an opinion, by noting in the minutes of the meeting the determination that there is not good cause to proceed.
4. If there is good cause to proceed, the BOE will notify the affected parties that it will take the RRV under investigation. The affected parties include, but are not necessarily limited to, the Town Board, the complaining party, and the party being complained against.
b. Under its authority to make its own operating rules and procedures, the BOE distinguishes between an initial (Phase 1) investigation and a more elaborate (Phase 2) investigation, including a public hearing. The BOE will conduct investigations in accordance with the following procedures:
1. During a Phase 1 investigation the BOE may:
(i.) Request and review additional documentary evidence, and/or interview parties who can provide evidence pertinent to the RRV.
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(ii.) Ask the party complained against to submit a written response or explanation of the conduct in question.
(iii.) Conduct interviews and other fact finding activities.
2. The BOE may conduct at least a portion of its deliberations during Phase 1 investigations, and its meetings with counsel to discuss the investigation, in executive session, in so far as this is permitted and consistent with New York State Open Meetings Law.
3. At the conclusion of this process, the BOE may be able to come to an opinion, or it may decide to move on to conduct a Phase 2 investigation before coming to an opinion.
(i.) In a given case, the Phase 1 investigation may suffice to allow the BOE to reach an opinion of no violation.
(ii.) However, the BOE will not reach an opinion that a violation has been committed without first affording the person(s) accused of the violation the opportunity to take part in a formal BOE hearing and without completing a Phase 2 investigation.
4. The fact that the BOE may decide to move to the Phase 2 investigation stage on a given RRV is without prejudice; it does not indicate how the BOE may eventually rule and in no way limits the conclusions of the BOE once the investigation is complete. The BOE will conduct Phase 2 investigations (i.e. holding formal hearings or similar proceedings for the purposes of taking testimony and allowing cross-examination, and of allowing the complaining party and the party complained against to present their cases) in accordance with the following procedures:
(i). The BOE may call witnesses and, if it does so, they must be sworn. If witnesses are called, the party complained against has the right to cross-examine them (see rule 6(b) (8) (iv.) below).
(ii). The BOE must, with the advice of counsel, conduct such investigational activities and hearings as it deems appropriate, once the Phase 2 investigation stage has been reached.
(iii). The principal parties have a right to appear before the BOE and a right to be represented by counsel. They may submit written materials and responses (both those requested by the BOE and those undertaken at their own initiative), as well as verbal testimony.
(iv.) The party complained against has the right to submit written responses, to cross examine witnesses, and to challenge documentary evidence.
(v.) The BOE has the authority to call witnesses and to determine which witnesses (other than the principal parties) will be heard at its hearings or proceedings. The parties to the RRV do not have independent authority to call or to determine witnesses, although they may recommend potential witness for the BOE’s consideration. It is the policy of the BOE that it will generally call witnesses requested by the parties.
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(vi.) At the beginning of a formal hearing the BOE will set forth and explain the specific rules of proceeding that will govern the hearing.
(vii). The BOE will control and lead the interrogation of witnesses. The party complained against (or his or her counsel) will have the right to cross-examine witnesses after the BOE has asked its initial questions.
(viii.) The COE does not grant the complaining party (or his or her counsel) the privilege of cross-examining witnesses. However, the BOE will permit such questioning to the extent that it promotes the fact-finding function of the hearing.
(ix.) The COE provides that a Phase 2 investigation shall be conducted with advice of counsel. If the BOE is not provided with appropriate independent counsel, the BOE has the option to discontinue its investigation and to issue a conclusion of “no finding” and the reason therefor.
(x.) Phase 2 investigatory hearings will be held in open meetings. Stenographers will be provided for and a written transcript will be prepared.
(xi.) In cases in which hearings are convened, the BOE will not issue any determination or opinion on a RRV until the hearing transcript has been reviewed.
(xii.) There will be no period for public comment at the meeting at which a hearing is conducted. Public comment on the hearing and the matter of the RRV will be permitted at the next BOE meeting following the hearing (570-11-I; 570-11-J).
7. Opinions. The COE provides that the BOE shall submit to the Town Board
a. The BOE will issue opinions in accordance with the following procedures:
1. An opinion may be issued (i) after the initial Determination of Good Cause to proceed, if good cause is not found; or (ii) after a Phase 1 investigation, if no violation is found; or (iii) after a Phase 2 investigation is complete.
2. BOE opinions will be guided by the standard of “preponderance of the evidence.” This standard requires that the BOE find that it is “more probable” that the person(s) accused did commit the alleged violation of the COE than that he or she did not.
3. After review and comment by the members of the BOE, the text of the BOE opinion will be finalized and approved by the BOE.
4. Any member of the BOE shall have the right to file a separate concurring or dissenting statement in writing, which will be included as an appendix in the document submitted by the BOE.
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5. Promptly after BOE approval of the final written opinion and the preparation of concurring or dissenting statements, the BOE opinion will be transmitted to the Town Board, Town Clerk, the parties to the RRV or complaint, and the Town website. (570-11-F.)
8. Publicity. For each RRV and BOE opinion, the BOE may designate one member to serve as the official spokesperson for the BOE. Press inquiries will be directed to that BOE member.
a. Other members of the BOE may give statements to the press or be interviewed by reporters, but should defer to the designated BOE spokesperson whenever possible.
b. Members of the BOE will keep executive session proceedings confidential and will limit their commentary and analysis to evidence and opinion that are on the public record.
9. Handling requests for Advisory Opinions. The BOE is authorized to receive and respond to requests for advisory opinions from elected, appointed, and professional town officials concerning conduct covered by the COE (570-11-D).
a. Requests for advisory opinions should be made in writing directly to the Chair of the BOE, with a copy of all BOE members; they need not use a specified form or be sworn and filed with the Town Clerk.
1. Upon receipt of a request for an advisory opinion from one entitled to make such arequest, the BOE shall promptly acknowledge receipt thereof and notify the requesting official that the BOE’s administration of the request and issuance of an opinion will generally be covered by Rule 9.
2. The BOE shall ask that the requesting official notify the BOE in writing if she/he wishes that her/his name (or the name of another person. Such as a relative, a subordinate working for the Town or other town employee, or an agency member) be kept confidential and shall note that, by the nature of the question posed or the position of the official or other individual involved, such confidentiality (if requested) may not be possible and that the requesting official may in writing withdraw the request if she/he is concerned about confidentiality.
3. The BOE may also ask the official for clarification of the request before it begins its deliberations.
c. Officials requesting advisory opinions should understand that the final opinion rendered by the BOE will be shared with the Town Board and Town Clerk. and posted on the Town website.
d. Officials requesting advisory opinions should understand that the BOE reserves the discretion to determine the scope of its investigation preparatory to preparing an advisory opinion; it will focus on the issue(s) or COE provisions that the official specifies in his or her request, but it may also take up other related issues or provisions as the circumstances warrant (570-H).
e. Officials requesting advisory opinions should understand that requesting and receiving an advisory opinion from the BOE does not preclude the filing of a complaint concerning the same issues and does not preclude a subsequent opinion by the BOE on that complaint. Additional information may come to light that could lead the BOE to change its position in an advisory opinion when issuing a later opinion.
f. Investigations related to advisory opinions will be conducted by the BOE in accordance with the following procedures:
1. If the request is for an advisory opinion that concerns proposed future conduct by the official, the background and circumstances relevant to that conduct will be provided by the official without additional independent investigation by the BOE. In this case the BOE will make clear that its opinion is contingent upon the accuracy and completeness of the information supplied by the requesting official.
2. If the request is for an advisory opinion that concerns conduct that has already taken place, or is ongoing, the investigatory process may go beyond information supplied by the requesting official. Additional documentation may be requested from that official, such as email records and the like; other persons may be interviewed by the BOE to provide additional information concerning the nature of the conduct in question and the circumstances leading up to it. In some cases it will be necessary for the BOE to come to conclusions concerning the intent and knowledge of the official at the time of the conduct; it may receive conflicting information in that regard; and reasonable inferences based on the available factual information will have to be made.
3. Normally, formal hearings like those convened in a Phase 2 investigation of a RRV, will not be undertaken during the course of an investigation relating to a request for an advisory opinion.
g. Deliberations and opinions will be handled by the BOE in accordance with the following procedures:
1. Advisory opinions will be determined by a majority of the BOE; concurring or dissenting statements may be prepared to accompany the majority opinion if individual members of the BOE chose to file such statements.
2. Advisory opinions normally will not carry recommendations to the Town Board concerning sanctions if the conduct is found to be in violation of the COE. However, recommendations may be made for the official to undertake on a voluntary basis to mitigate or compensate for his or her actions and any undermining of the public trust that such actions may have caused or may cause once it becomes known.
3. A recommendation to the Town Board for action may follow from an advisory opinion in cases where the official has benefited financially at Town expense by reason of unethical conduct in the past. In these cases the BOE may recommend to the Town Board steps to bring about financial restitution to the Town. Recommendations may also be made concerning general governmental practices and institutional policies (570-H).
h. The BOE recognizes that certain requests for an advisory opinion may be time sensitive and may require a response prior to the next scheduled meeting of the Board. Upon receipt of a request for an advisory opinion, the Chair or Acting Chair may find that it is in the best interest of the Town to issue an advisory opinion before the next scheduled meeting, in which case the Chair or Acting Chair may consult with the available members of the BOE for the purpose of preparing and issuing an advisory opinion. The decision to issue an accelerated advisory opinion is within the discretion of the BOE and nothing in this rule shall be deemed to give any party requesting an advisory opinion the right to an accelerated opinion or the right to demand an accelerated opinion. An accelerated advisory opinion must be formally accepted by a majority of the BOE at its next meeting and it will be treated as any other advisory opinion thereafter.
10. Providing Recommendations concerning Town Policy. The BOE may be called upon by the Town Board to offer analysis, recommendations, and advice concerning general matters of town ethics law and policy or on general matters of public policy that may have an ethical dimension or ethical implications. In making policy recommendations the BOE will strive to focus on its own experience and expertise in the area of government ethics and on the practices of municipal ethics boards in other jurisdictions.
11. Section 570-6 interpretive standards. When the Board of Ethics receives a properly certified complaint or a request for an advisory opinion involving § 570-6 of the Town Code, it will be guided by the Interpretive Standards which are contained in an Appendix to this rule.
12. Amendments to Rules and Regulations. These rules and regulations may be amended at a public meeting by a majority vote of the members.
Revised June 26, 2013
Appendix to Internal Rules and Regulations Standards for Interpreting Section 570-6
Board of Ethics Interpretative Standards under Section 570-6 of the Code of Ethics of the Town of Greenburgh for Use of Town Electronic Systems
The following is the section of the Code of Ethics of the Town of Greenburgh Town which is the subject of these interpretative standards:
“§ 570-6. Use of Town-owned equipment or property.
No Public Officer, Employee or Agency Member shall request, obtain, permit the use of or use Town-owned vehicles, equipment, buildings, material or property for personal convenience, Interest, use or benefit or the personal convenience, use or benefit of others, except when such services are available to the public generally or are specifically provided by the Town Board for the use of such Public Officer, Employee or Agency Member in the conduct of official business.”
If the Board of Ethics receives a properly certified complaint or a request for an advisory opinion involving § 570-6, it will be guided by the following standards:
1. Official business includes activities, duties and matters which directly or indirectly pertain to the legislative process or to the effective and efficient functioning, administration and operation of the Town and its services and programs and the performance of responsibilities in connection therewith. These include, but not are limited to, the conveying of information to the public and the requesting of public comment on such matters.
2. Official business does not include the use of Town-owned property for political purposes including, but not necessarily limited to, the solicitation of political support or monies or other contributions in favor of any candidate or political party.
3. Official business does not include the use of Town-owned property to make personal or political attacks on individuals or entities. Such attacks include but are not necessarily limited to the use of vulgar, obscene or defamatory language, and clearly inaccurate, false or misleading statements concerning the character, motivation, actions or omissions of one or more individuals or entities.
One of the purposes of the Board of Ethics as specified in the Code of Ethics is to “facilitate compliance” with the Code. The Town website and the Town email system are relatively new electronic technology. The Town does not have guidelines for the use of these systems in terms of distinguishing between personal convenience and official uses of the Town's email system and website. Nor are there any Town guidelines for content standards of official business. Content standards for the public use of Greenburgh Access TV (GATV) do exist, however.
In the opinion of the Board of Ethics, the Town email and Town website fall within the definition of “equipment, material or property” contained within Section 570-6. The equipment and material used for the Town website and Town email include computer hardware and software, electronic data storage devices, telecommunications equipment, air-conditioning equipment, wiring, and building space and security devices. In order to facilitate a fair and consistent application of Section 6 to the use of this equipment and these systems, the Board of Ethics has adopted the interpretative standards contained herein. With regard to the exclusion of political purposes from allowable uses in Interpretive Standard 2, we note that the Town, as a municipal entity funded by public monies from all citizens, is neutral as to whom the citizenry elects. Section 570-6 was part of legislation passed by the Town Board. In attempting to determine legislative intent in this regard we note that it is Town Board policy to treat individuals at public meetings with respect, even those with whom one may have differing points of view on matters of policy. We also reviewed the Town’s program content policy for public use of Greenburgh Access TV (GATV). This policy is posted on the Town website. Interpretive Standard 3, herein, is consistent with that policy. In addition, we examined official websites from other governmental bodies at the county, state and federal level as well as those of a number of other towns in New York State. This was done in order to help inform us of the usual and customary practice of these websites with respect to what is “official business.” In summary, we found these official websites to be vehicles used to communicate governmental information to the public. They are generally very professional in content and tone. We did not find that they were used for personal attacks. In addition to the above, the use of Town systems for personal attacks would be inherently disrespectful, would be unfair and would potentially have a chilling effect on democratic participation in municipal government.
Section 570-6 and these interpretative standards do not affect in any way the right of any Town official to express her/his opinions through property not owned by the Town, such as in personal emails, personal blogs, campaign emails, printed campaign materials, public debates, communications with the press, and other means not involving the use of property owned by the Town.
Items of official business addressed on the website or in town emails may include comments or discussion of proposed legislation or existing or potential litigation between the Town and other parties including private citizens and entities and other governmental authorities. Some of these items may be controversial and some Town officials, candidates for Town office, political parties or individual citizens or citizen groups may have different opinions than those expressed on the website or in the email. Nothing in these Interpretative Standards precludes a Town official when using the Town website or email from discussing issues regarding the administration of Town government or Town affairs including legal and law enforcement matters, from criticizing the substance of an opinion or view expressed by another, or from expressing a contrary opinion or view, as opposed to attacking named individuals or entities in a manner inconsistent with these Interpretive Standards. When using Town systems to discuss issues it should be done in a professional manner consistent with the official business of a municipality.
June 26, 2013