Dear Members of the Ethics Board:
As a mayor committed to ethical and transparent operation of my administration, I appreciate the significant advances the Board of Ethics has made on behalf of all Philadelphians toward the ethical and transparent operation of all of City government. So it is with the utmost respect that I write to urge that you reject Regulation No. 10. The Board’s proposed Regulation 10 threatens the very core of our collective efforts to maintain integrity within City government and protect the public trust.
Ethics, integrity and transparency have served as one of the central themes of my public service. As Councilman, I staunchly supported campaign finance reform. introduced ground-breaking legislation establishing fairness and transparency in non-competitively bid contracts, and led the fight to create the independent Board of Ethics. As Mayor, my commitment to ethics and integrity has been unwavering, as evidenced by my Executive Orders and the work of my trusted Inspector General and Chief Integrity Officer. Every City employee in my charge, in every department, and at every level, must place honesty and integrity above all other values. This is a priority that the citizens of Philadelphia deserve and demand.
Philadelphia government ethics have vastly improved under my administration. This regulation places that progress at great risk. I understand the need for guidance. I understand the intent behind this endeavor, but I do not understand the outcome.
I can imagine no credible justification for the unfathomable and egregious scenarios that the Regulation permits. I ask you to articulate any circumstances under which a City employee or official may solicit cash handouts from individuals with interests at stake. I ask you to explain why nonmonetary gifts of up to $200 – and monetary gifts of up to $50 – do not suggest improper influence.
It’s all too easy to predict the abuses that will undoubtedly occur within a City government where these acts represent normal and condoned behavior.
Building an honest and ethical government requires great care. If we are to continue on the path that the Board of Ethics and my administration have forged, we must maintain high standards of conduct on the part of City officials, employees and all who deal with them. I urge you to abandon this ill-conceived Regulation in favor of a solution that facilitates, rather than impedes, our mutual interest in an ethical City government.
Mayor Michael A. Nutter