OIG Report and Recommendations Regarding Gifts from Contractors to City of Chicago Employees

In response to a series of investigations concerning violations of the City’s gift policy (Section 2-156-040 of the City of Chicago’s Ethics Ordinance), the OIG is recommending that the Mayor institute a City-wide “no-gifts” policy.

“In examining gift related cases my office has investigated over the past year alone, it is clear that this recommendation is long past due,” said Inspector General Joseph Ferguson. “The policy we’ve got in place today simply isn’t working, and I salute the City Departments that have already taken action on this front.”

While the City studies this proposal, the OIG is also recommending that the Chicago Department of Transportation (CDOT) institute its own no-gift policy. Other City departments, including Buildings, Procurement Services, Aviation, Public Health, Office of Compliance, and the OIG have already implemented or are in the process of implementing no-gift policies.

Over the past year, the OIG has sustained allegations of gift related misconduct in seven cases spanning six departments and numerous City employees, contractors, and vendors. These investigations illustrate the inherent difficulties in promulgating and administering rules and regulations permitting the receipt of gifts by City employees. Recent OIG investigations have prompted at least three City departments to move to a no-gift or zero-gift policy. As a result, the City now operates under two different standards respecting the receipt of gifts by its employees.

First is the no-gifts approach, which certain City departments have already implemented. This is clear and simple, and also serves to remove doubt or uncertainty for employees, contractors, and vendors alike. It further promotes transparency and accountability, and enhances public confidence in the integrity of City operations.

The second, that directed by Section 2-156-040 of the Ethics Ordinance, is anachronistic and, based on OIG investigations, confusing to City employees, contractors, and vendors. Further, it is ill-defined and therefore difficult and time consuming to enforce. OIG has found that critical terms central to the jurisdictional scope and the enforcement of the Ordinance have never been meaningfully defined by the Board of Ethics. This has only served to further complicate the already difficult landscape regarding gifts for City employees.

“This is why we’re making a no-gifts recommendation to City Hall,” said Ferguson. “City employees and contractors deserve the consistency and clarity that comes with our recommendation, and City residents deserve to know that the public servants overseeing their tax dollars will be held to a higher standard.”