Quarterly Report: Fourth Quarter Report for the Public Building Commission of Chicago

Executive Summary

A | Complaints Received This Quarter
In Q4 2024, OIG received no new complaints related to PBC.
B | Newly Opened Matters
In Q4 2024, OIG opened no new investigation(s) related to the operations of PBC.
C | Investigations Concluded This Quarter

In Q4 2024, OIG did not conclude any investigations related to the operations of PBC. OIG received a response from PBC regarding an investigation concluded in Q3 2024. The investigation and the response are summarized below.

4 | Improper Influence; Failure to Cooperate (C2022-000043937)
An OIG investigation established that a commissioner of the Public Building Commission of Chicago (PBC) used their position in an attempt to influence employees of PBC to engage a company for PBC projects that would have provided the subject with an economic interest distinguishable from that of the general public. Specifically, the subject contacted PBC employees in an effort to get PBC to contract with the provider of a sanitation technology. At the time of the subject’s contacts with PBC employees, the subject was the chairman of a company engaged to provide financial advisory services to the sanitation technology company, and the subject stood to gain commissions in the event that the company successfully sold the sanitation technology. Additionally, during the course of OIG’s investigation, the subject willfully failed to provide documentation requested by OIG that was relevant to their financial interests in the contemplated transactions.

OIG found that the subject’s conduct violated Section 202 of PBC’s Code of Ethics (no Official or Employee shall make, participate in making, or in any way attempt to use his or her position to influence any Commission decision or action in which he or she knows or has reason to know that he or she has an Economic Interest distinguishable from that of the general public). The subject’s failure to cooperate with OIG violated the “Intergovernmental Agreement Between the Public Building Commission and the City of Chicago Providing that the City’s Office of Inspector General will also Serve as the Commission’s Inspector General,” specifically paragraph nine (duty to cooperate). OIG further noted that the PBC Code of Ethics does not address sanctions for PBC commissioners who violate the Code. OIG accordingly recommended that the PBC Executive Director provide the summary report to the Chairman of the Board and recommend discipline against the subject in a manner that is determined to be appropriate. OIG further recommended that PBC amend the Code of Ethics to remedy its failure to address commissioner misconduct.

In response, PBC neither agreed nor disagreed with OIG’s finding that the above misconduct occurred; that is, PBC was silent on OIG’s findings against the subject. PBC agreed that the Code of Ethics, as written, does not provide any sanctions for commissioners who violate the Code. PBC further noted that no actual financial transaction occurred, so it could not pursue remediation of a pecuniary benefit obtained by the subject. PBC’s response further reflects a recommendation that the PBC Board of Commissioners consider an amendment to the Code of Ethics that would enable sanctions against commissioners who violate the Code.

D | Active Investigations
OIG has one active investigation regarding PBC.