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And three, disclosure (including updates) means that officials regularly participate in <br />the ethics program, which helps create a good, active ethics environment in the local <br />government. <br />There are two sides to every disclosure: (1) the official and (2) individuals and <br />entities seekinb special benefits from the local government. And there are three t��pes of <br />disclosure: (1) annual disclosure of financial and personal relationships and ownership <br />interests, with updates; (2) "transactional disclosure" of conflicts when a matter comes <br />before an official with a possible conflict; and (3) "applicant disclosure," that is, disclosure of <br />relationships to officials, direct or indirect, by an individual or entity seeking a contract, <br />permit, or grant from the local government. <br />It is important to understand that, although disclosure is valuable, it is not alone <br />sufficient. If one discloses a possible conflict situation and does not handle it responsibly, this <br />tells the public that it is acceptable to use one's office to benefit oneself, one's family <br />members, and one's business associates. Disclosure provides information; it is not a <br />replaceinent for withdrawal from participation, refusing a gift, or other ways of responsibly <br />handling conflict situations. <br />4. Independent Administration <br />Since government ethics is all about conflicts, it is extremely important that there not be any <br />conflicts in the ethics program itself. In practice, this means that no official under the <br />jurisdiction of an ethics program should have any special role in the program. <br />LInfortunately, high-le�•el officials often select the members of an ethics commission <br />and, sometimes, its ethics officer or executive director; malze enforcement decisions; <br />approve the ethics program's budget; and, in the case of city or county attorneys, provide <br />ethics advice and ethics commission representation. Sometimes, in fact, these officials <br />administer the ethics program themsel�-es. <br />Whenever officials' appointees in an ethics program appear to act too indulgently <br />toward officials (or do not act at all, or appear to act to hurt a mayor or council majority's <br />opponents), this undermines the public's trust in the government. In addition, the selection <br />of ethics commission members by high-le�-e1 officials malces it look to the public like they <br />control the program. This undermines trust in the program and means that citizens don't <br />bother filing complaints. This is why the independence of an ethics program from <br />2t <br />