Inquiry and Review Committees

Once the Ethics Officer, with input from the Intake Committee, determines that a credible allegation of non-compliance constitutes violation of state law, Metropolitan Administrative Code or Operating Policy, or is otherwise inappropriate for informal resolution, the matter is referred to the appropriate Inquiry and Review Committee. These committees investigate concerns, using external investigators and counsel when indicated, and make recommendations to the General Manager or Executive Committee of the Board of Directors. The Ethics Officer submits an independent report.

As with the Intake Committees, the Ethics Office maintains two Inquiry and Review Committees - one for director concerns and another for employee and contractor concerns.

The Inquiry and Review Committee for Employee and Contractor Concerns consists of General Manager or designee, General Counsel or designee, and General Auditor or designee, so long as the individual representing each department does not also serve on Intake Committee. The committee functions with the advice of the Ethics Officer, but issues independent findings.

The committee convenes, elects a chair, considers the need for external investigations and develops a timeline with the goal of providing a disposition within six months of the date that the complaint was referred. As appropriate, the Ethics Officer will provide formal notification to principals that the matter has been referred to the Inquiry and Review Committee. Those involved in matters before the Inquiry and Review Committee may meet with that committee prior to any final determination. The Ethics Officer will review and excuse committee members for conflict of interest or the appearance of conflict.

Once a matter is referred to Inquiry and Review, the Ethics Officer will report monthly in oral and written report to the Board of Directors until the matter is resolved.

Inquiry and Review Recommendations

After completing its investigation, the committee will reach one of the following findings:

1. substantiated
2. unsubstantiated

The elected chair will submit findings along with any dissent to the appropriate Metropolitan department head (with copies to the General Counsel) for action. For matters involving directors, the committee will submit findings and any dissent to the Executive Committee (with copies to the General Counsel) for action. The Ethics Officer will submit separate findings. A report on actions to be taken in response to the findings must be submitted to the Ethics Office (with a copy to the General Counsel) within 30 days.