Ethics Board
 

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Ethics Board

Ensuring the Integrity of Milwaukee County Government

What We Do

The Board reviews, investigates and determines, as needed, all verbal and written complaints of potential violations of the Ethics Code as outlined in Chapter 9 of the Milwaukee County General Ordinances by Milwaukee County employees, Milwaukee County office holders and candidates for public office of Milwaukee County.

The Board reviews the rules, practices and procedures of the Ethics Code pursuant to Chapter 9 of the Milwaukee County General Ordinances and the Board's own Rules of Procedure.

The Board maintains annual financial Statements of Economic Interests for Milwaukee County employees, Milwaukee County office holders, citizens serving on board and commissions of Milwaukee County and candidates for public office in Milwaukee County service.

Annual Reports

Annual Reports

The report contains the financial disclosure provisions of the Code of Ethics, Ethics Board operations, yearly adopted budgets, Ethics Board members and terms, and summaries of investigations and complaints. The Ethics Board annual report is approved by the Ethics Board in April of the succeeding year.

Statement of Economic Interests

The Ethics Code (M.C.G.O. § 9.03) requires financial disclosure through the filing of a Statement of Economic Interests (SEI). While the Ethics Code applies to all public officials and county employees, regardless of whether they are required to file an SEI, only certain positions are required to file.

Ethics Board Newsletter

The Ethically Speaking newsletter keeps Milwaukee County employees up-to-date on the Ethics Code and highlights pertinent topics.

Fraud Hotline

The Ethics Board does not act on anonymous complaints or investigation requests. If you would like to make an anonymous complaint, please call the Fraud Hotline, (414) 93-FRAUD (3-7283), or visit the Audit Services Division webpage. The Audit Services Division is responsible for examining fiscal statements, reviewing internal accounts for compliance with applicable laws and regulations, monitoring vendor contracts for goods and services, and ensuring that fraud, abuse or waste of county resources does not occur. 

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How to File an Investigation Request or Verified Complaint

Potential Ethics Code violations may be brought to the Ethics Board by either filing an investigation request or filing a verified complaint. A verified complaint must be sworn before a notary public or other individual authorized to administer oaths, while an investigation request must simply be in writing and signed. Investigation requests and complaints shall be in writing and contain the following information:

  1. The name of the individual alleged to have violated the Code
  2. The details surrounding the violation
  3. Relevant sections of the Code regarding the violation

Process and Details

All verified complaints are referred to the District Attorney, whereas investigation requests are referred to the District Attorney only after the Ethics Board approves the investigation. All verified complaints must be filed no later than three years after the violation is alleged to have occurred. When an investigation request or verified complaint is filed, it does not become part of the public record, unless the accused requests to have the matter made public. A verified complaint becomes a public record at the close of all proceedings only if it results in a finding of an Ethics Code violation.

All Ethics Board deliberations regarding complaints or investigations will be held in closed session, unless the accused requests to have the matter heard in open session. The identities of the individual making the complaint or investigation request, and the person(s) named in the complaint or investigation request, shall remain confidential.

If at this point there is a reasonable basis for the belief that a violation of the Ethics Code has or might have occurred, a Preliminary Conference will be scheduled. The purpose of the conference is to determine whether the matter may be resolved without the need of holding a hearing.

If a hearing is to be held, the Ethics Board will appoint a hearing examiner to conduct the hearing. Based on the evidence from the hearing the Ethics Board will determine whether a violation of the Ethics Code has occurred.

Outcome

The finding of an Ethics Code violation may result in one or more of any of the following, or such other orders as may be necessary, pursuant to Ethics Code, Section 9.12(2) a-f:

  1. An order requiring the individual to conform his or her conduct to the Ethics Code
  2. A monetary forfeiture of $100 to $1,000 for each violation
  3. An order to return county property, funds or gifts and/or restitution for the value of property, funds or gifts procured in violation of the Ethics Code
  4. Censure, suspension or removal from office or employment

How to Seek Advice

Contact the Board

The Ethics Board and staff are available to answer questions and provide advice about the Ethics Code. County officials and employees are encouraged to contact the Ethics Board and/or staff with any questions or concerns that they may have. The Ethics Board and staff may be contacted at: 

Milwaukee County Ethics Board
Milwaukee County Courthouse
901 N. 9th Street, Suite 308
Milwaukee, WI  53233


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Advisory Opinions

Requests for advisory opinions may be made to the Ethics Board regarding the propriety of matters regarding the Ethics Code. (M.C.G.O. § 9.09(1)(a)). All requests for advisory opinions must be made in writing and contain the following information:

  • The name(s) of the person(s) on whose behalf the opinion is being requested
  • Each question upon which an opinion is sought
  • All of the facts giving rise to the question
  • Relevant Ethics Code provisions or other law, if known


Advisory opinions are not public records and shall be kept confidential, except that the Ethics Board may publish summaries of advisory opinions with all personally identifiable information removed.

Formal Opinions

The Ethics Board may also issue formal opinions interpreting the Ethics Code or applying the Ethics Code to hypothetical facts to address issues of universal concern. Formal opinions will be kept on file with the Ethics Board. (M.C.G.O. § 9.09(2)).

File a Public Records Request

Requests for records may be made in person at the office, by U.S. mail, by phone or from the MyCounty Customer Portal. Access to records will be made available for review to any person requesting them, except where the right to inspect or copy a record does not apply. It is solely within the power of the custodian whether access will be permitted, except where access is required by law.

Submit Your Request

Examples of Ethical Scenarios

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  Question 1: A county elected official is at a conference and is invited to attend a cocktail reception. The cocktail reception has an open bar. The reception is open to everyone who is in attendance at the conference. May the official attend?

a. No, because elected officials are not allowed to accept gifts.
b. Yes, because the reception is open to all attendees.
c. Yes, but only if the official pays for his or her drinks.

Answer:
b – While it is true that an elected official cannot accept anything of value that could be expected to influence his or her actions or judgment or be construed as a reward for past or future action (M.C.G.O. §§ 9.01 and 9.05), an elected official is allowed to accept food and drink offered in connection with a conference or seminar as long as the food and drink are offered to all attendees on the same terms and conditions. 

  Question 2: A county elected official is attending a golf tournament at a county park. A cocktail reception with an open bar is included for all attendees. However, there is also a special V.I.P. tent by invitation only. A lobbyist invites the official to join him in the “V.I.P. tent” where he will be served beverages by staff instead of having to wait in line. The lobbyist tells him that only a select few are invited. May the official go to the V.I.P. tent?

a. Yes, as long as the official reports the drinks on his Statement of Economic Interests.
b. Yes, because everyone else at the event, even those who are not invited to the V.I.P. tent, are receiving complimentary drinks.
c. No, because the food and drink are not being offered to everyone at the conference on the same terms and conditions.

Answer:
c – An elected official may only accept food and drink offered at events if the food and drink are offered to all attendees on the same terms and conditions.  Therefore, the official cannot go to the V.I.P. tent unless every single person at the event is given the same opportunity.  In addition, the official must consider why the lobbyist is making this offer.  If the offer could reasonably be construed as an attempt to influence the official’s actions, the official cannot accept.

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MILWAUKEE COUNTY ETHICS BOARD

Attorney Adam J. Gilmore - Executive Director
Milwaukee County Courthouse
901 N. 9th St., Suite 308
Milwaukee, WI 53233

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