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STATE OF LOUISIANA <br /> ''' _ DEPARTMENT OF STATE CIVIL SERVICE <br /> �d OF LOUj%. <br /> 44, ,4 LOUISIANA BOARD OF ETHICS <br /> �9y� <br /> e,dhr, "I P.O.BOX 4368 <br /> ui�ii�.;,yu <br /> IIIBATON ROUGE,LA 70821 <br /> ""i•• o (225)219-5600 <br /> FAX:(225)381-7271 <br /> 1-800-842-6630 <br /> www.ethics.la.gov <br /> January 23, 2018 <br /> Mr. Carl J. Krielow <br /> Post Office Box 39 <br /> Roanoke, LA 70581-0039 <br /> Re: Ethics Board Docket No. 2017-1273 <br /> Dear Mr. Krielow: <br /> The Louisiana Board of Ethics, at its January 19,2018 Board meeting,considered your request for <br /> an advisory opinion as to whether the ethics code would prohibit you from contracting and selling <br /> grain and commodities as a fanner to third party grain dealers who utilize the IFG Terminal to export <br /> their sales while you are a Commissioner on the Lake Charles Harbor and Terminal District which <br /> regulates the IFG Terminal. You stated that you are a farmer by trade and sell grain commodities, <br /> primarily rice,to third party licensed grain dealers. You stated that the grain dealers often export the <br /> grain through the IFG Terminal at the Port of Lake Charles, which is a private entity having a land <br /> lease with the Port of Lake Charles. You stated that you have no ownership interest or involvement <br /> with the grain dealers or the IFG Terminal. <br /> The Board concluded and instructed me to inform you that the Code of Governmental Ethics would <br /> not prohibit you from transacting with grain dealers who in turn export the grain through the IFG <br /> Terminal which is regulated by the Lake Charles Harbor and Terminal District of which you serve <br /> as a Commissioner. La.R.S.42:1111C(2)(d)prohibits a public servant and a legal entity in which <br /> the public servant exercises control or owns an interest from receiving any thing of economic value <br /> for services rendered to or for any person during his public service unless such services are neither <br /> performed for nor compensated by any person(1)having or seeking to have a contractual,business <br /> or financial relationship with the public servant's agency;(2)conducting operations or activities that <br /> are regulated by the public employee's agency;or,(3)having a substantial economic interest which <br /> may be substantially affected by the performance or nonperformance of the public employee's <br /> official duty. Provided that you have no ownership interest in and do not exercise control over the <br /> businesses maintained by the grain dealers or the IFG Terminal, then the Code of Governmental <br /> Ethics would not prohibit you from selling your grain to the grain dealers who would utilize the IFG <br /> Terminal to export their sales. <br /> AN EQUAL OPPORTUNITY EMPLOYER <br />