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If Ms. Guidry's current role with the Parish would typically involve participation in the transaction <br /> contemplated by SJB Group, Ms. Guidry should submit a disqualification plan to the Board for its <br /> consideration and approval. <br /> While Ms. Guidry's immediate family member owns a percentage of SJB Group, a legal entity, <br /> because that percentage is less than 25%, Ms. des Bordes would not be deemed to have a <br /> controlling interest in SJB Group pursuant to La. R.S. 42:1102(8). Accordingly, La. R.S. 42:1113 <br /> would not prohibit SJB Group from entering into any contract, subcontract, or other transaction <br /> that is under the supervision of the Parish. However, La. R.S. 42:1113 would prohibit Ms. des <br /> Bordes from representing SJB Group in matters involving the Parish. <br /> Additionally, because Ms. des Bordes is the immediate family member who is deriving a thing of <br /> economic value from a person who is in any way financially interested in a transaction under the <br /> supervision of Ms. Guidry's agency, Ms. des Bordes would be required to annually file a financial <br /> disclosure form pursuant to La. R.S. 1114A with the information required by such statute. <br /> CONCLUSION <br /> The Board concluded, and instructed me to inform you, that the Code would not prohibit SJB <br /> Group from entering into a transaction with the Parish; however, Ms. Guidry would not be <br /> permitted to participate in transactions involving SJB Group and a disqualification plan should be <br /> submitted for the Board's consideration and approval. Chapter 14 of the Rules of the Board,a copy <br /> of which is enclosed,describes the requirements for the disqualification plan.Also,Ms.des Bordes <br /> will have to file a disclosure statement pursuant to La. R.S.42:1114 annually by May 15 disclosing <br /> her income from SJB Group received in the prior calendar year. <br /> This advisory opinion is based solely on the facts as set forth herein.Changes to the facts as <br /> presented may result in a different application of the provisions of the Louisiana Code of <br /> Governmental Ethics. The Board issues no opinion as to past conduct or as to laws other than the <br /> Louisiana Code of Governmental Ethics, the Campaign Finance Disclosure Act, the Lobbyist <br /> Disclosure Acts, and the conflict of interest provisions contained in the Louisiana Gaming Control <br /> Law. If you have any questions, please contact me at (800) 842-6630 or (225) 219-5600. <br /> Sincerely, <br /> LOUISIA A BOARD OF ETHICS <br /> Charles E. Reeves, Jr. <br /> For the Board <br /> Page 3 of 3 (BD 2022-238) <br />