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2022-238
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Last modified
4/1/2024 8:38:54 AM
Creation date
5/10/2022 12:15:45 PM
Metadata
2022-238
Fields
Template:
Opinion Item
Opinion Type
Advisory Opinion
Docket Number
2022-238
Requesting Party
Wilfred Barry
Parties Involved
Jacquelyn des Bordes
Tonilyn Guidry
SJB Group, LLC
Agency at Issue
Pointe Coupee Parish
Decision Date
5/6/2022
Law
1112B(1)
1113A
1114A
Caption
Advisory opinion that SJB Group, LLC would not be prohibited from entering into transactions with Pointe Coupee Parish while the sister of an owner is employed as the Director of Finance with Pointe Coupee Parish since the owner holds less than a 25% controlling interest; however, the owner would be prohibited from representing the company before the Parish and would be required to file a disclosure statement pursuant to Section 1114.
Ethics Subject Matters
Prohibited Transactions
Participation
Disclosure - Other
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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 />
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