2025-171 - Laserfiche WebLink

Ethics Board Docket No. 2025-171 Page 8 of 14 relationship with OOC. Section 1115A of the Ethics Code prohibits Mr. Adams from receiving, directly or indirectly,any thing of economic value from persons doing business with OOC. Section 1117 of the Ethics Code prohibits LORA, Chromos and Mr. Berthelot from giving, delivering or transferring a thing of economic value to Mr. Adams which he is prohibited from receiving under Section 1115A of the Ethics Code. While Mr.Adams was employed by OOC,he received a loan under non-market conditions, and the source of funds for such funds was LORA. The loan was not a bona fide loan made by a duly licensed lending institution at the normal rate of interest, which makes the loan a thing of economic value under Section 1102(25) of the Ethics Code. LORA had an existing contract with OOC at the time Mr. Adams received the loan. Accordingly, this transaction violates Section 1115A of the Ethics Code. LORA was the indirect source of the funds for the prohibited loan, and each of Chromos and Mr. Berthelot actively participated in facilitating the loan to Mr. Adams. Accordingly,each of LORA,Chromos and Mr.Berthelot violated Section 1117 of the Ethics Code. If this matter proceeded to a public hearing before the Ethics Adjudicatory Board, and the Ethics Adjudicatory Board found a violation of the Ethics Code, the Ethics Adjudicatory Board could impose a fine of up to $10,000, pursuant to Section 1153B of the Ethics Code. The Ethics Adjudicatory Board could also impose penalties equal to one-and-a-half times the amount of economic advantage gained, pursuant to Section 1155A of the Ethics Code. In this particular situation, it is the conclusion of the Board that the interest of the public would be served by, and the parties have agreed to resolving this matter amicably through the publication of this Consent Opinion with the imposition of a $5,000 civil penalty against each of LORA, Chromos and Mr. Berthelot. __ --