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STATE OF LOUISIANA <br /> OV Lo U DEPARTMENT OF STATE CIVIL SERVICE <br /> I <br /> 10%4 LOUISIANA BOARD OF ETHICS <br /> P.O. BOX 4368 <br /> \ BATON ROUGE,LA 70821 <br /> NFIDE <br /> (225)219-5600 <br /> b.• <br /> FAX:(225)381-7271 <br /> 1-800-842-6630 <br /> www.ethics.1a.gov <br /> January 9, 2023 <br /> Eric A. Mund <br /> Deputy City Attorney, City of Kenner <br /> 1801 Williams Boulevard <br /> Building C, 3rd Floor <br /> Kenner, Louisiana 70062 <br /> Re: Docket No. 2022-840 <br /> Advisory Opinion <br /> Dear Mr. Mund: <br /> The Louisiana Board of Ethics, at its meeting on January 6, 2023, considered your request to <br /> approve a disqualification plan pursuant to La. R.S. 42:1111C(5). <br /> FACTS PROVIDED <br /> The City of Kenner hired Michael D. Gupton as a new Assistant Finance Director on October 17, <br /> 2022. Sisung Securities Corporation has served as the financial advisor for the City of Kenner <br /> since 2009. Sisung Investment Management Services, LLC,has served as the investment advisor <br /> for the City of Kenner since 2009. Sisung Strategic Resources, LLC, has served as the <br /> dissemination agent for the City of Kenner since 2009. Collectively, all three entities are known <br /> as Sisung. Mr. Gupton's spouse, Courtney Gupton, is a salaried employee of Sisung Securities <br /> Corporation ("Sisung") and has been continuously employed by Sisung since 2000. Neither <br /> Michael D. Gupton nor Courtney Gupton are owners, officers, directors, trustees, or partners in <br /> Sisung. <br /> The City of Kenner has proposed a disqualification plan in order to prevent participation in any <br /> prohibited transactions. <br /> Michael D. Gupton will recuse himself from any meetings, approval of invoices, assignments of <br /> work, or other transactions involving Sisung. Ms. Elizabeth Herring, the Finance Director for the <br /> City of Kenner, will take on any duties regarding contracts with Sisung. Courtney Gupton's <br /> compensation is substantially unaffected by a contractual or other business or financial relationship <br /> Sisung has with the City of Kenner. <br /> Both Michael D. Gupton and Courtney Gupton signed affidavits stating that they will comply with <br /> the disclosure requirements pursuant to La. R.S. 42:1114. <br /> Page 1 of 3 (BD 2022-840) <br /> AN EQUAL OPPORTUNITY EMPLOYER <br />