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La. R.S. 42:1121(C): No legal entity in which a former public servant is an officer, director, <br /> trustee,partner, or employee shall,for a period of two years following the termination of his public <br /> service,assist another person,for compensation,in a transaction,or in an appearance in connection <br /> with a transaction in which such public servant at any time participated during his public service <br /> and involving the agency by which he was formerly employed or in which he formerly held office. <br /> ANALYSIS <br /> As Secretary, Ms. Walters was the chief executive or administrative officer who exercised <br /> supervision over DCFS pursuant to the definition of"agency head" in La. R.S. 42:1102(3). Ms. <br /> Walters's agency for purposes of the Code was DCFS pursuant to La. R.S. 1102(2)(a)(i). <br /> Generally, La. R.S. 42:1121(A)(1) prohibits Ms. Walters, for a period of two years following her <br /> retirement on December 31, 2022, from assisting a person for compensation in a transaction, or in <br /> an appearance in connection with a transaction, involving DCFS. Additionally, La. R.S. <br /> 42:1121(A)(1) prohibits Ms. Walters from rendering any services on a contractual basis to or for <br /> DCFS for the same two-year period. <br /> As a result, La R.S. 42:1121(A)(1) prohibits Ms. Walters from assisting Metanoia for <br /> compensation in any transaction involving DCFS through December 31, 2024. Ms. Walters is not <br /> prohibited from being hired by Metanoia as the interim executive director, provided another <br /> Metanoia employee handles any transactions involving DCFS. <br /> Further, La. R.S. 42:1121(C)prohibits Metanoia, for the same two-year period, from assisting any <br /> person for compensation in a transaction, or in an appearance in connection with a transaction, <br /> involving DCFS, if Ms. Walters participated in such transaction while employed at DCFS. <br /> CONCLUSION <br /> The Board concluded, and instructed me to inform you, the Code does not prohibit Ms. Walters <br /> from being hired as interim executive director of Metanoia within the two years following her <br /> retirement as DCFS Secretary. Ms. Walters should seek an updated advisory opinion in the event <br /> a specific transaction arises which could potentially violate the post-employment restrictions of <br /> the Code. <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 Code of Governmental <br /> Ethics. The Board issues no opinion as to past conduct and or to laws other than the Code of <br /> Governmental Ethics, the Campaign Finance Disclosure Act, the Lobbyist Disclosure Acts, and <br /> the conflict of interest provisions contained in the Louisiana Gaming Control Law. <br /> Page 2 of 3 (BD 2023-1005) <br />