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2023-1004
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Last modified
3/6/2024 10:27:59 AM
Creation date
1/10/2024 1:06:57 PM
Metadata
2023-1004
Fields
Template:
Opinion Item
Opinion Type
Advisory Opinion
Docket Number
2023-1004
Requesting Party
Harry Vorhoff
Agency at Issue
Governor's Office of Coastal Activities
Decision Date
1/5/2024
Law
La. R.S. 42:1121B
Caption
The Code of Governmental Ethics prohibits Harry Vorhoff, for a period of two years following the termination of his employment with the Governor's Office of Coastal Activities, from assisting persons in transactions involving the State if he participated in those transactions while employed by the State, and from rendering the same services back to the Governor's Office of Coastal Activities through a contractual relationship.
Ethics Subject Matters
Post Employment
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Plan, which will be completed by January 2024. The other two deliverables are a Comprehensive <br /> Climate Action Plan and a Status Report. <br /> You ask whether you are permitted to receive payment from a third party to work on the <br /> development of the Comprehensive Climate Action Plan and the Status Report. La. R.S. <br /> 42:1121(B) prohibits you, for a period of two years following the end of your employment, from <br /> assisting a person for compensation in any transaction involving the State of Louisiana concerning <br /> the Priority Climate Action Plan, Comprehensive Climate Action Plan, and Status Report since <br /> you participated in the grant application while employed by the State of Louisiana. As such, La. <br /> R.S. 42:1121(B) will prohibit you from assisting third parties if you would be required to assist <br /> that person in a transaction involving the State of Louisiana or an agency thereof. <br /> You also ask whether you are permitted to receive payment, either directly from DOA or through <br /> a subcontractor, for services in connection with the Environmental Protection Agency grant. La. <br /> R.S. 42:1121(B) prohibits you, for the same two-year period, from rendering the same services <br /> back to your agency,the Governor's Office of Coastal Activities,through a contractual relationship <br /> with the Governor's Office of Coastal Activities. However, La. R.S. 42:1121(B) does not prohibit <br /> you from rendering services directly to DOA provided that the services do not involve the <br /> Governor's Office of Coastal Activities. <br /> CONCLUSION <br /> The Board concluded, and instructed me to inform you, that the Code prohibits you,for a period <br /> of two years following the termination of your employment with the Governor's Office of Coastal <br /> Activities, from assisting persons in transactions involving the State of Louisiana, if you <br /> participated in those transactions while employed by the State of Louisiana. The Code will also <br /> prohibit you from rendering the same services back to the Governor's Office of Coastal Activities <br /> through a contractual relationship with the Governor's Office of Coastal Activities. <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 /> If you have any questions, please contact me at(800) 842-6630 or (225) 219-5600. <br /> Sincerely, <br /> Louisi_AxABoAmOf ICS <br /> David M. Bordelon <br /> For the Board <br /> Page 4 of 4 (BD 2023-1004) <br />
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