Advisory Opinion request as to whether the Code of Governmental Ethics ("Code") permits John Adams' daughter to be employed by Arkus Management Services, LLC, a subcontractor of Louisiana Oilfield Restoration Association, Inc. ("LORA"), while LORA has a Cooperative Endeavor Agreement with the Office of Conservation, and he serves as the Deputy Assistant Secretary for the Office of Conservation. |
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John Adams is the Deputy Assistant Secretary for the Office of Conservation. The Office of Conservation currently has a Cooperative Endeavor Agreement with LORA. The sole authority to enter into Cooperative Endeavor Agreements originates with the Commissioner of Conservation. John Adams' daughter, Laura Elizabeth Adams, is seeking employment with Arkus Management Services, LLC. Arkus Management Services, LLC is a management company that provides back-end office support services, including IT support, data management, project management, and accounting services for different companies, including LORA. His daughter would be a field instrument technician who tests pipes and well sites for methane leaks and tracks and reports the data for purposes of mitigating the leaks and applying for carbon credits through a carbon registry, a project separate from the Cooperative Endeavor Agreement with the Office of Conservation. Additionally, she may be used to troubleshoot and resolve IT issues. The Office of Conservation has no regulatory authority or jurisdiction over IT issues, carbon credits, or associated methane testing.
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La. R.S. 42:1113A(1)(a) No public servant, excluding any legislator and any appointed member of any board or commission and any member of a governing authority of a parish with a population of ten thousand or less, or member of such a public servant's immediate family, or legal entity in which he has a controlling interest shall bid on or enter into any contract, subcontract, or other transaction that is under the supervision or jurisdiction of the agency of such public servant.
La. R.S. 42:1114A. Other than a legislator, each public servant and each member of his immediate family who derives any thing of economic value, directly, through any transaction involving the agency of such public servant or who derives any thing of economic value of which he may be reasonably expected to know through a person which (1) is regulated by the agency of such public servant, or (2) has bid on or entered into or is in any way financially interested in any contract, subcontract, or any transaction under the supervision or jurisdiction of the agency of such public servant shall disclose the following:(1) The amount of income or value of any thing of economic value derived;(2) The nature of the business activity;(3) Name and address, and relationship to the public servant, if applicable; and(4) The name and business address of the legal entity, if applicable.
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Adopt the proposed Advisory Opinion.
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Assigned Attorney: |
Mallory Guillot |
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