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Citywide anti-nepotism policy and vendor integrity initiatives

0:40:18

·

4 min

Charles Diamond, Special Counsel from the Mayor's Office of Contract Services (MOCS), explains the citywide anti-nepotism policy and vendor integrity initiatives. He discusses the development of these policies and their implementation across city agencies.

  • DHS nepotism policy became the basis for a citywide policy effective April 2024
  • Creation of MOCS vendor integrity unit and vendor compliance cabinet
  • Development of additional policies on conflicts of interest and related party transactions
  • Emphasis on stakeholder understanding and transparency in policy implementation
Charles Diamond
0:40:18
Yes.
0:40:18
Indeed.
0:40:18
I would say so that, as the commissioner just said, that DHS policy really rolled up into becoming what is now a citywide policy that became effective in April of 2024.
0:40:27
So there is that new anti nepotism policy.
0:40:29
And I would take a step back and say this has all kind of come out of the growth of, as referenced in the DOI report, the, beginning of the MOX, vendor integrity unit, which is housed within MOX, and then the vendor compliance cabinet, which is co chaired by Director Flores of MOX and Executive Director, Lebec of MORMEC.
0:40:47
And then has our procuring agencies, has law department, has, you know, Mons and law will come in and and and give support.
0:40:53
And through that kind of clearing house, we've developed this anti nepotism policy that DHS was the leader on.
0:40:59
And then we have that are really right at this the kind of final stages are conflicts of interest policy specific to that issue and then a related party transactions specific policy.
0:41:09
And this VCC, the vendor compliance cabinet, it's really, something that's desperately been needed and something that is we're really looking forward to expanding.
0:41:18
It's in stage 1 as we're building these out.
0:41:20
It's developed a charter to have stakeholders understand these policies.
0:41:24
Right?
0:41:24
So these policies, you know, have been discussed with vendors for over a year.
0:41:28
No more surprises.
0:41:29
No more, oh, my gosh.
0:41:30
What do I have to do?
0:41:31
That's certainly the goal.
0:41:32
And so we have our anti nepotism policy that is active and effective.
0:41:36
We have our conflicts an enhanced conflict of interest and enhanced related party transaction policy that is at that final stages with actually, the vendor compliance cabinet meets this afternoon on those two policies.
0:41:46
So all of these exact issues, I think the commissioner phrased it very well.
0:41:50
It's somewhat more nuanced.
0:41:51
You know, we use the word nepotism as obviously inherently awful, and that no show job she described, that's gonna be violative of 15 other parts of your contract.
0:41:59
But we've got to give our agencies the tools to find this stuff out.
0:42:02
And I think, crucially, as chair Brewer said, do it at not at the invoice stage.
0:42:07
All of these policies, all of these things are things that can start to be done at the prequalification stage, the responsibility stage, Things that can be done so that how can we minimize risk to the greatest extent possible without slowing anything down.
0:42:18
Because as we know, the system is already inherently way too slow.
0:42:22
So we we can't afford to just hit it with a hammer.
0:42:24
But, it's very exciting with the vendor compliance cabinet who have already had an effective policy out.
0:42:29
We've got more in the pipeline, and there's also things surrounding that that are still in work.
Diana I. Ayala
0:42:34
But is is the is the nepotism policy just for, leadership?
Molly Wasow Park
0:42:41
So it addresses supervisory lines.
0:42:43
Right?
0:42:44
If there are 2 caseworkers from the same family, frontline staff people, that's not inherently a problem.
Diana I. Ayala
0:42:52
Okay.
0:42:52
You know, because I've I've heard, you know, in in I've had situations where folks have, you know, in conversation brought up, like, you know, I work at the shelter and, like, my supervisor hired his cousin who now runs you know, is managing the program and then she hired her sister.
0:43:11
And, and so those people wouldn't necessarily be in leadership.
0:43:15
But when the whole family is running the shelter, then it can become problematic.
Molly Wasow Park
0:43:21
Yes.
0:43:21
Absolutely.
0:43:22
And that is something that we would follow-up on and and enforce as appropriate.
0:43:26
Is
Diana I. Ayala
0:43:27
there any language in in in the policy that prohibits that?
0:43:30
Is there any type of disclosure that is required, of whoever is overseeing that specific site, in relation to the nepotism policy?
Bedros Boodanian
0:43:43
I'll have to recheck the policy for that specifically, but I do know the policy does govern direct chain of command, direct oversight.
0:43:50
It prohibits, supervisors from having the ability to oversee performance evaluations of their, family members.
0:44:00
Whether that goes down to supervisor or employee, I'll need to confirm.
0:44:03
Yeah.
Diana I. Ayala
0:44:06
If there isn't a policy, I think that there has to be one.
0:44:09
And if there is one that I don't think people will understand are complying because I've heard it more than enough times to, because I've heard it more than enough times to get that that's is a thing within, you know, the shelter system.
Molly Wasow Park
0:44:22
We'll be having
Diana I. Ayala
0:44:23
a couple of people
Molly Wasow Park
0:44:24
who are offline
UNKNOWN
0:44:25
Yeah.
Molly Wasow Park
0:44:25
To get specifics.
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