Skip to main content

Ethics and Conflicts of Interest

2024 Ethics and Conflicts of Interest Changes: The Statewide Municipal Code of Ethics - Act 171

Act 171 became law on June 10, 2024 and drastically changes the ethical regulatory landscape for municipalities. It removes municipal authority to enact conflict of interest prohibitions tailored to address the specific needs, concerns, size, and values of their municipalities and replaces that authority with a new, top-down, one size fits all, statewide Municipal Code of Ethics.  

Deadlines:
All provisions of Act 171 take effect January 1, 2025 with two exceptions:
  1. The repeal of existing municipal ethics statutes (24 V.S.A. §§ 1984 and 2291(20)) took effect upon passage June 10, 2024. 
            2. New ethics training requirements take effect September 30, 2025
New Contact: Vermont State Ethics Commission

Since the legislature gave the State Ethics Commission the authority to provide guidance and advice (including advisory opinions) to municipalities, we are directing all municipal officers to contact the States Ethics Commission regarding any ethics questions they may have. The State Ethics Commission can be reached at 802-828-7187 or ethicscommission@vermont.gov 

New Municipal Ethics Requirements 

Please review the following new ethics requirements carefully and direct questions and comments to the Vermont State Ethics Commission.

Municipalities must post the Municipal Code of Ethics and their means of enforcing the code on their website and provide it to all municipal officers.  

Required designees:

  1. Assign staff member as ethics liaison to the State Ethics Commission (within 30 days of January 1, 2025).
  2. Assign a municipal officer or board to receive complaints of ethics violations.
  • Requires current specified* officers to complete State Ethics Commission approved training by September 30, 2025. 
  • Requires new officers* to complete State Ethics Commission approved training within 120 days of their election or appointment.
  • Requires all specified* officers to retake training every three years after their initial training.

List of Officers Required to Take Training:

Chief Administrative Officers, Town or City Managers, Mayors, all members of legislative bodies, and members of quasi-judicial bodies (Boards of Civil Authority, Boards of Abatement, Development Review Boards, etc.).

  1. Record and retain complaints received and the disposition of each complaint made against an active municipal officer for the duration of their service (plus five years after service has ended).
  2. Provide the State Ethics Commission with a summary of complaints received and the outcome of each upon request. Redaction of personally identifiable information (PII) is permitted.
  3. Create and maintain records of municipal officers who have taken ethics training. 

Requires every municipality to create processes for investigation and enforcement of alleged violations by ordinance, policy, or rule. 

  • Authorizes the Executive Director of the State Ethics Commission to provide advisory opinions and guidance, upon written request, to municipal officers related to governmental ethics.
  • Requires the Executive Director of the State Ethics Commission to refer any ethics complaints received about municipal officers to the municipality’s ethical liaison for investigation and enforcement by the municipality.
  • Creates a new whistleblower protection for municipal employees that is nearly identical to that which protects state employees. 

Federal regulations require that real or apparent conflicts of interest which may arise in the context of municipal purchases and contracting are addressed. 

If the municipality does not already have a separate conflict of interest policy, it should be addressed in the body of a purchasing policy. See the VLCT model purchasing policy in the Related Links panel (the teal box) on this page. 

Resources