Boost Your Business Ethics with Online Signature Legitimacy in Australia

How to eSign a document: online signature legitimacy for Business Ethics and Conduct Disclosure Statement in Australia

that I know people are in a nice meditative state after our last session so we've made it to the last session for day two which is financial disclosure so I'll try and keep our mood our mood right with this I have the chat open so I'm hoping that um if you guys have questions you can just type in to the chat and I'll just try and answer questions as I go but please feel free to type in the chat so well I'll go back to the Oh wrong page um prior page here this is um the session on financial disclosure statements um final session of the day and during this presentation I'll be explaining uh Financial disclosure statements and the financial disclosure uh statement process um so we'll start on a beautiful April day um and um just imagine it's a spring day and you get an email from either Vega telling you you've been designated as a public filer or your agency's general counsel or ethics counselor telling you you've been designated as a confidential filer what do you do yeah first of all you can consider what a financial disclosure statement is so a financial disclosure statement is an approximately 15 question form designed to obtain financial information from designated District employees public officials candidates for district office and ancs in order to identify and cure Financial conflicts of interest within the district government so if you get an email telling you that you are a filer that means you are someone who is required to file a financial disclosure statement and as this slide discusses it's asking questions about financial information to identify and potentially cure conflicts of interest so you've been designated oh here I have a nope that's not a question it's telling me to ignore something so I'll go ahead and ignore it so you've been designated as a fds filer what do you do next um so first of all do not ignore the email um that's a problem that um we we see a lot actually people are not sure what it means to have been designated as a filer or they're not sure um you know why they've been designated as a Filer and choose to ignore the email that's a mistake because as we'll discuss there are penalties and consequences for not filing oh I get it Nina okay that's exactly right so um our ethics counselors including um Nina on the line uh knows that folks uh do ignore these um emails and that's um what you should not do so if you get an email saying that you are designated as a filer please um uh read on um so first thing you should do is ask yourself if you agree with your designation as a Filer and in the email that you receive where you're designated as a filer Financial disclosure statement filer it should explain why you've been or it should at least explain the criteria for designation um for filers I mean whether or not you're a public filer or a confidential filer uh I'm getting a message saying that um someone cannot hear me or they can't hear anything and so I just want to make sure any if folks can type in the chat if you can hear me I I believe I can be heard at least by some because I gotta email I mean a chat from uh Nina but all right I'm getting a lot of I can hear you all right um so what I'll do is write back to this person and tell them that is probably them all right here we go um sorry about this folks all right so um right so so basically determine whether or not you agree and there is room for your disagreement so if you do disagree there's a process um for that you can follow um to uh basically to to challenge that designation um and um that this process is outlined here so basically within five days of your designation So within five days of whatever April day you get that notification that you've been designated as a filer you should submit something to your re you should submit for your request um for that designation to be reviewed to your agency head um and within five days your agency head should make a redetermination in writing um and redetermination um to me is a little bit confusing because it it kind of suggests that they would be determining something differently they're reviewing their decision to designate you based on the criteria and then they're determining whether or not they believe yes you were rightly designated or actually no we agree you should not have been designated so they would put that decision in writing and for all the agency heads um for all of the agency heads that are on the call or on this training you should describe to the person that's challenging their uh or requesting a review of their designation why um you've determined that they should or should not be designated um after the agency head does their redetermination um any denial of of the relief so basically if the agency said Ted says no I believe you should be uh designated we were right when we designated you you are permitted to appeal that redetermination within five days to the director of government ethics who is Ashley Cooks so if you then basically write a written appeal to our office then our office will review that designation and within five days of your appeal to our office you should get a final decision on whether or not you are um rightly designated as a filer or not and that decision by the director of government office of government ethics is final so if the director determines that you were properly designated as a filer you must file so if Taylor and you agree you need to file by May 15th and if you are um if you go through the process to challenge or request a review of your designation and you're determined to be a filer by Vega then you must file by May 15th May 15th is the magic date for most filers there are different dates for council members but for most DC government employees May 15th is the date that you need to file if May 15th falls on a holiday then you should file by the next business day but your designation email will specify what date you need to file this year I believe it was May 16th because I think May 15th did fall on a holiday but that would have been specified in your um email that designated you and by the way your agency heads and your general counsels are usually sending multiple uh emails so if you ignore the first one and you kind of think it's a junk mail and you get another one then certainly um you know your radar should be going up I'm getting several emails about this let me pay attention let me move these screens out of my way how do I file so now that you've kind of gotten over the I've been designated I have to file kind of portion of the of the process um we can consider how you should file so there are two different types of filers there are confidential filers those confidential filers are a category of employees that make less than a certain amount which your designation will will cover that you don't need to to make that decision on your own the email that you receive from either Vega or your general counsel will or your ethics counselor will let you know what which kind of filer you are so if you're a confidential filer that really means that your filing is confidential and it only goes to your agency head your ethics counselor and so that filing will not be posted it won't be published um it will be um strictly for your agency's review um if you are a public filer then um that uh obviously your your filing will become public um and it will be made public and and that's um for us specifically uh designated and delineated persons um who make over a certain amount but confidential filers currently you would get a pdf version of an fds statement you would complete and sign the form you'd answer every single question all questions 15 questions um you would and then you submit the form to your agency's ethics counselor or your general counsel what's important to do when it comes to filling out these PDF forms is to make sure that you fill out every single question and every single certification so um if you did this um this filing season that's just passed you know that there were multiple certifications um um including a certification that said I completed an Ethics training uh in the past year and then it asked you to name the date that you took that um ethics training so um we are you're basically the point of these uh filings is to determine whether or not there are any conflicts of interest that need to be addressed and and potentially cured um and so all of the answers and all the information is important and so we ask that you fill out all of that information so that your agency's ethics counselors can review for conflicts of interest and then notify you as to any next steps that need to occur notably next year we are going to move to e-filing for confidential filers so that'll be I think a relief for most everyone ethics counselors and the filers alike and then there also won't be as many issues with um um kind of making sure you file complete forms because that's a big issue we have with confidential filers when we're doing Audits and reviews um there's a couple of filers or there's you know always a few filers that are not completing the forms completely um but the e-filing system won't let you submit your form or move on unless you've completed the form completely so that'll be just kind of uh automatic check that we think will be helpful for everyone um and then yeah exactly we got a woohoo because that's a huge Improvement that I know our office is happy to offer for public filers you're basically logging into our e-filing system on our website so once you log into our e-filing system then you'll be kind of moved along um to the actual form so your user login is your work email address and you use your um your works computer password to log in you select your name or your email address select the continue filing button associated with the filing year and you answer all of the questions and complete all the certifications certify and submit now we made a recent Improvement to the e-filing system for Council Members which indicates that which kind of filing period they are filing for um but this is this is the kind of path for how how you would file um it's it's much simpler well it's simpler I won't say much simpler but it's simpler um with e-filing um just because the the system will kind of move you along um if you have problems with the e-filing system then you can feel free to file a ticket um with um our office and we have a program specialist who's really good about answering um questions and kind of navigating folks through technical difficulties uh that they may have and that's certainly possible so If you experience that then by all means please file a help ticket and we'll get to you as soon as possible I would encourage you if you have any technical difficulties and this is going to be for confidential filers next year to file the help ticket immediately so that you have something on record showing that you have attempted to file your form because that's going to be important if it's determined that you didn't get your form in on time something our office looks at is whether or not you actually try to rectify a problem that you are having so don't just log off and give up file the ticket and we'll try and help you as soon as possible to get your filing submitted okay I'm a public filer but I have concerns about answering some of the questions so as I stated the public filers um you're confident your um excuse me your financial disclosure statements are published um for the public to review um it's kind of a part of our government transparency for certain um level of employees and categories of employees that work for the district but we understand that there might be some concerns with answering some of the questions in light of the fact that the information will become public so I'm first by first like to start by saying that fds filing is statutorily required so it's mandatory it's not something that you can opt out of um without some uh process um and if you have concerns about disclosing any of the information that's requested by the questions you must submit a waiver request to our office and you should describe in your waiver request which questions you have a problem with answering and which questions you have concerns about answering and why that is and at that point this is called a partial waiver so partial waiver requesters should submit their requests to our director that's Ashley Cooks um and to counsel to the board who is Lynn Tran and then you should email um our FDX fds inbox so it's Vega Dash fgs dc.gov um and that's the way you would send that request uh the waiver request explaining the reasons for the request um so the waiver request should explain the reasons for the request so if you have safety uh concerned you can say you know I don't want to disclose you know whatever because of um you know some identity theft that I just experienced or whatever your safety or security uh reason is um please describe it um so that uh the folks who are reviewing it can make an informed decision about it um if the partial waiver request is granted then the filer would follow their fds forms per the instructions from our office after the board issues its order so um the board grants these waiver requests it's not um some our director reviews it makes a recommendation but our board is the one who uh kind of the final Arbiter on these requests and so they will either Grant or deny the waiver request um and we will our office will redact um that portion of the form um that has gotten kind of a waiver um so that that information is not public um and um it says the final kind of point is if the board grants a waiver for all 15 questions then the filer will file his or her form confidentially with OGE so obviously if all 15 questions are going to be an issue and and cause a safety issue or security issue then you know we wouldn't post a fully redacted form that would be essentially just file confidentially with our office let me make sure there are no questions okay said you all right you said do not ignore filene's statements um yes so do not I think when I was saying don't ignore I was saying don't ignore uh the emails that you receive I'm telling you that you are required to file your uh Financial disclosure statement uh if I didn't get um your point there um just please feel free to type another question in the chat um someone asked how common is this does vega receive a lot of waiver forms does the board often Grant these waivers um actually I would say no there's not that many waiver requests from public buyers but the few waiver requests that we do receive are often substantiated by uh you know several legitimate facts and so I believe that most if not all of the waivers partial waivers that have been requested have been granted I can say that um the the few that I'm recalling from this last cycle um were uh kind of maybe one to two questions at most um where folks had concerns about and were therefore permitted to um uh waive the public giving up those those answers um but I I would not describe it as many um at all all right let's keep moving sorry folks here we are who do I submit my filing to so um two different two different scenarios public file and confidential filer if you're a public filer using the e-filing system you're submitting your form to Vega when you when you press submit so essentially when you certify and submit that form goes to us and it goes to our office for review and we publish we publicize or publish uh that statement on our website if you're a confidential filer your filing goes to your agency you don't have to give it to Vega Vega doesn't need it your agency is the is the recipient for confidential filers this is huge because so many confidential filers send us their uh fds forms and we don't we don't we're not the first folks who get them your agency gets them now in in the case of an audit our our office might got them or in the case of an investigation for example we could also request them but by and large we're not reviewing confidential fds forums those statements go to your agency head or your agency ethics counselor so that they can make a review and then they might alert us to any potential conflicts and then in that case we might review those those limited forms but we're not reviewing all of the forms from all of the employees from all of the agencies um uh I have an asterisk here saying we develop capacity for all filers to file their forms electronically so next year confidential filers may also be able to submit their forms uh to their agencies electronically so as I already mentioned we're trying to move to e-filing or even confidential filers so hopefully um you know a user function anymore who you send it to and that'll cut down on the number of confidential forms that we receive too because I'll also state that when you submit it to us you really haven't satisfied your obligation under the statute about submitting your confidential form because you didn't submit it to the right agency and so what I tried to do this past cycle was to send an email to all of the confidential filers that sent their forms to our inbox I mean I tried to identify your ethics counselor and then um basically instruct you to submit your form to that person um but next year we're hoping that that um that function will be handled by the e-filing system as well so the May 15th deadline is approaching and I need more time what do I do so this is another biggie because the fds deadline seems to approach very quickly every year so you get that notification in April and then before you know it it's May 15th and you haven't done it or May 15th is coming up and you haven't done your FTS form first let me say this I I think that when people get that notification that they have to file an fds form they think it's going to be a lot more daunting than it actually is it's it's really not that daunting of a form to complete and oftentimes you might find yourself answering negative to most questions that's not the case for everyone so you know I don't want everybody just go in and just start filling out new but you know it's not as daunting as a process um as you might anticipate so you know there I think all of us um well I'll just speak for myself sometimes when you get an email and you have to do something it's going to be daunting you're just like I'll just you know do this tomorrow this this is not that daunting of task it's literally 15 questions and it's all information that you'll know and be able to answer very quickly kind of um off the top of your head you know do you own real property does your spouse own real property yes I do you know you know that that information uh presumably without having to do that much kind of digging and research but if you need more time to file your fds form because you haven't gotten around to it first request an extension and you have to do this by or before the deadline so this year we got a lot of requests by or before May 15th those requests we honored most of those because they gave a legitimate explanation as to why um and I think even the ones that were fairly short in the requests that you know maybe even I need more time if they got it to our office before or by the deadline we were pretty uh gracious and granting extensions to file however if you're asking for the Eileen are you're asking for an extension after the deadline it's less likely that you'll get an extension and you might potentially face uh penalties for late filing so try your best to request that extension by or before uh that May 15th deadline your requests will probably end up with a 30-day extension if it's granted so you you can request an extension of up to 30 days so you'll get till June 15th to answer the fds form and like I said once you open it up and review it and see it um you know I'm sure you could get it done uh fairly quickly um the request for extensions for for um submitting your fds forms should be made to the director of government ethics that's Ashley Cooks it should be in writing and it should show good cause as to why you cannot submit the Forum uh by the deadline so please um you know provide a reason and provide the reason why you're requesting that extension like I said we were very gracious I should say our director was very gracious in in granting those extensions but we would ask that you at least put the reason uh why you're requesting that extension don't forget to answer all the questions that's more for the confidential filers because like I said if you're on that e-filing system it's not going to let you submit it unless you've answered all the questions if you're filling out a PDF form please review it to make sure that you've answered all the questions because it could come back as an unfiled um or you know basically your form doesn't count as being timely filed if you've left out you know answers to too many questions um so take a look at take a look at review prior to emailing that to your ethics counselor or GC and of course if you're a public filer you're getting a notice or a signal that you haven't answered something go back and answer it so that you can submit it successfully um take ethics training delivered or approved by the office of government ethics so um if you're here today and you've been attending this session or any other session I think except for the yoga session um you you can basically get credit for attending an Ethics training but we also have so many other ways to get training we offer training through our learning management system so you can essentially log into our learning management system and take any training on any on basically any ethics topic on demand so it's on your time it's your selection um and you can use that as a way to satisfy your training requirement we also obviously give in person now it's virtual um trainings um so if you're attending any of our annual um excuse me not annual General ethics trainings um those would count and satisfy your fds training requirement and then I believe we still have the PeopleSoft training option as well so there are various methods that you can use but one of the requirements for fds filers is that you receive ethics training if there's a any ethics counselors on here that want to deliver their own training we would just ask that you share the training with our office so that we could review it and determine if it addresses what we think is appropriate to to qualify as a training for these fds filers I think there was one training that we received from a GC or a EC um and it didn't it didn't address fds or conflicts of interest excuse me it didn't address conflicts and interest and so I think we advised for that training that they put in a portion on on conflicts of interest um since that's kind of what the fds um statement is for and that's that's the purpose so um yeah we just like to chime in I guess and and give you some input on any trainings that you develop on your own um but the training does not have to be delivered by Vega it can be delivered by the agencies we just asked for those trains to be shared with us so that we can provide input on that um include any relevant attachments with your filing so um there might be times where you need to attach um some type of documentation to establish um uh something that you've disclosed um you know maybe it's um that you you know did own some some a property or a sun stock or some interest in something that would have been a conflict but you sold it you know in an appropriate time or or whatever it might be and you want to attach that information you can attach that there's there's really no limitation to um the the kind of document uh that you can attach you don't you don't have to attach um anything unless it's I'm going to be helpful to what um to the information that you have shared or disclosed um so for example if you wrote nose to everything you're obviously not you're not required to attach anything um but if you've written something that might allude to uh or suggest that there's a conflict present and you have some documentation that would help establish or inform us as to whether or not that conflict actually exists um yeah go ahead and attach that sign and date your form again this is really geared toward the confidential filers you need to um basically have a you have to sign your form so I think in the current PDF forms um I think it's just uh one signature block actually it's the e-filing system where we have a printed signature and uh electronic signature um but make sure you sign and date the form because that's important for uh whether or not we consider it a full um submission and then of course submit timely because there are penalties and consequences for um not submitting timely um so for example um if you don't submit timely first I'll say that there should be some kind of notice coming from either our office or your agency's ethics counselor informing you that you are late and you need to file your statement because at the very end you're subject to wage garnishment if you're a current employee or fines if you've separated from the government so um we um in the past and historically have fined folks for late filing and approximately 300 plus an administrative fee so it's it's not a small thing and and obviously when folks are find they're alarmed uh by that um and it's a huge um loss you know it's 300 that you know you otherwise would have had in your pocket um and so it's obviously not a good thing so make sure to um to submit complete forms um and um that includes everything from from the signature and the date to answering each of the questions um fully let me see if there are any more questions okay somebody's saying that receiving the forms electronically would be greatly appreciated I agree and I'm glad that that's something that um the office was able to to do um I see hi we've received a lot of confidential filer fds's but many did not disclose spouse info or financial info either they don't understand the question or they don't want to provide the information so if a form um doesn't provide the information requested like I said that form could be considered by your agency and our office as an incomplete form and therefore we wouldn't consider the form to be timely filed um now we would presumably go back to that filer first and inquire after the information that's missing but if the filer does not provide that information and did not seek um um if they were a public filer didn't seek a partial waiver they're required to provide that information as part of your government duties and so they they will be subject to a fine if it's determined that they didn't complete the form and file it so so if that occurs basically the employee is going to be exposed to the the penalties for not filing their fds form so um and I I understand that folks you know feel some kind of way about disclosing um financial information um um and unfortunately you know well I won't say unfortunately but this is a government setting uh where um these conflicts and identifying these conflicts are important um and especially in the confidential setting um you know that the the filer should provide uh the information it's literally not going past your agency unless it comes to Vega um and you know we're we're working basically to address whatever uh conflict exists we're not planning on reaching out to folks's um spouses necessarily or or doing anything related to um you know your family members businesses this is just to identify conflicts and cure them if necessary uh within the government if folks are not understanding the questions um they should definitely you should definitely reach out to us you can call or email us if you have have any question about one of the questions on this on the Forum so if you want to know what kind of information what exactly it's it's asking whether or not you need to disclose particular information that you have please feel free to reach out to us we got a number of emails um this past uh filing cycle and I I believe we were able to answer most everyone's questions so we're here to to help if you don't understand something but don't leave it blank just reach out to us um we have a question how will agencies use the online reporting system for confidential filers will Vega or octo provide technical support will the online system be handled centrally by Vega or octo so I kind of wish that our program manager Stan was on here but I didn't think to invite him as a panelist but he would have been great to give more information on this right now the e-filing system is supported by it's it's a Vega system that's supported by octo and I imagine that the confidential e-filing system will be the same most of the technical support that is required by the users of our program manager is able to provide so confidential filers I believe will just be reaching out to our office in the same way the public buyers are if they have any problem comes with the online system so it'll be any kind of technical support that users need we will be addressing um let's see how will agencies use the online reporting system for confidential filers um and so the the confidential um e-filing system will I believe essentially just feed those forms to or will be able to feed those forms to the individual ethics counselors so if you know we have any problems I guess among ourselves we can we can contact our our own tech support and an octo if they can provide anything but essentially I think everything will be kind of um uh build it through uh our system through US essentially um I hope that answers that question now I have a question saying I'm a general counsel and many employees have asked me if Vega has any concerns will they follow up with an employee after they do a public filing yes um we audit forms made by public filers and if we find that there is a conflict or a potential conflict we will follow up with that employee so for a public filers they should expect to hear from our office if we find that there's any potential conflicts our office does a review of filings and audit of both confidential and public filings to determine whether or not there are any substantive conflicts that need to be addressed so if we do find that there are any conflicts interests concerns we would reach out to the employee um to to kind of investigate um all right I think that's all the questions that I see for now let's see and that is I guess I think I'm a little early um not that early um but if anybody has any other questions uh about the process um feel free to type it in the chat have a couple more minutes um and I'm happy to answer them um but thank you all for attending this uh last session of day two and I hope it was helpful to you all um as I stated if there are any questions um feel free to just type them right in the chat here and I can use the last couple minutes to answer them but of course you can always reach out to us via email our Vega um box is um um Vega wait is it FTS it's Vega Dash fds sorry I always get that mixed up it's vega.ft fds dc.gov um and I monitor that inbox so if you have questions uh regarding your filing um feel feel free to email that box and um I'll respond to you as soon as possible all right it's looking like I'm getting mostly thank yous and of course you all are very welcome um so uh it looks like folks are um logging off but you can of course stay on I'll stay on um because if you're typing a question I get that it could take a little while to get it out so I'll keep staying on but if you want to pop off you can all right I got a question saying how would a conflict of interest typically be resolved or remedied um so the conflict of conflicts of interest you know can obviously you know span an entire Spectrum in terms of type um so you know we might ask for an employee for example to recuse themselves if we find that they um you know are participating in in decisions that um they have that could impact their own Financial interests um personally and substantially we might ask for that written recusal and that might be a way to cure at least future conflicts of interest we might ask for someone to be you know removed from a particular panel or or project in light of their personal financial um uh um affiliations um so so there's there's any it's basically going to be a case-by-case um thing uh where we're just determining what type of conflict exists and um and and how to handle it so you know I gave those two examples it's kind of difficult to determine exactly how it could be resolved or remedied without a a scenario but um essentially we're trying to just eliminate eliminate the conflict uh from existing um in the future if we find that one exists um you know we've we've like explored um whether or not you know many things could pop up from the fds form and so if it looks like somebody has a a full-time job for example we would look into that and just investigate whether or not you know the the two jobs are being performed um um you know outside of government time and and um in within the the permissions of the DPM um so there's there's just a number of ways to address a potential conflict or other type of violation of the code the conduct that is sure foreign all right we're about five minutes till the end of the I think scheduled ending so um about 10 minutes actually I think yeah 3 30. so I'll um go ahead and in in the presentation um but like I said if you want to um send us an email with any questions that you have I'm monitoring the box and so I'll email you as soon as possible I'm in that email address again is here in red it's Vega Dash fds dc.gov so thank you all so much oh foreign