741 Colonel Ledyard Highway

Ledyard, CT 06339

TOWN OF LEDYARD

Administration Committee

Meeting Minutes

http://www.ledyardct.org

Chairman S. Naomi

Rodriguez

Regular Meeting

Wednesday, June 11, 2025

5:30 PM

Town Hall Annex- Hybrid Format

In -Person Location goes here

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601320

CALL TO ORDER

the Meeting was called to order by Councilor Buhle at 5:30 p.m. at the Council Chambers

Town Hall Annex Building.

Councilor Buhle welcomed all to the Hybrid Meeting. She stated for the Town Council

Administration Committee and members of the Public who were participating via video

conference that the remote meeting information was available on the Agenda that was

posted on the Town’s Website - Granicus-Legistar Meeting Portal.

II.

ROLL CALL

Kevin Dombrowski

Jessica Buhle

Present:

April Brunelle

In addition, the following were present:

S. Naomi Rodriguez Town Council Chairman

Christine DiasHuman Resources Director

Deborah EdwardsResident

Roxanne Maher Administrative Assistant

III.

IV.

RESIDENTS & PROPERTY OWNERS COMMENTS

None.

PRESENTATIONS / INFORMATIONAL ITEMS

None.

APPROVAL OF MINUTES

Special Meeting Minutes of May 14, 2025

Moved by Councilor Dombrowski, seconded by Councilor Brunelle

VOTE:

3- 0 Approved and so declared

VI.

OLD BUSINESS

Discussion and possible action to create an Ethics Commission for the Town of Ledyard.

Councilor Buhle stated at their May 14, 2025 meeting that she and Councilor

Dombrowski conducted an extensive review of the proposed “An Ordinance to

Establishing a Code of Ethics and Ethics Commission” and they each provided

suggestions and edits to the document. She stated that both of their suggestions were

included in the May 14, 2024 draft for review this evening. She noted that her

recommendations were identified in pink font; and Councilor Dombrowski’s

suggestions were identified in bule font.

The Administration reviewed the May 14, 2025 draft and discussed the importance

for consistency in the langue and agreed to add the following text noted by the green

front in the June 11, 2025 draft below.

Councilor Buhle’s proposed changes were noted in pink italic font

Councilor Dombrowski’s proposed changes were noted in bule italic font

DRAFT 09/09/2024 6/11/2025 - Admin Cmt

J.Buhle: 5/14/2026

K. Dombrowski 5/14/2025

Ordinance # ______________

AN ORDINANCE ESTABLISHING A TOWN OF LEDYARD

CODE OF ETHICS AND ETHICS COMMISSION

Be it ordained by the Town Council of the Town of Ledyard

Section 1. Authority

In accordance with Chapter III, Section 8 of the Town Charter, there is hereby

established a Town of Ledyard Code of Ethics and Ethics Commission.

Section 2. Declaration of Policy and Purpose

Public Office is a public trust. The trust of the public is essential for

government to function effectively. The proper operation of the town government

requires that public officers, public officials, and public employees be independent,

impartial, and responsible to the people; that governmental decision and policies be

made in the proper channels of governmental structure; that public office and

employment not be used for personal gain; and that the public has confidence in the

integrity of its government.

Therefore, herewith is an established Code of Ethics for all Town Officials,

Town Officers, and Town Employees. The purpose of this code is to establish

standards of ethical conduct for all such officials, officers and employees, and for

those who serve or conduct business with the Town of Ledyard; to assist those parties

under the jurisdiction of the Ethics Commission by establishing guidelines for their

conduct in order to maintain a tradition of responsible and effective public service;

and to establish rules of procedure to be followed by the Ethics Commission in

receiving, adjudicating, and reporting on alleged violations of the Code of Ethics.

Section 3. Applicability

The Ethics Code shall apply to all Town Officials, Town Officers, and Town

Employees, whether elected and/or appointed, paid or unpaid. The Ethics Code shall

also apply to those conducting business with the Town of Ledyard.

Specific portions of this Ordinance shall not be applicable if they conflict in whole or

in part with any the Town Charter, labor agreement, employment contract, or state

statute.

Section 4.

Definitions

As used in this document, the following words or phrases, unless a different

meaning is required by the context or is specifically prescribed, shall have the

meanings indicated:

1. “Persons governed by this Code” means ALL Town/municipal officials, municipal

officers, and municipal employees, whether elected and/or appointed, paid or unpaid.

2. “Business” means any entity through which activity for profit or not for profit is

conducted including, but not limited to a corporation, limited liability corporation,

partnership, proprietorship, firm, enterprise, franchise, association, organization, or

self-employed individual.

3. “Complainant” means any person who signed a complaint under penalties of false

statement alleging a violation of this Code.

4. “Confidential Information” means information, whether transmitted orally or in writing,

which is obtained by reason of the public position of office held, that is not, at the

time of transmission, a matter of public record or public knowledge.

5. “Confidential Investigation” means the examination, prior to the finding of probable

cause, of both written and oral evidence, that is not to be disclosed to any third party

by anyone connected with the investigation, except upon the written request of the

respondent.

6. “Financial Interest” means pecuniary or material benefit accruing to a town

official/employee, spouse or minor child of an officer, official or employee of the

Town as a result of a contract, transaction, zoning decision or other matter which is,

or may be, the subject of an official act or action by or with the Town of Ledyard

except for such contracts of transactions which by their terms and by the substance of

their provisions confer the opportunity and right to realize the accrual of similar

benefits to all persons and/or property similarly situated.

“Financial Interest” shall be deemed to exist if any municipal/Town officer,

member, employee, immediate family of a municipal officer, official or employee

of the Town might, directly or indirectly, derive financial gain or suffer loss from

any purchase, contract, transaction, zoning decision, or other matter involving any

such Town office, board, commission, authority or committee and shall also be

deemed to exist if a business or professional enterprise in which the municipal

officer, employee, member or commission has any financial interest as owner,

member, partner, officer, employee or stockholder or has any other form of

participation which will be affected by the outcome of the matter under

consideration.

1. “Gift” means anything of economic value in excess of $100.00 $25.00, including but not

limited to entertainment, food, beverage, travel, lodging, given or paid.

A gift does not include:

a. A political contribution reported as required by law or a donation or payment as

described in subdivision (9) or (11) of subsection (b) of 9-333b.

b. Services provided by persons volunteering their time.

c. A commercially reasonable loan made on terms not more favorable than loans

made in the ordinary course of business.

d. A gift received from a member of a person’s immediate family or fiancé.

e. Goods or services which are provided to the municipality and facilitate

government actions or functions.

f. A certificate, plaque, or other ceremonial award.

g. A rebate or discount on the price of anything of value made in the ordinary course

of business, without regard to that person’s status.

h. Printed or recorded information germane to government action or functions.

i. An honorary degree bestowed upon a public official or public employee by a

public or private university.

j. A meal provided at an event or business meeting and/or the registration or

entrance fee to attend such an event, in which the public official or public

employee participates in his official capacity.

k. A meal provided in the home by a Ledyard resident.

l. Gift giving occasions recognized by the public, including, Christmas, Chanukah,

birthdays, the birth or adoption of a child, weddings, First Communions,

Confirmations, or Bar/Bat Mitzvahs, provided the total value of such gifts for

each event shall not exceed $100.00 $25.00.

2. “Immediate family” means spouse, child, parent, grandchild, brother, sister, grandparent,

niece, nephew, daughter-in-law, son-in-law, mother-in-law, father-in-law,

sister-in-law, and brother-in-law.

3. “On The Record” means in writing, signed and dated, or a directive to the secretary

taking the minutes of a meeting to note in the minutes of the meeting a special

disclosure or statement.

1. “Personal Beneficial Interest” means any interest, other than financial, which would

affect the action of the official or employee, except if that interest is based solely on

the responsibility of his/her town office or employment. Membership in or affiliation

with a social, fraternal, charitable, service, educational, religious, governmental or

similar non-profit organization is not deemed to automatically create a presumption

of personal interest unless the official employee is also an employee of the

organization.

2. “Probable Cause” is defined by determining whether the facts would warrant a

reasonable person to believe that a Town official, officer, or employee violated this

Code; the belief should be more than mere suspicions, but less than proof beyond a

reasonable doubt.

3. “Respondent” means any person accused of violating this Code.

4. “Town Official, Officer, or Employee” means an individual whether elected or appointed,

whether paid or unpaid, full or part time, including members of boards, commissions,

and committees in the service of the Town of Ledyard.

Section 5. Conflict Of Interest

1. Persons governed by this Code shall not engage in or participate in any business or

transaction, nor have an interest, direct or indirect, which is incompatible with the

proper discharge of that person or persons’ independent judgement or action in the

performance of that person or persons’ official duties.

2. Persons governed by this Code shall not be financially interested or have any personal

beneficial interest, in any contract or purchase order for any supplies, materials,

equipment or contractual services furnished to or used by the board, agency or

commission of which that person or persons is or are an employee(s).

It is further provided, notwithstanding the above, that the Mayor of the Town of

Ledyard, members of the Town Council of the Town of Ledyard, members of the

Board of Education of the Town of Ledyard shall not be financially interested, or

have any personal beneficial interest, either directly or indirectly, in any contract or

purchase order for any supplies, materials, equipment, or contractual services

furnished to or used by any board, agency, or commission of the Town of Ledyard.

A. A Town official, officer, or employee shall refrain from voting upon or otherwise

participating in any matter on behalf of the municipality if he/she, a member of

his/her immediate family, or a business with which the person is associated has a

financial or personal interest in the transaction or contract, including but not limited

to the sale of real estate, material, supplies, or services to the municipality.

If such participation is within the scope of the municipal official’s or municipal

employee’s official responsibility, he or she shall be required to provide written

disclosure, that sets forth in detail the nature and extent of such interest, to the Town

clerk.

Notwithstanding the prohibition in subsection 3(a) 5(A) a Town official, officer, or

employee may vote or otherwise participate in a matter if it involves a determination

of general policy, and the interest is shared with a substantial segment of the

population of the Town of Ledyard.

B. Persons governed by this Code shall not accept or receive, directly or indirectly, from

any person or business to which any contract or purchase order may be awarded by

the Town of Ledyard or any of its boards, agencies, or commissions any money,

rebate, or gifts, or any promise, obligation, or contract for future reward or

compensation.

No Town officials or employees shall accept a gift or engage in private employment

or render services when the gift, employment, or services are incompatible with the

proper discharge of the official duties of the Town official or Town employee, or

could tend to impair independence of judgement or action by the Town official or

Town employee, in the performance of his or her official duties. If a prohibited gift

is offered to a Town official or a Town employee, he or she shall refuse it, return it,

or pay the donor the market value of the gift.

C. To avoid even the appearance of impropriety or creation of a situation that would be

contrary to the declared policy and purpose of this Code, a Town Official or Town

employee, not otherwise restrained by the Code, shall exercise care when appearing

before other Agencies and shall disclose whether he or she is appearing in his or her

official capacity or as a private citizen.

D. Persons governed by this Code who have a financial or personal interest in any

transactions or contract with the Town, including but not limited to the sale of real

estate, materials, supplies, or services to the Town, on which that person or persons

may be called upon to act in that persons official capacity shall not vote or otherwise

participate in the transaction on behalf of the Town. That person (or persons) shall

declare on the record that person (or persons) has or have a conflict of interest.

E. Persons governed by this Code shall not request or permit the use of Town owned

vehicles, equipment, facilities, materials, or property for personal convenience or

profit, except when such are available to the public generally, or provided a

municipal policy for the use of such Town official/employee in the interest of the

Town.

F. No Town official or Town employee shall use his or her position or office and any

confidential information acquired by a Town official or Town employee through his

or her office or position to further such official’s or employee’s personal or financial

interest, or interest of his or her spouse, child, child’s spouse, parent, grandparent,

brother or sister, cousin, niece, nephew, father in-law; mother in-law;

brother-in-law; sister-in-law ;or a business with which the person is associated.

No Town official or Town employee may appoint or hire or participate in influencing

the appointment or hiring of his or her spouse, child, child’s spouse, parent,

grandparent, brother or sister, cousin, niece, nephew, father in-law; mother in-law;

brother-in-law; sister-in-law; or a business with which the person is associated for

any type of employment with the Town, including by contract, unless the contract is

competitively bid. No Town official or Town employee may directly supervise his or

her family member or any business with which the person is associated. No Town

official or Town employee may exercise authority or make recommendations with

regard to personnel actions involving such family member or any business with

which the person is associated.

G. No Town official or Town employee, or a member of his or her immediate family, or

a business with which the person is associated shall enter into a contract with the

Town valued at five hundred (500) dollars or more, other than a contract of

employment as a Town employee, or pursuant to a court appointment, unless the

contract has been awarded through a process of public notice and competitive

bidding.

H. No persons in their capacities as Town official or Town employee shall represent

anyone, other than the Town, concerning any matter before any board, commission,

council, committee, or department of the Town. Nothing herein shall prohibit or

restrict a Town official or Town employee from appearing before any board,

commission, council, committee, or department of the Town on his or her own

behalf, or on behalf of a member of his or her immediate family, or from being a

party in any action, proceeding or litigation brought by or against such Town official

or Town employee to which the Town is a party.

I. No former Town official or Town employee member shall represent anyone for

compensation before any Town board, commission, council, committee, or

department in which he or she was formerly employed at any time within a period of

one (1) three (3) year after termination of his or her service with the Town.

J. No former Town official or Town employee member shall represent anyone other

than the Town concerning any particular matter in which he or she participated

personally and substantially while in Town service.

K. No former Town official or Town employee shall disclose or use confidential

information acquired in the course of and by reason of his or her official duties, for

financial gain for himself or herself or others.

L. No former Town official or Town employee who participated substantially in the

negotiation or award of a Town contract obliging the Town to pay an amount of

twenty-five thousand (25,000) dollars or more, or who supervised the negotiation or

award of such contract shall seek or accept employment with a party to the contract

other than the Town for a period of one (1) three (3) years after his or her resignation

from Town office or position if his or her resignation occurs less than one year after

the contract is signed.

M. Willful violation by any such officer or employee of the provisions of this Code shall

be grounds for his/her removal in accordance with Chapter IX, Section 6 of the Town

Charter. Violation of this section with the knowledge, express or implied, of any

person

N. Willful violation by any such officer or employee of the provisions of this Code shall

be grounds for his/her removal in accordance with Chapter IX, Section 6 of the Town

Charter. Violation of this section with the knowledge, express or implied, of any

person or corporation participating in such contract, transaction, or decision shall

render the same voidable by the Town Council, or by a court of competent

jurisdiction.

Section 6. Disclosure of Interests Required

A. Any officer, official or employee who has a private financial interest in any action,

legislative or otherwise, by any Town agency and who is a member of, participates

in discussion with or gives an official opinion to such Town agency shall disclose

on the written records of such agency the true nature and extent of such interest.

This section shall not apply to:

1. Contracts awarded to the lowest responsible bidder after public

advertisement.

2. Unpaid appointed officials during a declared state of emergency.

3. Matters requiring disclosure to or approval by a court.

4. The Town Attorney, Town Engineer or similar Official, who is participating in

or offering an opinion on behalf of said agency, and whose financial

interest is merely in being paid for such services.

B. Every elected official, excluding Justices of the Peace shall, on or before January 1

each year, file with the Town Clerk, on a form to be prepared by the Town

Attorney, a statement, under oath, containing the following information:

1. All real estate located within the Town of Ledyard owned by such elected

official or held under a lease for a term exceeding five years, excluding,

however, his or her principal residence. The foregoing shall also apply to

real estate owned or leased, as aforesaid, by a corporation, trust or

partnership in which any such elected official is the legal or equitable

holder of at least 5% of the legal or equitable interests in said corporation,

trust or partnership.

1. The names of any firm, proprietorship, partnership, or corporation of which

said elected official is an employee or in which such elected official holds at

least a five-percent interest, and which firm, proprietorship, partnership,

corporation, or limited liability corporation has sold or supplied goods or

services in excess of $10,000 per annum to the Town of Ledyard during the

two years immediately preceding such official's election to office.

3. Any income, fees, salary, or wages directly or indirectly received by such

elected official from the Town of Ledyard or its political subdivisions

during the two years immediately preceding such official's election to

public office.

Section 7.

1. Purpose

Establishment Of An Ethics Commission

An Ethics Commission is hereby established to investigate specific charge(s)

and complaints concerning allegations of violations of this Code under this ordinance as

identified and assigned by the Town Council and/or the Mayor.

CONTINUE

RESULT:

The Ethics Commission shall be comprised of five (5) regular members and two (2)

alternates of whom shall be electors of the Town. No member shall hold or campaign for

any public office, hold office in any political party, serve as an officer of any other Town

Committee, Commission, and Board, or be part of the immediate family of any Town

official and Town employee. Political minority rules shall apply for the membership of

this commission.

The Regular Members shall include:

At least one member with Legal background (attorney, paralegal)

· At least one member with Financial background.

· Three Members from the Community-at-Large

No more than two (2) Regular Members may be affiliated with any one political

party. Both Alternate Members may not be affiliated with the same political party. At

least one Regular Member and one Alternate Member shall be registered as an

unaffiliated.

Minority Representation shall apply separately to each of the subsets: Regular

Members and Alternate Members.

Members will serve without compensation except for authorized expenses in conjunction

with their duties.

Members and alternate members must be residents of the Town of Ledyard. No

member or alternate member shall:

A. Be a public official or public employee of the municipality; or an

official; or employee of a quasi-public agency of the municipality.

B. Have held any Town or State Office for a period of one-year two years

prior to being appointed to the Commission.

C. Hold office in a political party or political committee.

Serve as a member of another agency

E. Hold or campaign to seek any Town Office.

F. Have been employed by the Town for a period of one-year two years prior to

being appointed to the Commission.

G. Serve as an officer member of any other Town Committee,

Commission, and or Board, or be part of the immediate family of any Town

official or Town employee.

H. Have any beneficial interest or financial interest in matters before the

Town or the Board of Education.

I. Have been found in violation of any federal, state, municipal or

professional code of ethics.

Members will serve without compensation except for authorized expenses in

conjunction with their duties.

3. Terms of Appointment

Members shall be appointed by the Town Council for a term of three (3) years and shall

commence to serve their terms immediately upon appointment and shall serve until their

successor has qualified or are removed by the Town Council.

In making the original appointments under this ordinance, the Town Council shall

designate two (2) regular members to serve for three (3) years, two (2) regular members

to serve for two (2) years; one (1) regular member to serve for (1) year; one (1) alternate

member to serve for three (3) years and one alternate member to serve for two (2) years.

Thereafter, vacancies shall be filled for a three (3) year term.

Inaugural members shall be eligible to serve two (2) additional three (3) year term

beyond his/her initial appointment.

Any vacancy on the Commission, other than by expiration of term, shall be filled for the

unexpired portion of the term by the Town Council with priority given to maintain the

structure above.

The Town Council may remove members for cause and fill the vacancy per Chapter III,

Section 6 of the Town Charter.

Cause for removal shall include, but is not limited to, unexcused absence from three (3)

consecutive meetings. It shall be the responsibility of the Chairman of the Commission

to notify the Town council when a member has not properly performed his/her duties.

Within thirty (30) days of the appointment of this Commission, an Organization Meeting

of said Commission shall be held at which members shall choose a Chairman,

Vice-Chairman, and a Secretary. Any vacancy in any such office shall be filled by from

its regular membership.

4. Authority/Duties

The Town of Ledyard Ethics Commission shall be authorized to perform the following:

Review assignments and determine whether or not the Ethics Commission would

have jurisdiction, if the allegation(s) is true, and if it would be a violation of this

Code.

· Consult with the Town Attorney or an Attorney, and other professionals specially

appointed by the Town Council to conduct its duties on assignments, as authorized

by the Town Council on a case-by case-basis.

· Request the Attorney provide advisory opinions with regard to the requirements of

this Code pertaining to the subject assignment. Advisory opinions rendered by the

Town Attorney, until amended or revoked by the Ethics Commission, shall be

binding and shall be deemed to be final decisions.

· Conduct hearings and issue subpoenas or subpoenas pursuant to Sections

7-148(c)(10)(B) of the Connecticut General Statutes.

· Compile and maintain a record with the Town Clerk of all reports, advisory opinions,

statements, and memoranda filed by and with the Commission to facilitate public

access to such reports and statements unless doing so would violate the

confidentiality provision of this Code or is otherwise prohibited by law.

· Report to the Town Council when an investigation is complete, and a

decision is rendered.

· Annually report to the Town Council on the status of investigations, while

maintaining confidentiality as applicable; summarizing the activities of the

commission.

· Agendas and Minutes of the Ethics Commission, not including those protected by

confidentiality, are public information and will be made available to the public

through the Town’s meeting portal and the Town Clerk’s Office in accordance with

Sections 1-200, 1-225 of the Connecticut General Statutes. Executive session

discussion will be confidential.

5. Procedures

a. Filing of Complaints

Complaints of violation of the code of Ethics related to unethical behavior concerning

any municipal official, officer, or employee of the Town of Ledyard may be made by any

person and shall be made in person on a form prescribed by the Commission and signed

under penalty of false statement before the Ledyard Town Clerk; or Assistant Town

Clerk. one of the following

1. A judge of a court of record

2. A clerk or a deputy clerk of a court having a seal;

3. AThe Ledyard Town Clerk (Moved to above paragraph);

4. A public notary;

5. An attorney admitted to the bar of this state

6. A justice of the peace

No complaint may be made under the code unless it is filed with the Commission within

three (3) four (4) years after the violation alleged in the complaint has been committed,

and within six (6) months of discovery. If multiple violations are alleged, the four (4)

three (3) year limitation shall be applied separately to each such alleged violation.

The Complaint shall include:

· Name of the person accused (respondent).

· Name of the person filing the complaint.

· The specific acts alleged to constitute the violation of Section 4 of this code, and

when they occurred.

· Whether or not these allegations have been presented to other administrative or

judicial authorities.

The Town Clerk within ten (10) business days shall provide proper notice to the Town

Council and Mayor that an Ethics Compliant has been filed The Town Council or

Mayor shall, within ten (10) business days of receiving complaint, forward the specific

charge(s) and complaints concerning allegations of violations of this Code under this

ordinance to the Ethics Commission under the heading of “Confidential Materials”;

pursuant to Section 1-82a of Connecticut General Statutes..

In the application of this Code of Ethics, care will be given to distinguish

between concerns of management of Town employees and violations of the public

trust. The daily management of employee performance is the responsibility of the

Mayor or School Superintendent in the case of the employees of Ledyard Public

Schools. Personnel policies should be the first guide in those areas where applicable.

Similarly, the routine activities of the Commission should be governed by its rules and

regulations.

b. Evaluation and Acknowledgement

i. Within thirty (30) business days of the receipt of the specific charge(s) and/or

complaints, the Ethics Commission shall call an executive meeting session to

evaluate if the filing is not in violation or is not in the proper form.

ii. If the complaint is not in the proper form and/or the Ethics Commission determines

that the allegations, even if true, would not constitute a violation of this Code

then the Ethics Commission shall dismiss the complaint and duly notify the

complainant in writing, with a copy to the Town Council, and Mayor of said fact

and the reasons thereof; by registered or certified mail not later than ten (10)

business days after said decision. Allegations applicable to other administrative,

or judicial authority will be referred to the proper authority.

iii. If the Ethics Commission determines that the complaint is in proper form and the

allegations, if true would, constitute a violation of this Code then the Ethics

Commission shall, not later than ten (10) business days after said determination,

provide a copy of the complaint provide a copy of the complaint to the Town

Council, Mayor and by registered or certified mail to all respondents against

whom such complaint is filed, and shall provide notice of the receipt of such

complaint to the complainant. The respondent(s) shall have ten (10) business days

to submit any response to the Ethics Commission.

i. If the Complaint is applicable to this Code, the Town Council shall request the Ethics

Commission convene an executive session meeting within fourteen (14) business

days of the issuance of notification to the complainant.

b. Investigation of Probable Cause-Confidential Investigation

All information supplied to or received from the Ethics Commission during their

evaluation or investigation shall remain confidential, as specified by provisions of the

Connecticut General Statutes, Section 1-82a, in relation to operations of a Commission

of Ethics, unless the Commission makes a finding of probable cause for a hearing, or

unless the respondent requests in writing that the entire record and any hearings be open

to the public.

The Ethics Commission shall within thirty (30) business days from the receipt of the

assignment evaluate the complaint to determine whether the person who is the subject of

the complaint is under the jurisdiction of the Ethics Commission; whether the act(s)

alleged in the complaint, if proven, would constitute a violation of the Code.

If the Ethics Commission accepts jurisdiction, it shall so advise both the complainant and

respondent by certified mail and provide a copy of the complaint (and any other

information submitted by the complainant) to the respondent The Ethics Commission

shall advise that complainant and the respondent by certified mail that it will conduct a

probable cause determination and invite the respondent to provide any information the

respondent deems relevant to the Commissions determination of probable cause. Such

information must be submitted to the Commission within twenty-one (21) business days

of notification.

Within thirty (30) business days after the response period specified in the previous

paragraph, the Ethics Commission shall meet in an executive session to determine if

there is probable cause that a violation of the Code has occurred. In so doing, the Ethics

Commission shall only consider the information submitted by the complainant and the

respondent.

If the Ethics Commission does not find probable cause of a violation of the Code, it

shall so notify in writing both the complainant and the respondent within five (5)

business days of its findings and a summary of the reasons and the complaint, and the

record of investigation shall remain confidential. Upon a finding of no probable

cause, the case file will be sealed and all matters pertaining thereto shall remain

confidential.

The Highlighted Sentences are redundant- I think the two paragrphs can be

combined into one paragraph as noted in red font below:

If the Ethics Commission determines, by four (4) three (3) affirmative votes that there is

probable cause of a violation of the code, it shall so notify both the complainant,

respondent; Town Council and Mayor in writing within five (5) business days of such

determination.

If the Ethics Commission determines that probable cause of a violation of the Code has

occurred, the Town Council will authorize the Ethics Commission to perform an

investigation. An investigation shall be conducted within (90) business days of

determining the complaint is in violation of this Code.

Substitute with the Paragraph below:

If the Ethics Commission determines, by four (4) affirmative votes that there is

probable cause of a violation of the code, it shall notify the complainant, respondent;

Town Council and Mayor in writing within five (5) business days of such

determination. The Town Council will authorize the Ethics Commission to perform

an investigation. An investigation shall be conducted within (90) business days of

determining whether the complaint is in violation of this Code.

If the Ethics Commission determines, by three (3) affirmative votes that there is probable

cause of a violation of the code, it shall so notify both the complainant and respondent in

writing within five (5) business days of such determination.

Within thirty (30) business days of a finding of probable cause, the Ethics Commission

shall schedule a hearing to determine if a violation of the Code has occurred if the

allegations are true. The Ethics Commission shall notify both the complainant and the

respondent of the date, time, and place of such hearing. Such notification shall be made

in writing within five (5) business days of the scheduling of the hearing.

All notifications under this section shall be sent via certified mail, return receipt

requested.

If the Ethics Commission determines that probable cause of a violation of the Code has

occurred, an investigation shall be conducted within (90) business days of determining

the complaint is in violation of this Code.

In the conduct of its investigation, the Ethics Commission shall have the power to hold

hearings, administer oaths, examine witnesses, receive oral and documentary evidence,

subpoena witnesses, and to require the production for examination by the Commission of

any books and papers as permitted by law which are relevant in any manner under

investigation or in question.

All parties and witnesses shall be duly sworn under oath prior to testifying before the

Commission.

During the investigation, the complainant shall be allowed to present evidence, including

documents and witnesses. The respondent(s) shall have the right to appear and be heard

and offer any information which may tend to clear the respondent of probable cause to

believe that the respondent has violated any provision of the Code of Ethics. The

respondent shall be allowed to present evidence, including documents and witnesses. The

respondent shall be allowed to examine and cross-examine witnesses presented and be

allowed to offer before the Ethics Commission any evidence or witnesses on their behalf.

This investigation shall be confidential pursuant to Connecticut General Statutes, Section

1-82a.

i. No probable cause

If the Ethics Commission finds no probable cause it shall within five (5) business

days advise the complainant and the respondent of its finding and a summary of the

reasons therefore and the complaint and the record of investigation shall remain

confidential.

ii. Probable cause

If the Ethics Commission finds probable cause by the concurring vote of three (3) out

of five (5) voting members, it shall within five (5) business days of such

determination notify both the complainant and the respondent in writing.

Within thirty (30) days of finding of probable cause, the Ethics Commission shall

schedule a hearing to determine if a violation of the Code has occurred. The Ethics

Commission shall notify both the complainant and the respondent of the date, time,

and place of such hearing. Such notification shall be made in writing within five (5)

business days of the scheduling of the hearing.

It shall also fix a date for a hearing on a complaint. It shall give notice of that date to

the complainant and respondent. Such date shall be not less than thirty (30) business

days following notice, nor more than ninety (90) business days after the finding of

probable cause.

b. Hearings

The Ethics Commission shall conduct a hearing to determine if a violation of the

code has occurred. Confidentiality of complaints, evaluations of possible violations,

and investigations shall be maintained pursuant Section 1-82a of the Connecticut

General Statute. Unless a judge trial referee makes a finding of probable cause, a

complaint alleging a violation of this part shall be confidential except upon the

request of the respondent All hearings shall be opened to the public and recorded in

a manner to be determined by the Ethics Commission.

Hearings shall not be subject to rules of court, except the rights:

i. Of an accused to confront and cross-examine his/her accuser.

ii. Of every witness or party to be represented by an attorney at law of his/her

Choice.

iii. Of every witness to decline to answer questions in accordance with the Fifth

Amendment to the Constitution of the United States.

In all other respects, hearings shall be conducted by the Ethics Commission, with the

advice and assistance of the Town Attorney acting through its Chairperson, in order

to facilitate the prompt and fair disposition of the proceedings.

While conducting a hearing of an alleged violation of this Code, the Ethics

Commission shall have the authority to administer oaths, examine witnesses, receive

oral and documentary evidence.

The Ethics Commission shall have the authority to issue subpoenas or subpoenas

duces tecum enforceable upon application to the Superior Court for the State of

Connecticut, to compel attendance of persons at hearings and the production of

books, documents, records, and papers, pursuant to Sections 7-148(c)(10)(B) of the

Connecticut General Statutes, subject to the inherent power of the commission to

decline or limit such request where it is merely duplicative or is unnecessarily

burdensome or harassing and not likely to lead to evidence which will aid the

Commission in its determination.

b. Finding/Sanctions

No finding of violation of this Code shall be made except upon concurring the vote of

five (5) four (4) out of five (5) members of the Ethics Commission. The

Chairperson shall render the finding of the Ethics Commission within thirty (30)

business days after conclusion of the hearing. A copy of the finding shall be sent to

the complainant, respondent, Town Council, and Mayor.

A copy of the finding shall be sent to the complainant, respondent, and the Town of

Ledyard.

Upon finding of a violation of any provision of the Code, the Ethics Commission will

refer the matter to the appropriate appointing or supervisory authority. The authority

affected will report within thirty (30) business days to the Ethics Commission the

action taken, if any. Violators of the Code of Ethics are subject to penalties that may

consist, but not limited to, any one or a combination of the following: of an order

to cease and desist the violation, to pay a civil penalty of up to the maximum allowed

per state law per violation, censure, reprimand, suspension without pay, termination

of employment and/or removal from appointed office. Additionally, the commission

may refer violators to the proper authorities for further civil or criminal action. If the

commission finds unethical conduct by a paid consultant or business performing

work for the Town, it can disbar the consultant or business from doing business with

the Town for up to 10 years.

1. Order to cease and desist the violation which must be enforced by a court of

competent jurisdiction.

2. Pay a civil penalty of up to the maximum allowed per state law per violation.

3. Public admonition or reprimand.

4. Censure.

5. Suspension without pay.

6. Demotion.

7. Termination of employment and/or removal from appointed office.

8. Restitution of any pecuniary benefits received because of the violation

committed.

The Town Council may prescribe penalties for violation of this Ordinance, as

authorized in CGS 7-479, including the avoidance of any municipal purchase,

contract, or ruling adopted in contravention thereof. In the case of an Ethics

violation by a member of the Town Council, the Ethics Commission will prescribe

the appropriate penalty(s) as permissible under the Law, and its decision will be

binding upon said Town Council Member, after appeal.

Persons subject to this code found not to be in violation of this code will be

reimbursed by the Town of Ledyard for their reasonable legal fees, except no legal

fees shall be paid for any services rendered before a finding of probable cause.

b. Appeals

Any person aggrieved by any final decision of the Ethics Commission may appeal

such decision in accordance with the provisions of Sections 4-175 or Section 4-183

of the Connecticut General Statutes. If successful, any and all reasonable legal fees

will be paid by the Town of Ledyard.

b. Interpretation

The provisions of this ordinance shall be construed in a manner consistent with all

applicable federal and state laws, and applicable to the provisions of the Charter of

the Town of Ledyard. In the event a conflict exists between this ordinance and a

federal or state law, or the Charter of the Town of Ledyard, the federal or state law,

or the Charter shall control.

Section 8. Severability

If any part of this Code or Ordinance shall be held by a court of competent

Jurisdiction to be invalid, such holding shall not be deemed to invalidate the remaining

provisions hereof.

Adopted by the Ledyard Town Council on:____________

__________________________

S. Naomi Rodriguez, Chairman

Approve/Disapprove on:________

________________________

Fred B. Allyn, III, Mayor

Continued Discussion: Councilor Buhle stated that she appreciated all of their

recommendations and suggestions noting that with tonight’s work that she thought that they

had a good draft. She asked Administrative Assistant Roxanne Maher to incorporate the

additional changes they agreed to this evening into the proposed draft “An Ordinance

Establishing an Ethics Commission for the Town of Ledyard.

The Administration Committee noted that they were satisfied with the additional revisions

they incorporated this evening. They agreed that after Administrative Assistant Roxanne

Maher updated the proposed Ordinance that Councilor Buhle would review the document to

ensure all changes have been included. With Councilor Buhle’s review and verification, she

would ask Ms. Maher to forward the proposed “An Ordinance Establishing an Ethics

Commission for the Town of Ledyard” as contained in the draft dated June 11, 2025 to the

Town Attorney for their legal review and recommendations.

Discussion and possible action to draft a resolution establishing a Sustainable CT Ad-hoc

Committee.

Councilor Buhle noted the Administration Committee has been discussing the draft

“Resolution Supporting the Town’s Continued Participation in the Sustainable CT

Municipal Certification Program And Establishing A Sustainable CT Ad Hoc Committee”

dated March

27, 2025. She stated in thinking about her conversation with Land Use Director/Town

Planner Elizabeth Burdick about having the Committee be comprised of Town Employees

that she had concerns about the town’s limited staffing and not wanting to overload staff

with additional work. Therefore, she suggested the Committee be comprised of the

following:

One member from the Planning & Zoning Commission or Inland Wetlands & Water

Courses Commission

One member from the Economic Development Commission or Conservation

Commission

One member from the Town Council Land Use Committee

Two members from the Community-at-Large

Councilor Buhle went on to note as currently written in the March 27, 2025 draft the

proposed Resolution already named the Director of Land Use & Planning as the Town’s

contact person for the Sustainable CT Municipal Certification process and authorizes

him/her to complete Municipal Registration on behalf of the Town of Ledyard.

The Administration Committee discussed the Sustainable CT Ad Hoc Committee’s

Membership and agreed with Councilor Buhle’s suggestions, as noted in the draft dated June

11, 2025 below, not to overburden staff and to ask members that were currently serving on

other Town Committees/Commissions to volunteer to take on the Sustainable CT initiative.

MOTION to recommend the Town Council adopt the proposed “Resolution Supporting

the Town’s Continued Participation in the Sustainable CT Municipal Certification Program

And Establishing A Sustainable CT Ad Hoc Committee” as contained in the draft dated June

11, 2025

DRAFT: 3/27/2

DRAFT: 6/11/2025

TOWN OF LEDYARD

RESOLUTION SUPPORTING THEIR CONTINUED PARTICIPATION

IN THE SUSTAINABLE CT MUNICIPAL CERTIFICATION PROGRAM

AND ESTABLISHING A SUSTAINABLE CT AD HOC COMMITTEE

WHEREAS, On March 11, 2020 the Ledyard Town Council adopted a “Town of Ledyard

Resolution Supporting the Participation in the Sustainable CT Municipal Certification

Program”; recognizing that Sustainable CT is a comprehensive, statewide, action-oriented

voluntary certification program, built by and for municipalities, with the vision that:

“Sustainable CT communities strive to be thriving, resilient, collaborative, and

forward-looking”.

WHEREAS, Sustainable CT is designed to boost local economies, help municipal

operations become more efficient, reduce operating costs, and provide grants and additional

support to municipalities.

WHEREAS, the Town of Ledyard continues to embrace an ongoing process of working

toward greater sustainability, selecting which actions it chooses to pursue from the voluntary

menu of actions provided by Sustainable CT; and WHEREAS; The Town of Ledyard has

implemented a number of programs which included a streetlight assessment that resulted in

the purchase of the streetlights from Eversource and converting them to Light-Emitting

Diode (LED) light bulbs saving both energy and taxpayer dollars; constructed the Multi-Use

Pathway from Ledyard High School to Ledyard Center to expand safe, connected, active

transportation for pedestrians and bicyclists; extending the sewer line providing

infrastructure for both affordable housing and business development; improvements to the

Linda C. Davis Food Pantry providing an equitable community food action plan to ensure

that all community members can access sustainable, nutritious food; improvements to the

Town Green providing handicap access to one of the best Farmers’ Markets in the State for

residents to purchase fresh produce from local farmers and featuring many community

organizations providing information to residents regarding fuel assistance, mental health

services, public safety services, and many other commodities and programs; regionalization

of shared services with the Town of Preston by providing Emergency Dispatch

Communication Services, Tax Assessor Services, Public Works Mechanic Services, and the

shared purchase of a streetsweeper to maintain the required MS4 (Municipal Separate Storm

Sewer System) Permit Certifications.

WHEREAS, the Director of Land Use & Planning is authorized to serve as the Town of

Ledyard’s Sustainable CT contact person for the Sustainable CT Municipal Certification

process and authorizes him/her to complete Municipal Registration on behalf of the Town of

Ledyard;

WHEREAS: it is recognized that the town is minimally staffed; and supplemental support is

needed to continue efforts to reach the Sustainable CT Goals of the community.

NOW, THEREFORE, BE IT RESOLVED, that to focus attention and effort within the Town

of Ledyard on matters of sustainability, and in order to promote local initiatives and actions

toward Sustainable CT Municipal Certification, the Ledyard Town Council establishes a

Ledyard Sustainable CT Ad Hoc Committee to be comprised of seven five (5) members

appointed by the Ledyard Town Council.

Those members shall, as much as possible, be representative as follows:

One member from the Planning & Zoning Commission or Inland Wetlands & Water

Courses Commission

One member from the Economic Development Commission or Conservation

Commission

One member from the Parks, Recreation, & Senior Citizens Commission

One member from the Board of Education

One Member from a Community Organization (i.e. Rotary, Lions Club, etc.)

One member from the Town Council Land Use Committee

Two One member from the Community-at-Large

BE IT FURTHER RESOLVED, each member shall serve for a term of two (2) years.

Members shall commence to serve their terms immediately upon appointment and shall

serve until their successor has qualified or they have been reappointed or removed by the

Town Council.

Any vacancies on said committee shall be filled by the appointment of the Ledyard Town

Council, with priority given to maintaining as much as possible the structure above; and

Any member of the Committee who is absent from three (3) consecutive regular

meetings and any intervening duly called special meetings shall be considered to have

resigned from the Commission and the vacancy shall be filled as hereinbefore provided,

except that the Commission may vote to waive the requirements of the section in each case

where illness or other extenuating circumstances make it impossible for a member to meet

the attendance requirements of this action. It shall be the responsibility of the Chairman of

the Committee to notify the Town Council when a member has not properly performed

his/her duties.

BE IT FURTHER RESOLVED, that said Ledyard Sustainable CT Ad Hoc Committee is

authorized to:

(1).

Work with the Land Use Director and the Mayor to engage staff; and or, contract

with consultants, or a Sustainable CT Fellow through Southeastern Connecticut

Council of Government (SCCOG) Program.

(2).

(3).

Review the Sustainable CT Tool Kit and Guidelines; and to oversee the preparation

and submission of Application at the appropriate time.

Develop initiatives, goals, and recommendations to achieve Points required to

complete the process to obtain the Sustainable CT Certification to include:

Building our community and our local economy;

Equitably promote the health and well-being of current and future residents;

Encourage and participate in regional collaboration and other forms of partnership.

Improve the services and quality of life for our residents, while focusing on

sustainability, efficiencies, and reducing the impact of inflationary costs for

residents.

(4).

(5).

(6).

Work with the Public Works Director on Food Waste Composting and other waste

management initiatives.

Work with the Planning & Zoning Commission to ensure the Town’s Plan of

Conservation and Development supports the proposed Sustainable CT Initiatives.

Work with the Board of Education to ensure that Ledyard’s educational facility

needs are considered and met in developing a plan and implementing Sustainable CT

initiatives.

(7).

Prepare and present to the Town Council for approval a Capital Improvement Plan to

support and move the Sustainable CT Plan forward.

(8) Identify funding sources, including grant funding, and other grassroots funding options

such as In Our Backyard (IOB) Grants, to support the goals and initiatives;

complying with the town’s Grant Policy.

(9) Work with the Finance Director on the application and administration of any grant

funding received; and the preparation of bid specifications and advertisement for

Requests for Proposals to facilitate approved Sustainable CT Initiatives, in

accordance with Ordinance #200-001 “Purchasing Ordinance for the Town of

Ledyard”.

RESOLVED, that the first meeting of the Sustainability CT Ad Hoc Committee must be

held within 90 days of passing this resolution and that the Sustainability Ad Hoc Committee

shall meet as frequently as needed, but no less than quarterly; and shall select a Chairman,

Recording Secretary, and Fiscal Officer from its body.

RESOLVED, that the Sustainability Ad Hoc Committee shall report annually to the Ledyard

Town Council on the progress of its activities toward the Sustainable CT Certification, with

reports and presentations being publicly available.

NOW, THEREFORE, BE IT FURTHER RESOLVED, that the adoption of this Resolution

reaffirms the Town of Ledyard’s March 11, 2020 initial desire and commitment to continue

their work in achieving the Sustainable Development CT Certification.

Adopted by the Ledyard Town Council on: ____________

_____________________________

S. Naomi Rodriguez, Chairman

**************************************************************************

The above is a certified a true copy of a Resolution adopted by the Town of Ledyard at a

meeting of its Town Council on ___________, 2025 and which has not been rescinded or

modified in any way whatsoever.

IN WITNESS WHEREOF: The undersigned has affixed his signature and corporate seal on

this __________day of ___________ 2025.

_______________________________

Patricia A. Riley, Town Clerk

(SEAL)

**************************************************************************

Revision: “Town of Ledyard Resolution Supporting the Participation in the Sustainable CT

Municipal Certification Program” Adopted: March 11, 2020

History:

Due to other competing demands on staff the Town of Ledyard was unable to continue their

Application process to obtain the Sustainable CT Certifications. However, the Town has

continued to take on and has completed a number of initiatives that have contributed to

building its community and our local economy; to equitably promote the health and

well-being of current and future residents; and has developed, fostered and participated in

regional collaboration and other forms of partnership with other communities in the area.

The 2025 adoption of this Resolution reaffirms the Town of Ledyard’s desire and interest to

achieve the Sustainable CT Certification to continue to improve the services and quality of

life for its residents, while focusing on sustainability, efficiencies, and reducing inflationary

costs for its residents.

Moved by Councilor Buhle, seconded by Councilor Dombrowski

Discussion: (see above).

\VOTE: 3 - 0 Approved and so declared

RECOMMENDED FOR APPROVAL

Jessica Buhle

RESULT:

MOVER:

Kevin Dombrowski

SECONDER:

Dombrowski, Buhle and Brunelle

AYE:

Any Old Business proper to come before the Committee.

VII. NEW BUSINESS

MOTION to reappoint Mr. Ethan Foltz (D) 894 Colonel Ledyard Highway, Ledyard, as a

regular member of the Ledyard Farmers’ Market Committee, for three (3) year term ending

May 9, 2028.

Moved by Councilor Dombrowski, seconded by Councilor Brunelle

Discussion: The Administration Committee noted that all of the members of the Farmers

Market Committee do an amazing job.

VOTE:

3 - 0 Approved and so declared

RECOMMENDED FOR APPROVAL

Kevin Dombrowski

RESULT:

MOVER:

April Brunelle

SECONDER:

Dombrowski, Buhle and Brunelle

AYE:

MOTION to reappoint the following Members to the Parks, Recreation & Senior Citizens

Commission for a three (3) year term ending June 28, 2028.

Ms. Lauren Hawes, (U) 8 Wabler Way, Gales Ferry, as an Regular Member

Ms. Paula Crocker (U) 1500 Route 12, Gales Ferry, as a Regular Member

Ms. Stephanie Bacon (D) 6 Patricia Court, Gales Ferry, as an Alternate Member.

Moved by Councilor Brunelle, seconded by Councilor Dombrowski

Discussion: These members of the Parks, Recreation & Senior Citizens Commission are

interested in continuing to serve on the Commission, and their reappointment has been

endorsed by the Commission and their respective parties.

VOTE:

3 - 0 Approved and so declared

RECOMMENDED FOR APPROVAL

April Brunelle

RESULT:

MOVER:

Kevin Dombrowski

SECONDER:

AYE:

Dombrowski, Buhle and Brunelle

MOTION to approve Mechanic II job description as presented in the draft dated May 16,

2024.

Moved by Councilor Dombrowski, seconded by Councilor Brunelle

Discussion: Human Resources Director Christine Dias explained that the Mechanic II

was a new job description that was added to provide the shared services support to

Preston. She noted that the individual was hired under a draft job description.

VOTE:

3 - 0 Approved and so declared

RECOMMENDED FOR APPROVAL

Kevin Dombrowski

RESULT:

MOVER:

April Brunelle

SECONDER:

Dombrowski, Buhle and Brunelle

AYE:

MOTION to approve proposed updates to Fiscal Assistant II Finance Department position as

presented in the draft dated February 19, 2025.

Moved by Councilor Brunelle, seconded by Councilor Dombrowski

Discussion: Human Resources Director Christine Dias explained Fiscal Assistant II

Finance and Human Resources job description has been updated to reflect the current

duties of the position.

VOTE:

3 - 0 Approved and so declared

RECOMMENDED FOR APPROVAL

April Brunelle

RESULT:

MOVER:

Kevin Dombrowski

SECONDER:

Dombrowski, Buhle and Brunelle

AYE:

MOTION to approve proposed updates to the Fiscal Assistant II Finance and Human

Resources job description as presented in the draft dated November 15, 2023.

Moved by Councilor Dombrowski, seconded by Councilor Brunelle

Discussion: Human Resources Director Christine Dias explained Fiscal Assistant II

Finance job description has been updated to reflect the current duties of the position.

VOTE:

3 - 0 Approved and so declared

RECOMMENDED FOR APPROVAL

Kevin Dombrowski

RESULT:

MOVER:

April Brunelle

SECONDER:

Dombrowski, Buhle and Brunelle

AYE:

MOTION to approve proposed updates to the Assistant to the Tax Collector Job Description

as presented in the draft dated May 2025.

Moved by Councilor Brunelle, seconded by Councilor Dombrowski

Discussion: Human Resources Director Christine Dias explained Tax Collector job

description has been updated to reflect the current duties of the position.

VOTE:

3 - 0 Approved and so declared

RECOMMENDED FOR APPROVAL

April Brunelle

RESULT:

MOVER:

Kevin Dombrowski

SECONDER:

Dombrowski, Buhle and Brunelle

AYE:

Any New Business proper to come before the Committee

None.

ADJOURNMENT

Councilor Dombrowski moved the meeting be adjourned, seconded by Councilor

Brunelle.

VOTE:

3 - 0 Approved and so declared, the meeting was adjourned at 6:01 p.m.

Respectfully submitted,

Jessica Buhle

Committee Chairman

Administration Committee

DISCLAIMER: Although we try to be timely and accurate these are not official records of the

Town.