My name is uh Councilman Juan Kimartinez, and I'm the chair of the committee.

I'd like to start by recognizing my colleagues joining us today, beginning with Vice Chair uh Councilmember Carter.

Uh we've also been joined by Councilmember Peck and Councilmember Ramides and staff from Councilmember Castillo's office and Cayman.

Vice Chair, if you would like to share any opening remarks.

No, thank you.

And uh Robin, we look forward to your presentation.

Thank you for being here.

Thank you for having me.

Thank you.

And we've now been joined by Councilmember Alcorn and staff from Mayor Mayor Pearl Tem uh Cassis Tatum's office, staff staff from her office.

Um as a reminder for council members, please hold your questions until the end of the presentation.

When you're recognized, please be sure to speak clearly into your microphone.

I will let that you know when your three minutes uh for questions has ended.

Um now switching into the meeting agenda today.

Uh the committee will be receiving an overview of the Office of Expect Inspector General from the Inspector General Robin Curtis.

Uh so let me turn it over to uh Robin to begin the presentation.

If you please introduce yourself uh for the record as well as any other members of your team that may have joined you.

Good morning.

I'm Robin Curtis, I'm the inspector general for the city of Houston.

I'm gonna give an overview today of the Office of Inspector General.

Uh what I'd like to do, next slide is give you a roadmap of where we're going, and I believe you have the presentation in front of you as well, so you can have a sense of what's going on.

We're gonna start with the foundation of OIG, uh OIG by the numbers, uh, the split up about the types of cases to that come to OIG, and we're gonna talk about the part that you had a special interest in, the fraud, waste and abuse portion of what OIG does, the ethics commission, and then of course it's election season.

So those are the areas that we will hit today.

Next.

So OIG was formed, established uh by Executive Order 1-39.

You might say to yourself, what does OIG have the authority to do?

And the answer is it's quite broad.

We investigate misconduct by city employees, officials, vendors, folks related to the city.

And misconduct, as you can see from your screen, is an act or failure to act that violates basically a law or a policy.

So you say that's very broad.

Next.

So what does that mean for everyday people trying to get a resolution when misconduct is an issue?

There are three areas that individuals go to to get resolution.

Generally, they go through the chain of command, they go to HR, and they go to OIG.

So the three uh three branches of the tree as you look for resolution and a misconduct issue.

And so you might say, what really does OIG do on a regular basis?

What kinds of things really come to OIG?

And so the OIG investigates discrimination, retaliation.

Um Texas whistleblower has a special act.

Uh fraud, waste and abuse, of course, violations of federal, state, and local law.

Uh referrals from the ethics committee, workplace violence, and wage theft, and city contracts and subcontracts are among those things that we see.

Next.

So OIG by the numbers.

The number of cases that come to OIG has risen fairly dramatically over the years.

Uh last year in 2025, uh, we closed 449 cases.

Huge number.

Six investigators.

I'm very proud of them.

Special shout out to each and one of them.

Um you think about those 449 cases, how are those split up?

So in general, about 75% of the cases that OIG gets are connected to discrimination, retaliation, or related alphabet suit of employment related matters.

The laws related to employment are quite lengthy.

So a single person can also make a complaint about more than one thing.

So you can have folks who make a complaint about both a discrimination matter and a fraud, waste and abuse matter.

And so while the numbers are not going to add up to 100% because of that overlap, you can take a look at the next slide, and you can see that about that's about 75% discrimination, retaliation and related.

And then on the next slide, you'll see those are connected to the laws that have to do with those employment related matters.

So Title VII, the Texas Human Resource, Texas Commission on Human Rights Act.

And then here in the city, you hear people talk about Executive Order 1-50 is the policy that's connected to that.

So 75% of the matters that we handle are those.

Next, the next slide talks about the different areas of discrimination based on protected classes.

Next, but the reason we are here today is the committee wanted more of a deep dive into the portion of the cases that OIG handles that have to do with fraud, waste and abuse.

So those are about 25% of the cases.

Next.

Next, one thing I'd like to add is that OIG also directly takes referrals from federal, state, and local matters.

So we get some of those, and those show up as fraud, waste and abuse matters as well.

Okay, so a number of you might have constituents who need to come to OIG.

So you might say, Robin, uh tell us how does a complaint get to OIG?

So employee complaints, uh the resident, your resident, your constituent, the mayoral referrals, director referrals, the city attorney refers, we get civil service commission appeals, and then of the fate uh federal and state agencies.

Next.

So if a constituent comes to you and says, I have an issue and I don't know where to go with it, and you believe it's an OIG matter, of course, you can always just call, we're happy to help.

But another way is right on the City of Houston website is the online complaint portal.

24-7, a person with a complaint in the middle of the night can make a complaint and get an instant number.

So they will get an immediate acknowledgement that they have a complaint with a number and it's going to be investigated.

So the next slide will show what it looks like when a uh you look at the portion of the City of Houston website.

And then the slide currently talks about the instant receipt number.

If you ever have any issues, please feel free to call us.

We're happy to help.

Okay, the next slide has to do with who does OIG not investigate.

We do not investigate businesses unrelated to the city, and we don't investigate anyone from the police department, whether they're classified or civilian, and that's by state law.

So those are the folks that we don't investigate.

Next.

So the portion that this committee had a special interest in had to do with fraud waste and abuse.

So the next slide shows the six ways that we split it out for the ones that you see fairly commonly.

So the six are uh employee standards of conduct right out of the ordinance.

So 14183 is the legislation uh that says how employees are supposed to behave, and it's so serious, uh, the city put it in an ordinance.

Similarly, there's one for city officials.

Uh that's 18-3.

Uh, the third area is conflicts.

This is an um uh policy set forth at AP 2-22 that gives a source list of types about the many, many places that conflicts can occur and the different uh matters that uh rules that might apply.

Another one that's fairly common is unauthorized outside employment or employment that's authorized but isn't what the person is actually doing.

The next one is the mayor's policy on gifts, and the last one is the mayor's policy on hiring relatives, sometimes called the nepotism policy.

Next.

So on chapter 14183, this is the employee standards of conduct, and I'm just going to mention a couple of them that we see.

Gifts shows up again, so you'll see that at the top.

And unauthorized outside employment again shows up separately from the policy.

And then the last one on there you see attempts to use a city position for special privilege for a person themselves or for others.

So when you think about those types of issues, you might think to yourself, what kinds of things might come up in connection with each of those?

So if you have a question about that, happy to answer those.

The next section has to do with city official standards of conduct.

And the city officials very similar.

And the ones, again, that uh uh we see are connected to the same ones that happen with employees.

Uh business and professional activities that may conflict with official duties, uh, whether or not gifts are involved, uh, matters of private game or self-advantage, uh, use of city employees who are on duty for uh uh non-city matters.

That sort of thing is what we're talking about for city officials.

And next.

And I have a lot of these, but I am not going to read you the slides.

So understood.

Next.

So the next section is the conflict list.

And the reason that is so important to have uh front and center is you can see by the kinds of things that come to OIG that a lot of them are about conflicts, even if they show up in different places.

So in the same way that an employee uh has uh may be investigated for fraud, waste, and abuse, a lot of times it's it's some version of a conflict.

And so the kinds that uh we see in connection with uh AP2-22 about the conflicts policy that is different from those that we've already spoken about, is that there is a definition in AP 2-22 about the appearance or an apparent conflict of interest.

And so an apparent conflict of interest, which is sometimes called the appearance of a conflict, and you see this in the newspaper all the time, means when circumstances are such that a reasonable person with knowledge of the facts would question the impartiality of the city person and their participation in a program or receipt of a benefit.

So that definition comes up in connection with let's train to not have even the appearance of a conflict of interest.

And so AP 2-22 gives that list of where conflict might go.

So if you take a look at the next slide, a couple of them that may be unusual to you are uh the local government code has its own section having to do with um public servants and whether they have a substantial interest in a business entity or real property.

Uh disclosure of relationships with local government officials came up in um a recent matter that made the newspapers where were the forms filled out correctly about who was an official uh who had a relationship with a local government official.

Uh next.

Another one that comes up in connection with the appearance of a conflict of interest is that right in the city charter, we have uh the strong statement that uh it is against the public policy of the city uh for any employee of the city to bid on, be awarded, or any contract being led by the city, or to be, and here's the magic words, to be pecuniarily interested in.

That's hard to say, isn't it?

It's about the money.

So directly or indirectly, employees can't be involved in the money in connection with the city where the rights of the liability uh or the liabilities of the city are involved.

So they can't be involved in a connection with a contract where they would get money directly or indirectly.

Next.

So the next one that comes up for us is federal money.

The city is grateful to be the recipient of federal grants and federal rules about conflicts are different.

They run a different set of rules, although of course there's a lot of overlap and they have a great interest in the conflict provisions.

If a person has a financial or other interest in a tangible personal benefit from a firm, this can come up when a person owns a side business and also works for the city, or their family members do.

So the uh federal government's very involved, and we work with them closely.

On the next slide, uh, when we talk about what should a person do when an apparent conflict of interest comes up.

The answer is the policy says we have to manage that conflict through to resolution because it may be an apparent conflict, but it may not turn out to be an actual conflict, or it may be a real one, it may need to be resolved, and the city attorney is involved in that all the way up to the top.

Next, the next section is on the gift policy.

Surprising how old this policy is.

The gift policy is uh goes back decades, and it's EO 1-28, and before that it was a mayor's policy.

Um city employee shall not directly or indirectly, so as broadly as they could write this, uh city employee may not accept a benefit.

And so you as you can imagine, we get a lot of calls about what constitutes a benefit, and the benefit includes any gift of food, goods, services, money, lodging, transportation, or any other thing of value.

The reason this comes up so often is you can imagine that it's written to be so broad that a person who is working very hard digging a ditch in a constituent's front yard is offered uh uh uh a bottle of water, right?

Um, we we don't investigate those, obviously, but you can imagine where does it end, right?

Where are the edges of that?

And the answer is we want people to call so we can find out who might be uh offering benefits that need to be looked into.

So that's a big help to us as well.

So that's the gift policy.

Next.

Another policy that's quite old is on the hiring of relatives, sometimes called uh nepotism.

And uh there's nothing wrong with having relatives that also work at the city.

We have 22,000 employees, so not surprising that people might be related to each other.

However, we discourage by policy the hiring of relatives into certain positions, and they're uh probably what you would expect.

People who are related to each other should not be deciding on their relatives' business.

They shouldn't be reporting to a relative, and they shouldn't uh supervise each other or report to the same supervisor.

So that one comes up as you can imagine, and how can that be handled comes up in connection with the individuals uh management situations?

Okay, next.

So the next system uh portion is the ethics commission.

So the ethics commission, if you look on the next page, involves the ethics commission board.

The legislation around the ethics commission was to create a board that involved no city employees or people who might be perceived to be uh uh beholden to the city in some way.

And so there are seven positions.

They come from different areas of our city, the Houston Bar Association, uh for the law community, the AFLCLIO comes with the labor side of our community, uh the medical center has a nomination, and then uh each of you as council members uh uh nominate and put on city council members onto this board.

Uh the city count uh they uh uh they don't have a prescribed meeting cadence, rather they retain the flexibility to convene as needed and respond promptly to matters within their jurisdiction.

So as you can imagine, they when they have something that has come forward to be worked on, they need to work on it in connection with that matter.

So next.

So that seven-member board has the duty and the power to review all allegations of impropriety.

Magic word there, magic word.

Impropriety by city officials.

Uh, as we talked about, board members can't be city officials or city employees to avoid even the appearance, again, of impropriety.

There needs to be a swarm sworn-written complaint, so that it's not uh uh anonymous rumors, that sort of thing.

Um, although the ethics commission can, on its own initiative, review an act of impropriety.

Uh when the commission needs assistance, they call on OIG to investigate, and that's why it's a part of this slide deck.

Investigations are conducted in a confidential matter, and records are confidential to the full extent permitted by law.

And of course, that purpose of that is uh we call it TRR, uh transparency, reputation retaliation.

There is a natural uh uh tension between those things, but you can uh obvious about how that needs to be handled.

So the next slide has to do with what the ethics commission actually can decide.

So they can choose to find reasonable cause that the sworn complaint is true, or they can find no cause.

If they find it to be true, they write a written report that comes to you as the council members, to the mayor, uh, to the city attorney, and if appropriate goes to a uh, for example, to the director.

That uh that written report leaves you as the legislatures in the position to decide what to do next, what the repercussions would be.

If the commission does not find reasonable cause, it is the commission's duty to notify both the complaining person and the respondent that the investigation is complete and that no cause was found.

Some people have asked, well, what happens if in the midst of the investigation we determine that the matter is far beyond an impropriety?

And the answer to that is in the legislation itself, in the ordinance, the commission has a duty to stop and involve law enforcement or the appropriate matters.

It's almost always, it's it's written carefully, but it's almost always, if it looks like it might be a criminal matter, we need to have law enforcement handle that right.

Next.

When there they decide that there has been reasonable cause to believe that a count uh city official has used his or her position to harass or discriminate, the commission has the power without going to anybody else to issue a public rebuke or reprimand or to recommend that the city official be removed and relieved of all duties related to the same.

Another issue that has come up is individuals have said, what about an advisory opinion?

What if we don't know enough to know whether or not we should go forward with a sworn written complaint?

What if we need some advice from the ethics commission?

In that situation, the ordinance says that the commission may also issue written advisory opinions, and that's true whether the written advisory opinion has to do with something that is existing, like a real issue with real facts and real people in front of it, or an advisory opinion can be requested on a hypothetical matter.

That gives an opportunity again.

Ethics is about stopping that kind of misbehavior before it happens.

So that is an option of not everybody knows about.

So happy to pass that one on.

Transparency in connection with uh reputation and retaliation concerns.

Right.

So next.

So the next section is the last part of this, and that has to do with its election season.

So thank you.

Folks had a special interest in making sure we had a couple of slides on election seasons, so happy to do that.

Special reminders during the election season.

Uh obviously don't engage in business or professional activities that might conflict uh with campaign matters, right?

Uh don't use city employees to perform uh acts or services on campaign business.

Every once in a while we get somebody who calls and said, I I saw somebody putting up a sign, and I think it was during business hours.

I don't think they should be doing that.

Uh but I don't I don't know who it was, and I don't know when it happened, that sort of thing.

So uh thank you guys for your uh wanting to have this uh uh get together to talk about these issues.

Uh don't accept contributions in city owned or operated buildings.

Um city employees cannot solicit contributions for any candidate, including themselves, uh, or participate in election or campaign activities unless they're doing so off duty or on duly approved leave.

Sounds pretty obvious, right?

Uh and the next slide.

Um the Texas election code itself uh prohibits an officer or an employee of a public subdivision from knowingly spending or authorizing the spending of public funds for political advertising.

We like to make sure this gets out because it's not obvious to uh everyone when you say political advertising.

I think people think about commercials on TV.

Uh but in fact uh the Texas Ethics Commission determined that the use of public funds includes city time, city resources, and city facilities.

So those that is uh the end of my prepared presentation.

Does anybody have any questions?

Uh thank you, Robin, for for this presentation.

Um, I I think we can all agree that um uh you know the mayor's priority in in the health of the finances is somewhat parallel to making sure that we're getting rid of the fraud, waste, and abuse, and I think we've been talking about around the horseshoe a lot as well.

So this was important for us to make sure that it's a reminder for not just ourselves as as uh city council, but also to employees, whether it worked for us or in in whether the 2,000 plus employees that we have right at the city of Houston.

And so I appreciate um you know the this presentation.

Um I I wanted to ask a quick question on the ethics commission.

Well, first, you know, you said you there's about 490 cases.

Um how many within your division uh are able to address these 490 cases, and then is it a referral to the ethics commission or do they refer just to you all certain certain uh uh challenger issues?

So great questions.

So we have six investigators who work very, very hard.

Um when you get to 450 cases a year, you're talking just huge, huge volume.

Um the uh the question about the ethics commission, it comes up uh you sort of ask it which comes first the chicken or the egg.

The answer is the ethics commission is the boss.

They call us and they say we have a concern and we'd like to have it investigated.

Perfect.

Uh before I uh pass it over to some of my colleagues, I just want to recognize staff from Councilmember Jackson's office, councilmember Thomas's office, and Councilmember Davis's office as well.

Uh first we have uh Councilmember Peck.

Thank you, Chair, and thank you so much for the presentation and for all the work that you do and your whole office.

Such important work, and we don't always hear about everything that you're doing, but it's crucial, especially when we're talking about public dollars and that kind of thing.

So thank you so much for that.

Um is there a way to report either to you or to the commission anonymously?

I could see how that could be problematic, but at the same time, because you want to question the person who's you know saying that there's an issue.

Um, but at the same time, I could see circumstances where someone might want to report something but not use their name.

So is there an opportunity for that?

Yes.

So great question, and you can understand both sides of it, because I I can tell by how delicately you ask the question that you know there's an old saying about you know, uh throw the rock and hide the hand, right?

So uh obviously we take anonymous complaints and you can file you could come out today and you could file one anonymously through the portal.

I will tell you that it's pretty hard to investigate an anonymous complaint.

So you can all imagine we'll do the ends of the spectrum, right?

If the anonymous complaint says Joe Bob stole the city's money and it's buried under the tree in front of City Hall, we could go dig it up and see if that was true, right?

So that's one end of the spectrum.

At the other end of the spectrum is somebody who sends an anonymous complaint that says, I heard a rumor that Joe Bob did something bad.

And now we don't have a person to call and ask for the details that would allow a thorough investigation.

And so, can you file one or could a person file one?

Yes, you can, and you can file it on the portal, and we will take a look at it.

The I want to manage the expectations of the people who file anonymous complaints uh because it's so hard to investigate one while being sensitive to TRR, transparency, reputation, retaliation, right?

And so we're taking all that into account.

But those ends of the scale are what we're working with.

Did I answer your question?

Yes, thank you.

Oh, thank you.

Uh Council Armeed.

Thank you, uh Mr.

Chair, and thank you, Inspector, for your presentation.

Um there's a lot in it, and I don't know how much time I have, but I did want to ask you, since you mentioned the Ethics Commission can get the ball rolling uh with the complaint uh that OIG will investigate.

Uh of uh the complaints that you guys have resolved, um how many come from the ethics commission and how many come through the other process where someone comes in and files a sworn complaint?

Oh very percentage.

Very few.

So of the 450, we don't have any current from the ethics commission.

Okay, so right now zero percent have come from the ethics commission.

That is correct.

And and all of them come from sworn complaints or anonymous complaints uh made directly to OIG, is that right?

Not sworn complaints, sir.

Uh uh complaints.

So complaints can come to us through the different ways.

You might refer one, like we talked about.

Okay.

One of your constituents might refer one.

We would not require your uh constituent to to to file a sworn complaint.

Okay.

Okay, wonderful.

Um let me ask you about the the way you conduct your investigations.

You mentioned you have six investigators.

Are they all attorneys or or not?

No.

Okay, the ones who aren't attorneys, are they uh peace officers or former peace officers?

They have been in the past.

Right now they're not.

So I have five attorneys and one who's a non-attorney with enormous experience, obviously.

And the attorneys uh not only have the uh the training through their uh investigations involving uh matters that touch the law, um, but we also uh big shout out to HPD for allowing us to attend their uh law enforcement trainings as well.

Okay, and curious to know um when when an investigation is complete that OIG is done, is all of it protected by attorney client privilege?

So there is a closure letter that goes out to the individuals who made the complaint that is that is not privileged.

So the person obviously, if you were a person who made a complaint, you would you would want to know the answer.

Um I'll give you uh I'll give you a real live example so it'll make more sense.

A person might we might investigate and find that a person engaged in some version of fraud, waste and abuse, and let's for our example use an uh unauthorized outside job with a conflict of interest.

That would that person would be notified, and then the next step would be it would go through the public process that goes all the way up to civil service.

So there would be a uh uh referral uh for whatever the disciplinary action would be up to an including indefinite suspension, and then that would go to the louder mill hearing, and that would go to civil service as the person appeals uh through the process.

So does that give you a sense?

I think so.

So apart from the closure letter, the entire OIG investigation, as I understand it, is protected by attorney client privilege.

Yes, sir.

Under what circumstances can member of the public media find out what that investigation by OIG revealed if it's protected by attorney client privilege?

What if they went to the hearing, uh the civil service hearing, they would hear the results.

I'm sure that's not what you mean.

If you mean do we hand it over to the media in spite of the fact that it's privileged, of course the answer is no.

So I think I'm not answering your question.

Can you help me a little bit?

You did, you did.

And and if it gets to a louder mill process, um, that doesn't mean the entire investigation is made public, does it?

No, no.

Uh obviously people testify, though.

So instead of hearsay, I mean a report is a piece of paper, right?

So uh as a I I believe you have much experience with hearsay is not very good.

And so you want the real person to be at the louder mill or civil service giving that first hand testimony, and that's who testifies.

My understanding is that not all jurisdictions do it the way we do it.

In other words, protect the entire investigation by attorney client privilege and therefore make it uh not discoverable by by the public or the media.

What why does Houston choose to protect the entire OIG investigation uh through attorney client privilege?

Uh you know, I don't know the answer to that question.

Okay.

So that is something that that City Council could alter um if we thought it was wise uh in order to be more transparent.

So I l uh OIG is neutral.

We are all on the same side about ethics, and so I leave the legislating to you guys great.

All right, thank you for that.

Um, while I've still got a little time.

So I I got this um offer from the Sports Authority to attend a uh World Cup match and and for two tickets.

Um there was a value attached to it for reporting purposes uh uh a lot of money.

Let's let's just leave it at that.

Are there any um city rules that impact the uh acceptance of that that you can think of at this point?

Uh as my granny would say, Heavens to Betsy, yes.

Okay.

So just like the you know, the World Series, uh, it's uh the people around this horseshoe are powerful people and folks would like to have time with you guys.

Uh that's just normal human behavior, but the all the rules we've talked about today are for that very reason to not even give the appearance of impropriety.

So you can imagine uh what shows up in the newspaper is people saying, well, I wonder if that person was impartial.

So that thank you for raising that.

Well, I appreciate this training.

Maybe you could offer this training to other governmental entities as well.

Well, funny you should say that.

We do.

We uh we provide it to uh we provide it to the unions.

Uh we provide it to the unions, we provide it management training and leadership training.

Uh so we do try to get the word out.

And I gotta say th thank you so much for your support in the realm of ethics.

It is uh it's easy to say ethics, but it's uh a lot harder to walk the walk.

Thank you.

Thank you, Councilman Ramides.

Um and and this is one of the reasons why um and I've said this prior to uh well even at my first uh committee chair uh as a committee chair uh for this this uh for ethics committee is that prior to there was probably had to have been at least 10 years that no ethics committee meetings have been held.

Uh we've been really trying to kind of raise raise the bar, make sure that folks are on this horseshoe, uh staff, um employees understand that you know we need to take this uh in high regard.

We want to make sure that folks know that that um as elected officials that we're holding uh that integrity that folks have put in and trusted in us.

So um, you know, I we really appreciate this presentation, uh, Robin.

I just just a reminder, uh, because I really want to make sure that our colleagues and of course staff around the horseshoe.

Um we've received calls from constituents sometimes, so I really want to just highlight that uh the online complaint portal.

Uh if y'all have an opportunity to share on your website, uh on your newsletters or social media, let folks know how to uh be able to uh submit a complaint if if need be.

Um because again, this is this is uh holding us all accountable, including every employee for the city of Houston.

Um there's no one else in the queue.

So this this concludes the presentation from council.

Um and I don't know, I don't think we have any public comments.

Um and so just want to.

Okay.

Councilman Alcorn.

Uh on the gift policy, I'd look to it.

It it hasn't been revised since like Anise Parker's day, right?

I'm looking at the right one.

You are that's I I tried to mention how old some of these are.

I mean, some of they just go back a very long way.

Yeah, and that and the there's not really a monetary, I mean some people used to say fifty dollars or whatever.

Is there a oh I'm so glad you mentioned that.

Uh there is a state one that you guys may be familiar with that has money attached to it, and we have had a fair number of people uh think that the one for the city is the same as the one for the state.

I'm making this up because I'm not looking at it, but fifty dollars or something, y'all know what I'm talking about, right?

And so uh ours has zero, so we we have a much stronger bar than others.

So thank you for getting the word out about that.

Okay.

Which actually brings up, you know, and Council Armita's brought up uh possible uh policy change or ordinance.

Uh and please submit those uh recommendations.

We're happy to take those on and talk to the administration about uh identifying ways where we can update some of these older uh policies or ordinances as well.

Again, leave the legislation to the legislators.

Thank you guys.

Thank you, Robin.

And this concludes uh of course the public comment aspect of it as well.

Uh for any members of the public watching, you may send questions or comments by emailing my office, district I at Houston TX.gov.

Uh seeing no additional comments or questions from council members, we'll move to adjourn.

I want to thank everyone for participating and this meeting's adjourned.

Thank you.