THE CITY OF NEW YORK

CONFLICTS OF INTEREST BOARD

In the Matter of

DISPOSITION

JOHN BOUGIAMAS

COIB Case No. 2014-667

Respondent.
WHEREAS, pursuant to Section 2603(h)(1) of Chapter 68 of the New York City
Charter, the New York City Conflicts of Interest Board (the Board) commenced an
enforcement action against John Bougiamas (Respondent) alleging violations of provisions of
the City of New Yorks conflicts of interest law, Chapter 68 of the New York City Charter
(Chapter 68); and
WHEREAS, the Board and Respondent wish to resolve this matter on the following
terms,
IT IS HEREBY AGREED by and between the parties as follows:
1. Respondent admits to the following:
a. From January 5, 2009, to September 15, 2014, I was employed by the New
York City Board of Elections (BOE). As such, I was a public servant
within the meaning of and subject to Chapter 68.
b. At all times stated herein, I had ownership interests in and positions with 360
Consultants, which provides website design and development and technical
support services to private clients, and Pharos Group, Inc., which markets data
services to political campaigns and related entities.
c. In or around March 2012, while I was working as a supervisor in the BOE
Queens Borough Office, I engaged a subordinate BOE employee (herein, the
BOE Employee) to work for 360 Consultants. The BOE Employee
generally performed this work without compensation, with the exception of
one project, for he received $500 as compensation.
d. Although I was unaware at the time, I now understand that, by hiring a
subordinate City employee to work for me at my private company, I violated
City Charter 2604(b)(14), which provides: No public servant shall enter

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into any business or financial relationship with another public servant who is a
superior or subordinate of such public servant.
e. Between December 10, 2012, and February 6, 2013, I used my BOE email
account on approximately seven occasions for purposes related to my nonCity businesses, 360 Consultants and Pharos Group, including to
communicate with the BOE Employee.
f. I acknowledge that, by using my BOE email account for these non-City
purposes, I violated City Charter 2604(b)(2) pursuant to Board Rules 113(b). City Charter 2604(b)(2) provides: No public servant shall engage in
any business, transaction or private employment, or have any financial or
other private interest, direct or indirect, which is in conflict with the proper
discharge of his or her official duties. Board Rules 1-13(b) provides in
relevant part: it shall be a violation of City Charter 2604(b)(2) for any
public servant to use City letterhead, personnel, equipment, resources, or
supplies for any non-City purpose.
2. At the September 4, 2014, meeting of the Commissioners of Election, the
Commissioners voted to suspend Respondent without pay pending a disciplinary hearing
concerning the above conduct. In resolution of the pending administrative action, Respondent
tendered his resignation effective September 15, 2014. The Board accepts, as sufficient penalty
for the violations of Chapter 68 cited above, Respondents suspension without pay and
resignation.
3. Respondent agrees to the following:
a. This disposition is a public and final resolution of the Boards charges against
me.
b. I knowingly waive, on my behalf and on behalf of my successors and assigns,
any rights to commence any judicial or administrative proceeding or appeal
before any court of competent jurisdiction, administrative tribunal, political
subdivision, or office of the City or the State of New York or the United
States, and to contest the lawfulness, authority, jurisdiction, or power of the
Board in imposing the penalty which is embodied in this disposition, and I
waive any right to make any legal or equitable claims or to initiate legal
proceedings of any kind against the Board, or any members or employees
thereof relating to, or arising out of this disposition or the matters recited
therein.
c. I confirm that I have had the opportunity to be represented by an attorney of
my choice in this proceeding and have declined such representation; that I
have entered into this disposition freely, knowingly, and intentionally, without
coercion or duress; that I accept all terms and conditions contained herein
without reliance on any other promises or offers previously made or tendered

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