Under Old Business at the 5/4/2026 Town Council meeting the Council will discuss and schedule a Public Hearing to adopt a revised ethics code.
Discuss and schedule a public hearing for May 18, 2026 regarding the proposed revision to the Municipal Code, repealing Title I, Chapter XXIX, and adopting Chapter 20 Code of Ethics. (Kirsten Hildonen, Administrative Services Director)
Documents:
2026-05-04 Code of Ethics Cover Sheet.pdf
2026-05-04 Chapter 20 Ethics Final Draft.pdf
2026-05-04 Title I Chapter XXIX Code of Ethics.pdf
Below is ChatGPT’s analysis of the current and proposed codes:
Yes — I compared the two documents. The newer document is not just a light edit. It substantially reorganizes and expands the ethics code.
Major differences
1. Much broader definitions section in the new version
The new code adds formal definitions for:
- conflict of interest
- electioneering
- lobbying
- pecuniary interest
- personal interest
- recusal
- town resources
- volunteers
This makes the new document more explicit and easier to administer. The old version relied more on general narrative language rather than defined terms.
2. Lobbying and electioneering are a major new focus
This is probably the biggest substantive addition.
The new policy creates detailed restrictions on:
- lobbying during work hours
- use of town email, websites, social media, facilities, employee time, and equipment for lobbying or electioneering
- federal grant restrictions
- state grant restrictions
It also specifically states that the Town Manager may authorize town employees to advocate on behalf of the town when consistent with Town Council legislative policy.
The old code did not contain this level of lobbying regulation.
Practical effect: the new version regulates political advocacy and use of municipal resources much more directly.
3. Freedom-of-expression language is new
The new document explicitly says:
- public employees may publicly discuss government matters as individuals
- no one may interfere with employee freedom of speech
- confidential records remain protected
This appears in Section 20.5(D), tied to NH RSA 98-E.
The old document did not contain this explicit speech-protection language.
4. Gift rules changed materially
Old version:
- prohibited gifts from persons with matters pending before the official
- holiday/family gift exception
- informal $25 threshold language for ordinary holiday gifts.
New version:
- explicit $75 cap
- broader prohibition on gifts that could appear to influence decisions
- expressly includes money, services, loans, travel, entertainment, hospitality, equipment, premises, and indirect solicitation.
Bottom line: more formal and broader gift regulation, with a higher dollar threshold.
5. Conflict-of-interest procedures are much more detailed
The new policy creates a dedicated section for elected and appointed town officials.
It specifies:
- public disclosure of reasons for recusal
- advisory votes by the body when conflict questions arise
- another member may request a vote
- members of the public may object and state reasons
- reasons must be entered into the minutes
- planning board and zoning board references to RSA 673:14.
The old code required recusal and disclosure but did not spell out this formal meeting procedure in this detail.
6. Improper use of office section is new and more specific
The new code adds explicit rules that:
- town letterhead may only be used for official town business
- individual councilors do not determine official town business on their own
- officials may not speak for a board or council unless authorized
- officials appearing publicly as individuals must say they are speaking personally
- members may not appear before their own body on behalf of third-party private interests.
This is considerably more precise than the old document.
Important removal: nepotism section disappeared
The old code had a dedicated Town Nepotism Policy covering:
- hiring immediate family
- appointment participation
- supervision of family members
- chain-of-command restrictions
- family definitions.
That dedicated nepotism section does not appear in the new Chapter 20.
That does not necessarily mean the town eliminated nepotism rules entirely — but the old standalone ethics-code nepotism section was removed from this chapter.
Reporting process changed
Old version
The old code had a more differentiated reporting structure:
- employees → Town Manager
- Town Manager → Town Council
- appointed board members → Town Council
- elected body members → their elected body.
New version
The new code says:
- suspected violations shall be reported to the Town Manager
- Town Manager investigates or coordinates investigation under ADM-126.
That is a more centralized structure.
Advisory opinions are new
The new policy expressly allows officials and employees to seek written advisory opinions from the Town Manager, and those may serve as precedent for future guidance.
The old document did not include that mechanism.
Complaint form removed from the chapter
The old code included a formal complaint form as an appendix.
The new chapter does not include one.
My short read of the practical meaning
The new 2026 version appears to move the ethics code toward a more administrative-governance model rather than a simple statement of ethical expectations.
It especially strengthens:
- control over lobbying and political advocacy using town resources
- formal conflict-of-interest procedures during meetings
- official-versus-personal speech distinctions
- Town Manager administrative oversight
At the same time, it removes the old standalone nepotism section.
If you want, I can also give you a “what changed politically and why this may matter for Londonderry town officials” analysis — including which provisions are likely to matter most for councilors, boards, and public comment disputes.
Politically, the biggest shift is that the new ethics chapter moves from a fairly traditional “don’t misuse office” code toward a more explicit set of rules about how public officials, employees, and boards communicate, advocate, and use municipal resources.
What changed politically
Lobbying became a central issue
The old code focused mainly on conflicts, recusal, gifts, and misuse of office. The new code adds a substantial lobbying and electioneering framework. It regulates employee lobbying during work hours, use of town email/websites/social media, and use of facilities, equipment, and employee time for political advocacy. It also ties those rules to federal and state grant restrictions.
Political meaning: this creates clearer boundaries around when municipal infrastructure can and cannot be used to influence public policy or political outcomes.
“Who speaks for the Town” is much more explicit
The new chapter states that:
- official Town business is determined by formal action of the Town Council as a body
- individual councilors cannot unilaterally define official Town positions
- members of boards, committees, and commissions may not speak on behalf of their body unless authorized
- when speaking publicly as individuals, they should clearly state they are speaking personally.
Political meaning: this narrows the ability of individual officeholders to present personal views as institutional positions.
That matters most during:
- controversial local policy debates
- social media disputes
- public statements to press or advocacy groups
- letters or communications using official titles or town channels
Conflict-of-interest challenges are more formalized
The new code gives a clearer process when someone believes an official has a conflict:
- another member of the body may request a vote
- members of the public may object and state reasons
- the presiding officer must ensure the reasons are entered into the minutes
- the vote is advisory, not binding.
Political meaning: conflict disputes are more likely to become visible parts of public meetings and meeting records.
That can matter because it creates a formal public mechanism for raising objections in real time.
Greater administrative role for the Town Manager
The new chapter gives the Town Manager a larger role:
- receiving reports of suspected violations
- investigating or coordinating investigations
- issuing written advisory opinions that may serve as precedent.
Political meaning: ethics administration becomes more centralized and managerial.
In practice, that can make interpretation of the code more structured—but it also means administrative judgment becomes more important.
Public employee speech was expressly protected
The new code also says public employees may publicly discuss government matters as individuals and that no person shall interfere with that right, subject to confidentiality law.
Political meaning: while the chapter restricts official use of municipal resources, it simultaneously preserves personal speech rights.
That creates a deliberate distinction between:
- speaking as a private individual
- speaking with governmental authority or using governmental resources
One especially notable removal: nepotism
The old chapter contained a dedicated nepotism section governing family hiring, supervision, appointments, and contract participation.
That dedicated section does not appear in the new chapter.
Political significance: a formerly explicit topic became less prominent in this ethics chapter. Whether those rules now live elsewhere would require checking other town policies.
My candid read
The new code looks less like a simple ethics statement and more like a response to modern local-government friction points, especially:
- political advocacy by public employees
- social media and official communications
- disputes over whether individual officials are speaking personally or institutionally
- public conflict-of-interest challenges during meetings
In other words, it appears designed partly for governance disputes about speech, advocacy, and authority, not just classic corruption issues.
What may matter most in Londonderry
The provisions most likely to affect real-world local politics are:
- Individual councilors cannot define official town positions alone
- Use of town communication systems for advocacy is more constrained
- Public conflict objections can now become part of the meeting record
- Officials must distinguish personal speech from official representation
Those are the parts most likely to surface during contentious public debates.