Sheriff's Policy Manual: Lobbying

Lobbying Policy

• Lobbying is defined as communicating directly or indirectly with the Sheriff or any other employee of the Broward Sheriff's Office to influence the award of a purchasing contract or bid award.

Definitions

• Lobbyist: Any person employed, retained, or compensated by a principal or client who engages in lobbying.
• Senior Level Employee: Any sworn law enforcement or detention personnel having the rank of captain and above, any sworn Fire Rescue personnel having the rank of battalion chief and above, and any civilian personnel having the position of manager and above.
• Vendor's Representative: Any employee, partner, officer, or director of a potential vendor, or any consultant, lobbyist, or actual or potential subcontractor, or sub-consultant of a vendor.
• Cone of Silence: A prohibition on communication regarding a particular Request for Proposal (RFP), Request for Letters of Interest (RLI), bid, or other competitive solicitation between any person who seeks an award from BSO and certain individuals, including the Sheriff, members of the Selection, Evaluation or Technical Committee, agency employees assigned purchasing responsibilities, and senior level employees.

Lobbyist Registration

• Every lobbyist must register with the Office of the General Counsel on the Lobbyist Registration Statement (BSO#A165) prior to engaging in lobbying activities.
• Separate registration is required for each principal or client represented.
• Registration forms are subject to public records laws and open to inspection as permitted by Chapter 119, Florida Statutes.

Cone of Silence Provisions

• The Cone of Silence begins when the RFP, RLI, bid, or other competitive solicitation is posted and available to the public to review.
• The Cone of Silence terminates at the time the contract is executed or when all bids or proposals have been rejected.
• The Cone of Silence does not prohibit certain types of communication, including:
  • Making presentations at scheduled agency Purchasing Bureau meetings or before agency Selection, Evaluation or Technical Committees.
  • Communicating in writing with any Purchasing Bureau employee for purposes of seeking clarification or additional information regarding the RFP, RLI, bid, or other competitive solicitation.
  • Purchasing Bureau employees initiating contact with a potential vendor or vendor's representative and subsequent communication related thereto for the purpose of obtaining further information regarding the RFP, RLI, bid, or other competitive solicitation.

Violations and Investigations

• The General Counsel will be informed of any person who is alleged to have violated the requirements of the Lobbyist Registration section or the Cone of Silence section of this policy.
• The General Counsel or their designee will conduct an investigation and compile a report.
• A determination of violation of the Cone of Silence on the part of the vendor or the vendor's representative will render the RFP, RLI, bid, or other competitive solicitation award to said potential vendor voidable, at the sole discretion of the Sheriff or designee.