Ethics Board

About the Board of Ethics

The Board of Ethics, established by Denver ordinance and the City Charter, is an independent agency governed by specific provisions of the City Charter, the Denver Code of Ethics and its own Rules of Procedure. There are five members of the Board, appointed by the Mayor and by City Council. Members are all unpaid volunteers and meet monthly. The Board has one full-time employee, Executive Director Lori Weiser.

Denver has had a Code of Ethics for city officers, employees and officials since at least 1965. The City Council strengthened the Code of Ethics in 2001, 2004, 2007, 2009, 2012, 2018, and 2021. Both the Denver City Charter and the Code of Ethics provide “it is the intent of the City and County of Denver that its officers, officials and employees adhere to high levels of ethical conduct so that the public will have confidence that persons in positions of public responsibility are acting for the benefit of the public.”


Encourage and guide city officers, officials and employees to adhere to high levels of ethical conduct so that the public will have confidence that persons in positions of public responsibility are acting for the benefit of the public.

Board Members

Dianne Criswell, Board Chair

Dianne Criswell is General Counsel to the Colorado Special District Risk Pool, Firefighter Benefit Trust, and the Colorado Special District Association. She graduated from the University of Washington Law School and is licensed in Colorado and Washington State (inactive). Previously, she served as Revenue Counsel to the Washington State Senate and as Legislative Counsel at the Colorado Municipal League. Appointed by the Mayor, her term will expire May 31, 2027.

Jane T. Feldman, Vice-Chair

Jane T. Feldman was the Executive Director of the Colorado Independent Ethics Commission for nearly six years.  Prior to that, she was a First Assistant Attorney General in the Natural Resources Section of the Colorado Attorney General’s Office, and an Assistant Attorney General in the Criminal Enforcement Section.  She began her legal career in the New York County District Attorney’s Office in New York City.  She is a magna cum laude graduate of the Benjamin N. Cardozo School of Law. She served on the Steering Committee and as President of the Council on Government Ethics Laws (COGEL). She previously served on the Denver Board of Ethics in 2015, but resigned in December of  2015, because she moved to New York State to serve as the Executive Director of the Office of Ethics and Compliance for the New York State Assembly.  She served for a year and a half in that position before returning to Colorado in 2017.  She currently is the Principal of Rocky Mountain Ethics Consulting, which advises local governments on ethics issues, and has acted as pro bono counsel in several immigration cases. She was appointed by City Council to a term that will expire on April 20, 2025.

Hon. Doris E. Burd

Hon. Doris E. Burd earned her J.D. from Temple University School of Law. After law school, she worked with the Legal Aid Society of Denver and the University of Denver Law School Clinical Education Program, followed by engaging as a solo practitioner. She served as a Denver County Court Judge for approximately 29 years, retiring in November 2017. She continues to serve as a Senior Judge. Appointed by the Mayor, her term will expire on April 30, 2025.

Everett B. Martínez

Everett B. Martínez is General Counsel to Denver International Airport and responsible for managing the legal staff and representing the Airport in various matters related to aviation, finance, real estate, and concessions.  Mr. Martínez has been with the City since 2016, most recently as Assistant General Counsel.  Prior to his tenure as General Counsel, Mr. Martínez was a public finance attorney, for a decade, at national law firms.  Mr. Martínez earned an undergraduate degree from the University of Colorado and a Juris Doctor from Harvard Law School.  Appointed by jointly by the Mayor and City County, his term will expire July 1, 2025.

Ray Gradale

Ray Gradale is Assistant General Counsel to DaVita, Inc. He graduated from Lewis & Clark Law School and is licensed in Colorado (Single Client) and New York State. Previously, he served as Counsel for 9/11 First Responders in New York, NY and as Law Clerk for the City and Port of Portland, Oregon. Appointed by City Council, his term will expire September 18, 2027.

Policies and Guidelines

Timing policy for requesting advisory opinions and waivers

The Board of Ethics wishes to give proper consideration to every request for an advisory opinion or waiver.

Therefore, the Board encourages anyone requesting an official advisory opinion or waiver to:

  1. Submit the request in writing by letter or e-mail to the Staff Director of the Board of Ethics at least ten days before the monthly meeting of the Board of Ethics (on the fourth Thursdays of each month, except for November and December, when the meetings are on the third Thursdays). This will enable the Staff Director to gather information and prepare and mail a report to the members of the Board.
  2. Attend the Board of Ethics meeting so that the person requesting the opinion or waiver may respond to any questions the Board members may have. If the person requesting the advisory opinion or waiver is doing so on behalf of another person, the requester should encourage the affected person to attend and respond to questions.
  3. Exceptions may be made in case of justifiable emergencies.

Adopted by the Board of Ethics: June 22, 2006

Guidelines for accepting payment of travel expenses

The Denver Code of Ethics prohibits City officers, employees or officials from accepting travel or lodging expenses under certain circumstances. In that regard, the Denver Board of Ethics has considered several requests for advisory opinions and/or waivers relating to payment for travel or lodging expenses for City employees by organizations other than the City and County of Denver.  

To assist you, the Board of Ethics publishes the following guidelines for your use:

  1. Acceptance of travel and lodging expenses by City officers, officials or employees is prohibited if (i) you are in a position to take direct official action with regard to the donor and (ii) the donor has an existing, ongoing or pending contract, business or regulatory relationship with the City. There is an exception for payment by nonprofit organizations or other governments for attendance at a convention, fact-finding mission or trip or other meeting where you are scheduled to deliver a speech, make a presentation, participate in a panel or represent the City. (Section 2-60, Code of Ethics).
  2. "Direct official action" is defined as any action that involves:
  3. Negotiating, approving, disapproving, administering, enforcing, or recommending for or against a contract, purchase order, lease, concession, franchise, grant, or other similar instrument in which the City is a party. With regard to "recommending," direct official action occurs only if the person making the recommendation is in the formal line of decision making.
  4. Enforcing laws or regulations or issuing, enforcing, or regulating permits.
  5. Selecting or recommending vendors, concessionaires, or other types of entities to do business with the City.
  6. Appointing and terminating employees, temporary workers, and independent contractors.
  7. Doing research for, representing, or scheduling appointments for an officer, official or employee, provided that these activities are provided in connection with that officer’s, official’s or employee’s performance of (1) through (4) above. (Section 2-52(b), Code of Ethics).

While the Board of Ethics has the authority to grant a waiver, it believes that the best interests of the City are served if waivers are not routinely granted. However, the Board of Ethics is prepared in an emergency, unusual or exigent circumstances to consider granting waivers. The fact that a City department or agency does not have a sufficient budget for travel and lodging expenses is not sufficient to justify the granting of a waiver by the Board of Ethics.

Issued December  2002

Guidelines for board member positions

Board members are volunteer unpaid positions. Each Board member must be willing to dedicate himself or herself and the necessary professional time to:

  • Review written case materials and other documents before each meeting
  • At each Board meeting give official advisory opinions to city employees, elected officers and board and commission members about ethics questions and considering whether waivers should be given if a proposed action would violate the Code of Ethics but the action would be in the city’s best interest
  • Review and comment on drafts of Board opinions
  • Review and, if necessary, conduct hearings on complaints filed by citizens or city personnel alleging violations of the Code of Ethics
  • Give guidance to the staff director of the Board of Ethics on policy issues and ethics training issues

Board of Ethics Meeting Minutes