The Rules of Procedure for Enforcement of the Code of Ethics (Rules) govern the ethics review process when ICMA receives a clear, written complaint with accompanying documentation that alleges a member’s conduct has violated the ICMA Code of Ethics (Code). The ICMA Executive Board first adopted the Rules in 1972 with revisions occurring at the Committee on Professional Conduct (CPC)’s recommendation throughout the years.

The CPC completed a comprehensive review of all facets of the Rules, conducted research and data analysis, and offered dedicated opportunities for member feedback during the 2025 Local Government Reimagined Conference in Milwaukee, as well as at a free webinar open to all members. 

The board adopted the CPC’s recommended revisions to the Rules during its May 1 meeting with notable provisions detailed here: 

• Who has standing to file an ethics complaint with ICMA. The ethics review process holds members accountable to their peers for conduct that undermines the profession’s integrity and damages public trust. Over the past few years, the CPC has seen an increasing trend of nonmembers filing ethics complaints who may not share ICMA’s same motivations. Based on five years of data, when nonmembers filed ethics complaints, the significant majority resulted in an ethics decision that a member’s conduct did not violate the Code. The CPC explored who should have standing to file an ethics complaint. 

  The Rules now limit eligibility in filing a complaint to these three groups: 

  • Current ICMA members

  • Current state/country association members 

  • An individual who is not a member of ICMA and possesses first-hand knowledge of the alleged conduct, e.g., the member’s employee or a representative of the member’s governing body. 

  This process allows a nonmember “whistleblower” to file a complaint if that individual thinks a member’s conduct violated the Code as long as they are aware of the conduct themselves. 

• Reviews are limited to conduct within five years of ICMA receiving the ethics complaint unless the member concealed the conduct. 

• In the prior versions of the Rules, the member waived process rights if they chose to resign their ICMA membership. That provision was removed so individuals can now request reconsideration and appeals/hearings regardless of whether they retain membership during an ethics review. 

• The Code states that a complaint remains strictly confidential unless it results in a public censure. New provisions in the Rules state (1) ICMA may choose not to process a complaint if a member does not have the benefit of it remaining confidential and (2) in situations where there is no ethics violation, the CPC has the authority to determine notification to appropriate parties in instances where confidentiality may not be assured or notification is not in ICMA’s best interest. 

Additional Highlights

• Added language that ICMA will not tolerate harassing behavior or retaliation of any individual connected with the ethics review process and ICMA may engage law enforcement, the legal process, or reject a complaint.  

• A complaint must be electronically filed, signed, and include contact information of the submitter in order for ICMA to contact the submitter with clarifying questions. Submitters can still choose to be named as a complainant or remain anonymous to the member whose conduct is alleged to have violated the Code. 

• Clarified the limited circumstances when a state association fact-finding committee is required to gather the facts of an ethics complaint. 

• Provided overall edits and updated language to clarify the ethics review process. 

Rules of Procedure

All members agree to abide by the Code of Ethics as a condition of ICMA membership and ICMA encourages all members to read the Code of Ethics. Frequently asked questions, free resources, and the ICMA Code of Ethics are available on ICMA’s website. 

As a benefit of membership, ICMA provides free, confidential advice to any member who may need guidance to resolve an ethical dilemma or may be uncertain of their ethical obligations. Members should contact Jessica Cowles, ethics director at jcowles@icma.org, for a conversation or with questions about the Rules revisions.