Press Release  State Ethics Commission Issues Public Education Letter to Ludlow DPW Board Chairman Stephen Santos

Boston, MA — The State Ethics Commission issued a Public Education Letter today to Ludlow Department of Public Works Board Chairman Stephen Santos after finding reasonable cause to believe he violated the conflict of interest law by voting to elect himself as DPW Board Chairman and by participating in disciplinary matters involving a DPW employee he believed was cooperating with an investigation of him.

According to the letter, the stipend paid to the Ludlow DPW Board Chairman is higher than that paid to other Board members. In June 2020, Santos voted to elect himself Board Chairman but lost to another nominee. Later in 2020, when the Board again voted to elect a new chairman, Santos voted for himself and won. The Commission found reasonable cause to believe that, by voting to elect himself to the more highly paid Board Chairman position, Santos violated the conflict of interest law’s prohibition against municipal employees participating in matters in which they have a financial interest.

According to the letter, in April 2017 Santos confronted a DPW employee he believed was providing information to another DPW Board member in support of allegations against Santos being investigated by a state agency. Later in 2017 and into 2018, Santos participated as a Board member in disciplinary matters regarding the DPW employee that could have resulted in the employee being suspended. The Commission found reasonable cause to believe that, given what Santos believed about the DPW employee, by participating in the disciplinary matters involving the employee, Santos violated the conflict of interest law’s prohibition against public employees acting in a manner that creates the appearance that they are likely to act with bias when performing their public duties.

The Commission chose to resolve the allegations against Santos through the issuance of the Public Education Letter rather than through adjudicatory proceedings because it determined that the public interest would be better served by publicly discussing the application of the conflict of interest law to Santos’ alleged actions. Santos agreed to resolve the allegations with the Public Education Letter and waived his right to a hearing before the Commission. The Commission expects that the letter will provide public employees in similar circumstances with a clearer understanding of how to comply with the law.

The Commission encourages public employees to contact the Commission’s Legal Division at 617-371-9500 for free advice if they have any questions regarding how the conflict of interest law may apply to them.

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