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Recommendation R20

Recommendation R20

By April 1, 2027, the BART Board should consider requiring the Audit Committee to conduct and document biennial reviews of the Employee Code of Conduct as required by the Audit Committee’s Charter.

Jury report: BART at a Crossroads: Structural Deficit, Governance Accountability, and the Choices Ahead · PDF page 27

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Official response

BART Board of Directors

Agency says implemented

Claims implemented because charter already requires biennial review, but promises updated code for January 2027 meeting.

Read official response · PDF page 31

Existing requirement does not establish conducted/documented reviews. Retain implemented label alongside future review commitment.

  • Provide updated Employee Code of Conduct for committee review and discussion. Owner: BART Board of Directors. Timing: January 2027 Audit Committee meeting; implemented label does not establish completed review..

This review evaluates the response document. Implementation claims have not been independently verified.

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