Greensboro Housing Coalition / Councilmember Hugh Holston Conflict-of-Interest Complaint

Re: Subrecipient Agreement #11707 (as amended) – Greensboro Housing Coalition & Councilmember Hugh Holston

I. Background

On July 1, 2023, the City of Greensboro entered into a Subrecipient Agreement with the Greensboro Housing Coalition (GHC), amended on October 15, 2023 via First Amendment #11707.

The amendment designates $500,000 solely for Personnel Costs, with funds disbursed quarterly, directly funding GHC staff, including its Executive Director.

Councilmember Hugh Holston is both:

A sitting and compensated member of Greensboro City Council.

The Executive Director of GHC, receiving salary from this contract.

II. Contractual Conflict

The City’s contract provision stipulates:

“Such personnel shall not be employees of or have any contractual relationship with the City.”

As Executive Director, Holston is clearly “personnel” of GHC, which is under a direct contractual relationship with the City, thus violating the provision.

III. North Carolina Statutory Violation

N.C.G.S. § 14-234 prohibits public officials from deriving a direct benefit from contracts they vote on or administer. A direct benefit includes being:

An employee or officer, or

Receiving income directly under the agreement.

Holston meets all criteria: he is an employee/officer of GHC and receives income funded by the contract.

IV. Greensboro Local Ethics Policy

The City of Greensboro has an established Code of Ethics, Gift Policy, and Disclosure Requirements for its Mayor and City Council, as required under N.C.G.S. § 160A-86.

This local policy mandates that Council members must:

Uphold integrity and independence,

Avoid impropriety or appearance thereof, and

Avoid conflicts between personal interests and public duties

Holston’s dual role (as GHC Executive Director and Councilmember who approved the funding) fundamentally conflicts with these principles and undermines public trust.

V. Federal ARPA Compliance Risk

The contract involves federal ARPA funds. Under federal grants management rules (e.g., GMCR), entities must:

Maintain codes of conduct,

Avoid real or apparent conflicts of interest,

Implement safeguards against public officials benefiting from subgrants

Non-compliance may result in audits, findings, and potential fund clawbacks.

VI. Conclusion

Councilmember Hugh Holston’s role as Executive Director of the GHC, the direct recipient of City funding, breaches:

The contract’s personnel clause,

State criminal conflict-of-interest law (N.C.G.S. § 14-234),

Greensboro’s own ethics policy, and

Federal grant compliance standards.

VII. Requested Actions

I respectfully request that the City Attorney’s Office:

Formally review the amended Subrecipient Agreement for contractual and statutory compliance.

Determine appropriate remedies, which may include rescission, recoupment of funds or administrative sanctions.

Publicly disclose the conflict, including whether Holston recused from relevant votes, in line with ARPA transparency expectations.

Recharge ethics training or clarify policy, to prevent similar future conflicts.

If concerns remain unaddressed, consider referral to the NC State Bureau of Investigation (SBI) or U.S. Treasury OIG.

Respectfully submitted,

George Hartzman