Policies / 08-01 · Policy 1 of 13

Conflict of Interest Policy for State Grant-Making

OGM Policy 08-01, effective January 1, 2022 (Version 2 update, January 2026)5:11Based on public OGM policies and Minnesota statutes
Key points

What the policy requires

What counts

Actual or potential. A conflict exists even if nothing improper results.

OGM Policy 08-01, Definitions

Disclosure form

Every reviewer, every competitive review. Name the applicant; context is optional.

OGM Policy 08-01, Min. Req. 1.B; Procedures 1; Minn. Stat. § 10A.07, subd. 1

Individual conflict

Special advantage · money or ownership · employee, board member, or immediate family

OGM Policy 08-01, Definitions (a) to (c)

Who to tell

Supervisor · RFP contact · program manager. If one of them is involved: ethics officer or leadership.

OGM Policy 08-01, Procedures 2 and 5

Tell the panel. Write it down.

Every state employee on the review is told. The resolution is noted in the minutes or grant records.

OGM Policy 08-01, Procedures 5 and 6

What the statute adds

Training for all parties. No conflict-free substitute? Notify interested personnel; the employee may proceed.

Minn. Stat. § 16B.98, subd. 3

Organizational conflict

Impaired objectivity · unfair advantage from information other competitors don't have

OGM Policy 08-01, Organizational Conflict of Interest

Response options

Notify, allow a response, then disqualify, amend or terminate, reassign the grant to another employee, or ask for a mitigation plan

OGM Policy 08-01, Procedures to Avoid Organizational Conflicts 2 and 3

The code of ethics behind it

No gifts or favors tied to your duties. Probable cause of a substantial violation: written report to the Legislative Auditor.

Minn. Stat. § 43A.38, subd. 2; § 43A.39, subd. 2
Team checklist

Questions to ask

  • 1Every reviewer signs a disclosure form, for every competitive review?
  • 2Everyone knows who to tell, including the ethics officer?
  • 3Disclosures and resolutions recorded in minutes or grant records?
Sources

Policy and statutes

Statute links open the Office of the Revisor of Statutes.