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Minnesota Department of Commerce <br />Commerce Fraud Bureau <br />Conflicts of Interest <br />State grant policy requires thatsteps and procedures are in place to prevent individual and <br />organizational conflicts of interest, both in reference to applicants and reviewers per Minn. Stat.§16B.98 <br />Subd. 2-3and08-01 Conflict of Interest in State Grant-Making Policy effective date 1/1/21. <br />Organizational conflicts of interest occur when: <br />a grantee or applicant is unable or potentially unable to render impartial assistance or advice to <br />the Department due to competing duties or loyalties <br />a grantee’s or applicant’s objectivity in carrying out the grant is or might be otherwise impaired <br />due to competing duties or loyalties <br />In cases where a conflict of interest is in question ordisclosed, the applicants or grantees will be notified <br />and actions may be pursued, including but not limited to,revising the grant work plan or grantee duties <br />to mitigate the risk, requesting the grant applicant to submit an organizational conflict of interest <br />mitigation plan, disqualification from eligibility for the grant award, amending the grant,or termination <br />of the grant contract agreement. <br />Public Data <br />Per Minn. Stat. §13.599 <br />Names and addresses of grant applicantsand amount requestedwill be public data once <br />proposal responses are opened. <br />All remaining data in proposal responses (except trade secret data as defined and classified in <br />§13.37) will be public data after the evaluation process is completed. For the purposes of this <br />grant, when all grant contract agreements have been fully executed. <br />All data created or maintained by the Commerce Fraud Bureauas part of the evaluation process <br />(except trade secret data as definedand classified in §13.37) will be public data after the <br />evaluation process is completed. For the purposes of this grant, when all grant contract <br />agreements have been fully executed. <br />Grant Payments <br />Per Policy 08:Grant Paymentsreimbursement is the preferred method for making grant payments. All <br />grantee requests for reimbursement must correspond to the approved grant budget. The State shall <br />review each request for reimbursement against the approved grant budget, grant expenditures to-date <br />and the latest grant progress report before approving payment. Grant payments shall not be made on <br />grants with past due progress reports unless Commerce Fraud Bureauhas given the grantee a written <br />extension. <br />Grant Monitoring <br />Minn. Stat. §65B.84require annual auditing of plans and programs funded by this grant.The state’s <br />program manager willhaveperiodic monitoring visits to evaluate and assist in the success of <br />the grant. <br />Audits <br />Per Minn. Stat. §16B.98Subdivision 8, the grantee’s books, records, documents, and accounting <br />procedures and practices of the grantee or other party that are relevant to the grant or transaction are <br />subject to examination by the granting agency and either the legislative auditor or the state auditor, as <br />Dedicated Auto Theft InvestigatorGrant Page 5of 6 <br /> <br />