Rights you already have · and things to ask for

Conflicts of interest

≈ 5 min read · or listen, or skim the bold lines

A · Primary source   Every section below was read in the published Navajo Nation Code. The Code is current only through 2009; later amendments may exist and are unverified. This page names no person and describes no case. It describes a law. How we verify →

Ask people what the Navajo Nation lacks and someone will say a conflict-of-interest law. That is not the problem. The Nation has one, and it is detailed. The Ethics in Government Law devotes an entire subchapter to the standards of conduct expected of every public official and employee — conflicts, confidential information, outside employment, recusal, contracts, the revolving door, nepotism, and gifts.

The problem is the one this whole site keeps finding. A duty that nobody can see performed is indistinguishable, from the outside, from a duty nobody performs.

What the law already requires

SectionWhat it says, in plain words
2 N.N.C. § 3745
Conflicts of interest
No official or employee may use the authority of their office — or its apparent authority — to place their own economic gain, or that of business interests they are associated with, before the interests of the general public their office exists to serve. Note the phrase “could reasonably be perceived as placing.” The law reaches appearance, not only proof.
§ 3746
Confidential information
No official or employee may use or disclose confidential information gained through their position to further their own economic and personal interest, or anyone else’s.
§ 3747
Incompatible interests
No official or employee may hold direct or indirect financial interests, or take outside employment, that involve an inherent substantial conflict with their public duties — or that appear to.
§ 3748
Abstention — the recusal statement
If an official must act on a matter where they have a personal economic interest, they should first consider eliminating the interest. If they cannot, they shall prepare and sign a written statement describing the matter and the nature of the conflict, and deliver copies for inclusion in the official record of the vote or decision, and to the Ethics and Rules Committee. Then they must abstain — from voting, sponsoring, and from attempting to influence the outcome in any manner.
§ 3749
Contracts
Restrictions on Navajo Nation government contracts and bidding, including where an official or a member of their immediate family stands to profit. Who enforces it.
§§ 3750–3751
The revolving door
An official or employee may not represent other people or entities for compensation before governmental bodies on non-ministerial matters. And after leaving office, a former official — or their partners, employees, or associates — may not act as agent or attorney representing others before the Nation on matters within the reach of the rule.
§ 3752 · § 3753
Compensation & property
No unauthorized compensation or benefit for official acts. No personal use of the Nation’s property or funds.
§ 3755
Anti-nepotism
No official or employee may employ, appoint, nominate, or influence the hiring of any person related to them within the third degree by blood or marriage, nor anyone in the same household.
§§ 3756–3757
Gifts and loans
No soliciting or accepting gifts, favors, services, loans, or economic opportunities that could influence official acts — with defined exceptions for permitted gifts, awards, reimbursements, and campaign contributions.

The document that should exist — and the thing to ask for

FINDING

Read § 3748 again. When an official has a conflict, the law does not merely tell them to step back quietly. It requires a signed, written statement naming the matter and the nature of the conflict, placed in the official record of the vote, and filed with the Ethics and Rules Committee.

That means these documents are supposed to be part of the public record of decisions the people’s government makes. This project could not locate any published collection of them, nor any count of how many are filed in a year. We also could not locate published case counts or dispositions from the Ethics and Rules Office.

So the ask is narrow, cheap, and hard to argue with: publish the § 3748 recusal statements, and publish how many ethics complaints are filed and how they end. Not names of complainants. Not open investigations. The statements the law already requires officials to sign, and the numbers the office already has.

Why we will not name anyone here

FINDING

It would be easy to build a page pairing officials with their relatives, employers, and former clients, and to invite readers to draw conclusions. This site will not do that, and the reason is not squeamishness.

An appearance of conflict is not a finding of one. The law itself makes the distinction: § 3745 reaches conduct that could reasonably be perceived as self-dealing, and that standard exists to protect public trust — not to license strangers to assign motives from a distance. A person who serves in a small nation will often have a cousin who works somewhere, an employer they once worked for that has business before a committee, a professional life that predates their office. The remedy the law provides for that ordinary fact is disclosure and abstention, in writing, on the record. Which is exactly the document nobody publishes.

So this page asks for the record instead of guessing at what is in it. If the recusal statements were published, no one would need to speculate about anyone. That is the whole design.

TAKE ACTION

Three questions with correct answers

To any candidate: “§ 3748 requires a signed recusal statement in the official record. Have you ever filed one — and would you publish them?” To a Council candidate: “Ethics and Rules reports to the Law and Order Committee. Will you require it to publish case counts and dispositions?” To a candidate for President: “What conflict would you have on your first day, and how would you handle it?”

Learn the machinery first: Ethics & Rules, explained · the Right Door guide · the Law Ledger. If you tried to see a recusal statement, tell us what happened on Participate.

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