Summary
The Leelanau County Board of Commissioners' Conflict of Interest and Complaint Policy Committee met on May 14, 2026, with Commissioners Alan Campbell, Gwenne Allgaier, and Steve Yoder present. The committee elected Campbell as Chairman and spent the bulk of the meeting reviewing and revising a draft County Code of Ethics and a draft Conflict of Interest Policy. No final policy was adopted; Administrator James Dyer will incorporate Campbell's definitions into his proposed structure and prepare a new draft for the next meeting, tentatively scheduled for June 12, 2026 at 2:00 p.m.
Other Business
Human Resources Manager Jennifer Kain recapped a customer service training held earlier in the year, attended by 18 people, which highlighted the need for clearer ethics guidance since employees often struggle to know "where to draw the line."
The committee then reviewed a draft Code of Ethics (adapted by Campbell from a Grand Traverse County model) section by section. Notable revisions discussed: adding "and attendees at conferences" to the list of allowable benefits (Section II.C.1); raising the allowable value of food/refreshments from $75 to $100; changing wording in Section II.E to "which results in a personal profit" instead of "which may profit"; clarifying that employee records "will be used and released only as necessary consistent with applicable law" (Section II.J, per Dyer, citing the Bullard Plawecki Right to Know Act); routing reports of misuse of County assets to the Administrator first (Section II.K); and allowing use of the County seal by the "County Clerk or other authorized elected official" (Section II.N). Administrator Dyer said he could not support Section II.I as written and said it needs clearer language prohibiting illegal discrimination or harassment. Section II.G, regarding recusal procedures, will be referred to legal counsel for guidance.
Members also agreed to reorganize the document, moving "Definitions" to Section II and "Guidelines" to Section III, and discussed defining "person" broadly to include commissioners, elected officials, employees, and members of public bodies rather than listing categories separately.
The committee discussed, but did not decide, whether to form an ethics panel. Chairman Campbell said he had been in favor of a panel but now has doubts about its feasibility, and raised the possibility of the full Board of Commissioners serving as the appellate body instead. Commissioner Allgaier stated she thinks the Board should serve this role. Administrator Dyer noted any panel structure would require legal advice.
The complaint filing procedure, investigative and determination processes, and range of penalties were listed on the agenda but not discussed at this meeting.
Action Items
- Administrator Dyer to incorporate Campbell's ethics definitions into his Conflict of Interest Policy draft structure and prepare a revised draft for the next meeting.
- Administrator Dyer to consult legal counsel regarding recusal procedures (participation, seating, or commenting when recused) under Section II.G.
- Committee to further discuss Section I (Purpose) and its relationship to Board Policy 1.07 (Nonunion Personnel Policy) as a separate discussion point.
- Next committee meeting tentatively scheduled for June 12, 2026 at 2:00 p.m.