Minnesota Department of Transportation

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MnDOT Policies

Code of Ethical Conduct

MnDOT Policy #WF008
Revised: September 28, 2022

View/print signed policy (PDF)

Please go to the MnDOT Org Chart to find specific contact information: Org Chart.

Responsible Senior Officer: Deputy Commissioner/Chief Administrative Officer
Policy Owner: Director, Office of Human Resources
Policy Contact: Labor Relations Manager

Policy statement

The Minnesota Department of Transportation (MnDOT) fully adopts the enterprise policy, Code of Ethical Conduct, HR/LR #1445, which is issued by Minnesota Management Budget (MMB) and incorporated herein by reference.

MnDOT employees are held to the highest standard of honesty, integrity, and ethical behavior. MnDOT employees have a duty to the people of Minnesota and must act in the public interest. All MnDOT employees must comply with this Code of Ethical Conduct Policy to:

  • Ensure compliance with the Code of Ethics for Employees in the Executive Branch found in Minnesota Statutes §43A.38, and other applicable law
  • Avoid any appearance of impropriety
  • Maintain the public trust
  • Ensure the use of state resources for state purposes
  • Strengthen governance processes
  • Increase accountability in state government

Within 60 days of hire/rehire at MnDOT, transfer/demotion/promotion from a different state agency, or upon promotion for the first time to a supervisory/managerial position, all MnDOT employees must complete the Code of Ethical Conduct training and the Code of Ethical Conduct Acknowledgment and Disclosure Form in Enterprise Learning Management (ELM).

Annually thereafter, all MnDOT employees must recertify by completing the Code of Ethical Conduct training and the Code of Ethical Conduct Acknowledgment and Disclosure Form in ELM.

As provided in HR/LR Policy #1401 Voting Leave and Other Election Topics, employees who run for elected public office must obtain a conflicts of interest opinion from MMB.

Violations of this policy, significant internal control weaknesses, evidence of theft, embezzlement, or unlawful use of public funds or property must be reported through designated agency channels.

Employees who violate this policy may be subject to discipline, up to and including discharge. Violation of this policy also may be subject to criminal penalties as provided in Minnesota Statutes §43A.39 and other law.

Reason for policy

The purpose of this policy is to:

  • safeguard the reputation of MnDOT and the State of Minnesota
  • safeguard MnDOT employees
  • safeguard state assets
  • establish expectations for ethical conduct
  • ensure compliance with the law, Minnesota Statutes §43A.38:
    • Subd. 2. Acceptance of gifts; favors
    • Subd. 3. Use of confidential information
    • Subd. 4. Use of state property or time
    • Subd. 5. Conflicts of interest


All MnDOT employees must comply with MnDOT policies.


Designated Agency Channels

Designated agency channels for reporting include:


All MnDOT employees must comply with the responsibilities identified in the enterprise policy, Code of Ethical Conduct, HR/LR #1445.

Agency Ethics Officer

  • Review potential conflicts of interest, whether disclosed or discovered.
  • Determine whether mitigating measures are needed to address a conflict of interest.
  • Issue written decisions.
  • Retain decisions according to the Records Retention Schedule.
  • Raise issues of concern to the commissioner or other department leaders.
  • Refer issues to Office of Audit, HR, or OED for additional action, as needed.

Policy Owner (Director, Office of Human Resources)

  • Coordinate and monitor employee completion of required training.
  • Review the policy every two years, or whenever MMB changes the enterprise policy, to ensure the policy remains up-to-date.
  • Ensure resources and forms associated with the policy remain current.
  • Monitor state, federal, enterprise, agency, or other requirements that apply to the policy or procedures.
  • Ensure the policy and procedures remain compliant with all state, federal, enterprise, agency, or other requirements and that necessary approvals by state or federal agencies are obtained before changes to the policy or procedures are implemented.
  • Work with the Policy Coordinator to revise the policy and/or confirm its accuracy.
  • Communicate policy revisions, reviews, and retirements to stakeholders.

Resources and related information


Processes, Procedures, and Instructions


History and updates


August 6, 2013


  • Policy 3.21 - Administration No. 94-2, Code of Ethics
    • Effective: June 1, 1994
    • First Revision: February 10, 1998
    • Second Revision: June 20, 2003
  • Guideline 3.21-G1 - Administration No. 94-2, Code of Ethics Guidelines


  • First Revision: September 28, 2022

Policy Review

This policy's next scheduled review is due September 2024.