STATE OF MICHIGAN

GRETCHEN WHITMER DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS ORLENE HAWKS
GOVERNOR LANSING DIRECTOR

March 6, 2019

Re: Nonparticipation Procedures
Dear Deputy Director:

As the Director of the Department of Licensing and Regulatory Affairs I want to
assure the administration of our department in a manner consistent with applicable law
and ethical obligations. I therefore want to avoid any appearance of or potential for a
conflict of interest relating to Governmental Consultant Services, Inc. or any
business entity that employs GCSI as its lobbyist agent.

As you know, my husband, Mike Hawks, is one of the owners of GCSI. I do not have a
financial or other interest in GCSI. I do not participate in any of its management or
business'activities. GCSI currently is not a party to any contract with LARA. One or more
of the business entities that employs GCSI as a lobbyist agent (as defined in 1978 PA472)
may be a party to a contract with LARA or may seek to contract with LARA in the future.
LARA employees should use the information reported to the Michigan Department of
State under 1978 PA 472 to identify business entities that employ GCSI as a lobbyist
agent

To avoid any appearance of or potential for a conflict of interest, I will not:

(1) hold any financial interest in or participate in any management or other
business activities of 

(2) participate in the negotiating or executing of a contract with GCSI, making
of a loan to GCSI, granting of a subsidy to fixing of a rate charged by
GCSI, issuing of a permit or certificate to GCSI, or the regulating or
supervising of another form of or

(3) participate in the negotiating or executing of a contract with a business entity
that employs GCSI as its lobbyist agent, making of a loan to a business entity
that employs GCSI as its lobbyist agent, (0) granting of a subsidy to a business
entity that employs GCSI as its lobbyist agent, fixing of a rate charged by a
business entity that employs GCSI as its lobbyist agent, issuing of a permit or
certificate to a business entity that employs GCSI as its lobbyist agent, or the
regulating or supervising of another form of a business entity that employs 
as its lobbyist agent.

611 W. OTTAWA PO. BOX 30004 . LANSING, MICHIGAN 48909
517-3734 320

 

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March 6, 2019

I will refrain from participating in a deciSion or action described above relating to GCSI or
any business entity that employs GCSI as its lobbyist agent and delegate the
departmental decision or action to a deputy director of LARA or other agency head within
LARA authorized to make the decision or take the action for LARA. In any such instance,
I ask for your assistance in identifying the appropriate deputy or agency head to act for
LARA.

Sincerely,

jig 
Orlene Ha

Director