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Conflicts of interest: Former state auditor says, “disclose more, not less, and do it publicly.”

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Rob Shelton | Lehi Free Press

John Dougall has seen what happens when government officials don’t talk about their conflicts of interest. It doesn’t end well.

“People start to speculate,” said Dougall, who spent 12 years as Utah’s State Auditor before leaving office in January 2025. “Even if you’re fair, reasonable and appropriate, not disclosing causes people to speculate about improprieties and that starts causing other issues.”

It’s advice that couldn’t be timelier for North Utah County. Since the fall 2025 elections, readers have asked for information about potential conflicts of interest involving elected city officials, the Alpine School District (ASD) and three newly created districts to replace it: Lake Mountain, Aspen Peaks and Timpanogos. Three new school boards were sworn in November 2025 and are now in a multi-year transition, with ASD set to officially dissolve in July 2027.

To address these concerns, and help the public understand what the law actually requires, The Lehi Free Press is publishing a three-part series.

This first article focuses on what a potential conflict of interest is and draws on insights from former State Auditor John Dougall, who now serves as administrator of the Utah Attorney General’s office. Dougall knows the terrain.

Before his dozen-year run as state auditor, he spent a decade in the Utah House of Representatives, where he chaired the House Ethics Committee and served as vice chair of the powerful Executive Appropriations Committee. He holds degrees in electrical engineering and an MBA from Brigham Young University and recently earned his law degree from Syracuse University. As an auditor, he built a reputation for pushing transparency as a standard, not an afterthought.

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His message on conflicts of interest is blunt: “Disclose more, not less, and do it publicly.”

“I would always encourage folks to add more detail,” he said. “Hopefully that reduces the speculation that might exist if disclosures are more vague.”

When it comes to local government, Dougall said the most critical area is the bidding and procurement process. The principle is straightforward: if your company is competing for a contract, you shouldn’t be the one deciding who wins it or oversees it.

“You want to make sure you’re not on both sides of that arrangement,” he said. “If your company is bidding, you shouldn’t be part of the selection process. You need separation.”

The core concern, he said, is keeping the process clean, not closing government contracts off to companies run by elected officials, but making sure no one has their thumb on the scale.

“All bidders should have a fair chance at winning the bid,” Dougall explained. “That’s what you’re trying to protect.”

Trickier situations arise when an elected official serves two organizations that interact with each other, such as a city council member who also sits on a special service district, or a board member or employee serving two entities involved in a district split.

“You just have to work very hard to make sure folks know what the conflict is,” Dougall said. “You’re above board about what you’re doing, trying to fairly represent both organizations, because technically you’re a fiduciary for both.”

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He acknowledged that complete avoidance isn’t always possible. When it isn’t, the burden falls on the official to be visibly fair to all sides and to say so publicly.

On whether Utah’s current conflict-of-interest statutes are strong enough, Dougall offered a measured but direct assessment. State law, he said, is a minimum threshold, a floor every governmental entity must meet.

But local governments can go further, and state law doesn’t stop them.

“Governmental entities can choose to set additional requirements,” he said. “Fundamentally, it comes down to the individual official just looking at where am I going to be: what are the potential risks, concerns, public perception, and how do I help people better understand what conflicts exist?”

He was careful not to argue for heavier-handed state intervention. The push-and-pull between local control and statewide standards is a familiar tension in Utah politics, and Dougall respects it. But he was clear about the risk of staying vague: when officials don’t disclose, even fair and reasonable decisions invite speculation.

“We all have conflicts,” he said. “Some are greater than others. There’s always that element of potential conflict. It’s just trying to help folks understand here’s what’s there, and here’s how you’re trying to make the best decisions within that arena.”

Asked what he considered best-practice behavior from his years auditing state and local governments, Dougall didn’t cite a policy or a statute. He pointed to individual character.

“The best practices I saw were when elected officials were just really upfront,” he said. “‘Here’s what I do, here’s why I have potential conflicts in this arena.’ That’s when their constituents say, OK, they’re being upfront, they’re disclosing it, they’re not hiding anything,’ and they can see that person is making the best decisions and trying to minimize their conflict to the greatest extent possible.”

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The contrast was stark, he said. Officials who appeared to favor their own companies or family members without disclosure- that’s where problems arose. Not always from actual wrongdoing, but from the perception of it.

“People didn’t have to inquire about them,” he said of the Legislature’s conflict disclosures. “They were just there, 24/7.”

It’s a simple standard: Whether officials in city government, the Alpine School District and the three new replacement districts- Lake Mountain, Aspen Peaks and Timpanogos- are meeting the standard is what this series aims to find out.

“People didn’t have to inquire about them,” he said of the Legislature’s conflict disclosures. “They were just there, 24/7.”

It’s a simple standard: Whether officials in city government, the Alpine School District and the three new replacement districts: Lake Mountain, Aspen Peaks and Timpanogos, are meeting the standard is what this series aims to find out.

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