Oneida Business Committee (2026)

Tribal code

Ask Donna

What actually matters in this document.

Text

1 of 289

Oneida Nation

Oneida Business Committee

Legislative Operating Committee

PO Box 365 • Oneida, WI 54155-0365

Oneida-nsn.gov

ONEIDA

LEGISLATIVE OPERATING COMMITTEE MEETING AGENDA REVISED

Business Committee Conference Room - 2nd Floor Norbert Hill Center

March 18, 2026

9:00 a.m.

Call to Order and Approval of the Agenda

II.

Minutes to be Approved

1. March 4, 2026 LOC Meeting Minutes (pg. 2)

III.

Current Business

1. Code of Ethics Amendments (pg. 5)

2. Pardon and Forgiveness Law Amendments (pg. 40)

3. Recycling and Solid Waste Disposal Law Amendments (pg. 69)

4. Budget and Finances Law Amendments (pg. 112)

5. Boards, Committees, and Commissions Law Amendments (pg. 158)

IV.

New Submissions

Additions

VI.

Administrative Updates

1. Certification of Leasing Law Rule No. 2 – Agricultural Leasing Amendments (pg. 207)

VII.

Executive Session

VIII. Recess/Adjourn

A good mind. A good heart. A strong fire.

2 of 289

Oneida Nation

r'\

Oneida Business Committee

Legislative Operating Committee

GDDDOO

PO Box 365 • Oneida, WI 54155-0365

ONEIDA

Oneida-nsn.gov

LEGISLATIVE OPERATING COMMITTEE MEETING MINUTES

Oneida Business Committee Conference Room-2nd Floor Norbert Hill Center

March 4, 2026

9:00 a.m.

Present: Jameson Wilson, Jennifer Webster, Kirby Metoxen, Jonas Hill

Unexcused: Marlon Skenandore

Others Present: Grace Elliott, Carolyn Salutz

Others Present on Microsoft Teams: Rae Skenandore, Ashley Blaker, Rhiannon Metoxen,

Clorissa Leeman, Kaylynn Beily, Trina Schuyler, Fawn Billie, Kristal Hill, Tavia James-Charles,

Fawn Cottrell, Peggy Helm-Quest, Melissa Alvarado. Grace Koehler, Joel Mikulsky, Misty Lee

Herzog, Sidney White, Ralinda Ninham-Lambries, Ronald Van Schyndel, Linda Dallas, Terri

Schiltz, Diane Wilson.

Call to Order and Approval of the Agenda

Jameson Wilson called the March 4, 2026, Legislative Operating Committee meeting to

order at 9:00 a.m.

Motion by Jennifer Webster to adopt the agenda; seconded by Kirby Metoxen. Motion

carried unanimously.

II.

Minutes to be Approved

1. February 18, 2026 LOC Meeting Minutes

Motion by Kirby Metoxen to approve the February 18, 2026, LOC meeting minutes and

forward to the Oneida Business Committee; seconded by Jennifer Webster. Motion carried

unanimously.

III.

Current Business

1. Elder Protection Law

Motion by Jonas Hill to approve the legislative analysis and the public meeting packet for

the Elder Protection Law and forward to a public meeting to be held on April 16, 2026;

seconded by Kirby Metoxen. Motion carried unanimously.

2. Uniform Commercial Code. Motion by Jennifer Webster to approve the legislative

analysis and the public meeting packet for the Elder Protection Law and forward to a public

meeting to be held on April 16, 2026; seconded by Kirby Metoxen. Motion carried unanimously.

<XXXXX)

A good mind. A good heart. A strong fire.

Legislative Operating Committee Meeting Minutes of February 18, 2026

Page 1 of 3

ONEIDA

3 of 289

3. Real Property Law. Motion by Jennifer Webster to approve the updated draft, legislative analysis, and the public comment review memorandum for the proposed amendments

to the Real Property law; seconded by Jonas Hill. Motion carried unanimously.

4. Real Property Law. Motion by Jonas Hill to direct the Finance Department to provide

the LOC with a fiscal impact statement of the proposed amendments to the Real Property

law; seconded by Jennifer Webster. Motion carried unanimously.

5. Higher Education Grant Law. Motion by Jennifer Webster to approve the updated

draft, legislative analysis, and the public comment review memorandum for the Higher

Education Grant law; seconded by Jonas Hill. Motion carried unanimously.

6. Higher Education Grant Law. Motion by Kirby Metoxen to approve the updated draft,

legislative analysis, and the public comment review memorandum for the proposed amendments to the Higher Education Grant law; seconded by Jonas Hill. Motion carried unanimously.

7. Recycling and Solid Waste Disposal Law Amendments. Motion by Jennifer Webster

to accept the public comments and the public comment review memorandum and defer to

a work meeting for further consideration; seconded by Jonas Hill. Motion carried unanimously.

8. Eviction and Termination Law Amendments. Motion by Jennifer Webster to approve

the public meeting packet for the Eviction and Termination Law Amendments and forward

to a public meeting to be held on April 16, 2026; seconded by Kirby Metoxen. Motion

carried unanimously.

9. Petition: G. Powless-Buenrostro – Accountability Measure Options for BC and

BCC’s #2025-04. Motion by Jennifer Webster to accept the statement of effect for the

Petition: G. Powless-Buenrostro – Accountability Measure Options for BC and BCC’s

#2025-04 and forward to the Oneida Business Committee; seconded by Jonas Hill. Motion

carried unanimously.

10. Petition: G. Powless-Buenrostro – Amend the Administrative Rulemaking Law

#2025-05. Motion by Jennifer Webster to accept the public comments and the public comment review memorandum and defer to a work meeting for further consideration; seconded

by Jonas Hill. Motion carried unanimously.

11. Budget and Finances Law Amendments. Motion by Jennifer Webster to accept the

public comments and the public comment review memorandum and defer to a work meeting for further consideration; seconded by Jonas Hill. Motion carried unanimously.

IV.

New Submissions

Additions

VI.

Administrative Updates

1. E-Poll Results: Safe Neighborhoods Law Emergency Adoption. Motion by Jennifer

Webster to enter into the record the results of the February 23, 2026, e-poll entitled, Safe

Legislative Operating Committee Meeting Minutes of February 18, 2026

Page 2 of 3

4 of 289

Neighborhoods Law Emergency Adoption; seconded by Jonas Hill. Motion Carried unanimously.

VII.

Executive Session

VIII. Adjourn

Motion by Jennifer Webster to adjourn at 10:24 a.m.; seconded by Jonas Hill. Motion carried unanimously.

Legislative Operating Committee Meeting Minutes of February 18, 2026

Page 3 of 3

5 of 289

r'\.

Oneida Nation

Oneida Business Committee

Legislative Operating Committee

PO Box 365 • Oneida, WI 54155-0365

Oneida-nsn.gov

=DODDDD=

ONEIDA

Legislative Operating Committee

March 18, 2026

Code of Ethics Law Amendments

Submission Date: 10/26/22

LOC Sponsor: Jennifer Webster

Public Meeting: N/A

Emergency Enacted: N/A

Summary: This item was carried over from last four (4) terms. Amendments to the Code of

Ethics are being sought to strengthen accountability of employees, elected officials, and

appointed officials. On October 26, 2022, the Oneida Business Committee adopted a motion to

request the Legislative Operating Committee to consider deletion of section 103.7 from the Code

of Ethics.

10/4/23 LOC: Motion by Jonas Hill to add the Code of Ethics Law Amendments to the Active Files

List with Jennifer Webster as the sponsor; seconded by Marlon Skenandore. Motion

carried unanimously.

4/1/25:

Work Meeting. Present: Jameson Wilson, Jonas Hill, Kirby Metoxen, Fawn Cottrell,

Kristal Hill, Grace Elliott. The purpose of this meeting was to begin the initial review

of the Code of Ethics. The history of the Code of Ethics and related laws were

considered prior to reading through the law.

5/5/25:

Work Meeting. Present: Jameson Wilson, Jennifer Webster, Fawn Billie, Fawn

Cottrell, Kristal Hill, Clorissa Leeman, Carolyn Salutz, Grace Elliott. The purpose of

this meeting was to review potential reporting processes and a draft reporting form.

5/13/25:

Work Meeting. Present: Matthew Denny, Rita Reiter, Laura Laitinen-Warren, Grace

Elliott. The purpose of this meeting was to hear initial thoughts from the Human

Resource Department on the Code of Ethics.

6/6/25:

Work Meeting. Present: Jameson Wilson, Jonas Hill, Kirby Metoxen, Marlon

Skenandore, Kristal Hill, Clorissa Leeman, Carolyn Salutz, Grace Elliott. The

purpose of this meeting was to review feedback from the Nation’s human resource,

law enforcement, and gaming divisions in relation to the Nation’s Code of Ethics.

The LOC determined to eliminate the program and enterprise sections from the law as

they are addressed in the Nation’s personnel, policies, and procedures, and to focus

on expanding the government official ethics sections.

7/28/25:

Work Meeting. Present: Jameson Wilson, Jennifer Webster, Jonas Hill, Marlon

Skenandore, Carolyn Salutz, Fawn Billie, Fawn Cottrell, Kristal Hill, Grace Elliott.

The purpose of this meeting was to review the overlap in conflict of interest

regulation in the Conflict of Interest law and the Code of Ethics. The LOC

Page 1 of 3

A good mind. A good heart. A strong fire.

6 of 289

determined that all government official conflict of interest subject matter should be

aggregated and addressed within the Code of Ethics law exclusively.

10/17/25:

Work Meeting. Present: Jameson Wilson, Jennifer Webster, Kirby Metoxen, Fawn

Cottrell, Kristal Hill, Rhiannon Metoxen, Laura Laitinen-Warren, Carolyn Salutz,

Grace Elliott. The purpose of this meeting was to review the section of the draft

addressing a potential prohibition on elected officials applying for positions within

the Nation while in office.

11/14/25:

Work Meeting. Present: Jameson Wilson, Kirby Metoxen, Jennifer Webster, Jonas

Hill, Fawn Cottrell, Rhiannon Metoxen, Grace Elliott, Kristal Hill. The purpose of

this meeting was to review the revised employment application section, alternate

definitions, tone and language adjustments, gifts and honorarium section,

enforcement and restorative justice sections, and identify next steps.

11/19/25:

Work Meeting. Present: Grace Elliott, Peggy VanGheem. The purpose of this meeting

was to collaborate with the Law Office, receive questions or concerns, and identify

suggestions that may be incorporated into the draft or flagged for further group

discussion.

1/9/26:

Work Meeting. Present: Jameson Wilson, Kirby Metoxen, Jennifer Webster, Laura

Laitinen-Warren, Carolyn Salutz, Clorissa Leeman, Grace Elliott, Peggy VanGheem,

Kristal Hill, Fawn Cottrell, Rhiannon Metoxen. The purpose of this meeting was to

review the draft amendments against the checklist to ensure that the latest edits met

expectations.

1/15/26:

Work Meeting. Present: Jameson Wilson, Jennifer Webster, Laura Laitinen-Warren,

Carolyn Salutz, Grace Elliott. The purpose of this meeting was to review

documentation related to the decision to focus the Code of Ethics on the OBC.

Consensus was to continue on this path.

1/29/26:

Work Meeting. Present: Jameson Wilson, Jennifer Webster, Jonas Hill, Kirby

Metoxen, Carolyn Salutz, Clorissa Leeman, Grace Elliott. The purpose of this

meeting was for the LOC to reconsider the scope of the Code of Ethics. LOC

determined that the Code of Ethics be limited to Oneida Business Committee based

on information provided that employees are effectively regulated by the Personnel,

Policies and Procedures and Conflict of Interest laws, BCCs are effectively regulated

under the BCC, Conflict of Interest, and Removal laws—in addition to the fact that

the BCC and Conflict of Interest laws are both currently open on the Active Files list

and may be amended as necessary to enhance already present protections.

Additionally, the LOC has accepted several requests for stand alone laws to address

OBC ethics related matters that can be most efficiently and effectively addressed

under the Code of Ethics.

2/4/26:

Work Meeting. Present: Jameson Wilson, Jennifer Webster, Jonas Hill, Clorissa

Leeman, Carolyn Salutz, Grace Elliott. The purpose of this meeting was for the LOC

to review various sections of the draft law. Decision was made to remove any

references to enforcement provisions.

A good mind. A good heart. A strong fire.

Page 2 of 3

ONEIDA

7 of 289

2/16/26:

Work Meeting. Present: Jameson Wilson, Jennifer Webster, Jonas Hill, Kirby

Metoxen, Carolyn Salutz, Grace Elliott. The purpose of this meeting was review the

entire draft for potential LOC approval and to specifically review the reporting

processes for gift and conflict of interest disclosures. The LOC requested definitions

for “sacred trust” and information on federal standards for meeting conduct and

acceptance of gifts. Follow-up is scheduled for 2/18/26.

2/18/26:

Work Meeting. Present: Jameson Wilson, Jennifer Webster, Jonas Hill, Kirby

Metoxen, Carolyn Salutz, Kristal Hill, Fawn Billie, Grace Elliott. The purpose of this

meeting was to review definitions of sacred trust language and review federal

standards for employees and elected officials’ acceptance of gifts. The LOC chose to

incorporate all six definitions of sacred trust within the law, and determined to set the

gift reporting threshold at one thousand dollars to address the request for reporting

lavish gifts.

2/23/26:

Work Meeting. Present: Jameson Wilson, Jennifer Webster, Jonas Hill, Kirby

Metoxen, Carolyn Salutz, Kristal Hill, Fawn Billie, Grace Elliott. The purpose of this

meeting was to review sacred trust language placement within the law and refine

language.

3/4/26:

Work Meeting. Present: Jameson Wilson, Jennifer Webster, Jonas Hill, Kirby

Metoxen, Carolyn Salutz, Kristal Hill, Fawn Billie, Clorissa Leeman, Grace Elliott.

The purpose of this meeting was to complete a read through of the entire law for LOC

review and initial approval to move forward through the legislative process.

Next Steps:

▪ Approve the draft Code of Ethics law amendments, legislative analysis, and public meeting

packet for the Code of Ethics law amendments and schedule a public meeting to be held on

May 14, 2026.

A good mind. A good heart. A strong fire.

Page 3 of 3

ONEIDA

8 of 289

Analysis to Draft 1

2026 03 18

CODE OF ETHICS

LAW AMENDMENTS

LEGISLATIVE ANALYSIS

SECTION 1. EXECUTIVE SUMMARY

Intent of the

Legislation or

Amendments

Analysis by the Legislative Reference Office

▪ Update the Code of Ethics so it clearly focuses on the Oneida Business

Committee, bringing all expectations for how leaders should conduct

themselves into one easy-to-understand law. [1 O.C. 103.1–103.4].

▪ Integrate the Great Law of Peace into the ethical foundation, affirming

decision-making grounded in peace, unity, and thoughtful deliberation as

cultural mandates for governance. [1 O.C. 103.3-1(c)].

▪ Ground the ethical framework in the Good Mind teachings, infusing leadership

obligations with humility, compassion, clarity, and community-centered

thinking. [1 O.C. 103.1-2].

▪ Articulate the concept of Sacred Trust, emphasizing leadership as a duty held

on behalf of past, present, and future generations rather than an individual

entitlement. [1 O.C. 103.4-1(c)].

▪ Clarify the definition of “Conflict of Interest” to encompass financial, personal,

and political interests affecting leaders and their immediate families,

reinforcing impartial stewardship. [1 O.C. 103.3-1(a)].

▪ Mandate transparent disclosure of conflicts, ensuring ethical clarity consistent

with the Good Mind’s call for honesty and openness in governance. [1 O.C.

103.4-2(a)].

▪ Require OBC members to recuse themselves from matters in which conflicts

exist, upholding the Great Law of Peace’s expectation that leaders avoid

self-interest. [1 O.C. 103.4-2].

▪ Implement structured annual and as-needed conflict-of-interest filings, creating

accountability mechanisms that reinforce responsible leadership. [1 O.C.

103.4-2(c)(1)–(3)].

▪ Modernize gift and honoraria reporting by increasing financial thresholds and

updating reporting processes to better reflect contemporary governance

realities including public disclosure. [1 O.C. 103.4-9(b)].

▪ Prohibit acceptance of gifts tied to influence or business advantage, protecting

the Nation’s decision-making from external pressure and maintaining

community trust. [1 O.C. 103.4-9(a)].

▪ Regulate OBC members’ applications for positions that report directly to the

Committee, preventing conflicts before they arise and strengthening procedural

fairness. [1 O.C. 103.4-8].

▪ Safeguard confidential information by restricting its use for personal, financial,

or political benefit, aligning with the Haudenosaunee value of responsible and

respectful speech. [1 O.C. 103.4-3].

▪ Promote fairness and impartiality in leadership actions, ensuring decisions are

made through unbiased judgment grounded in the Good Mind and collective

well-being. [1 O.C. 103.4-5].

Page 1 of 8

9 of 289

Analysis to Draft 1

2026 03 18

▪

Purpose

Affected Entities

Related Legislation

Enforcement

Due Process

Public Meeting

Fiscal Impact

Prohibit nepotism in hiring, supervision, and resource decisions, maintaining

equitable access and protecting the legitimacy of OBC leadership.[1 O.C.

103.4-7].

▪ Reinforce accountability and transparency as essential qualities of public

office, affirming that OBC authority flows from the people and must remain

answerable to them. [1 O.C. 103.4-6].

▪ Elevate cultural accountability by requiring OBC members to conduct

themselves in ways that honor Oneida identity, teachings, and responsibilities.

[1 O.C. 103.4-11].

▪ Strengthen expectations for meeting attendance, preparation, and professional

engagement, acknowledging that presence and participation are integral to

carrying the Sacred Trust. [1 O.C. 103.4-12].

▪ Codify a comprehensive list of prohibited behaviors—including retaliation,

discrimination, misuse of office, and corruption—to uphold dignity and protect

community confidence in leadership. [1 O.C. 103.4-10].

▪ Align enforcement with broader Nation laws to ensure consistency, due

process, and integrity in the handling of ethical violations. [1 O.C. 103.5].

The purpose of this law is to is to establish clear standards of conduct rooted in the

values of the Oneida people, to guide those entrusted with authority in serving the

Nation with honor and responsibility. These standards reflect the sacred trust

between the government and the people, and are intended to promote integrity,

uphold the will of the Nation, and preserve the confidence of the Oneida people. In

a government founded upon the consent of the people, it is the right of the Oneida

to expect loyalty, honesty, and accountability from those who serve. [1 O.C. 103.11].

Oneida Business Committee; Office of the Nation Secretary; Oneida Law Office;

Elected Officials; Appointed Officials; Employees of the Nation and its

enterprises.

Boards, Committees, and Commissions law; Conflict of Interest law; Removal law.

Enforcement of this law shall be conducted in accordance with all applicable laws

and regulations of the Nation. [1 O.C. 103.5]

The Code of Ethics law incorporates core due process protections by clearly

defining prohibited conduct and ethical obligations in advance, thereby providing

notice to Oneida Business Committee members of the standards governing their

conduct [1 O.C. 103.4, 103.4-10]. It establishes mandatory conflict-of-interest

disclosure and recusal procedures to ensure impartial decision-making and prevent

biased participation [1 O.C. 103.4-2(a)–(c)] and expressly prohibits retaliation

against individuals who report unethical behavior, safeguarding fair enforcement

and participation in accountability processes [1 O.C. 103.4-10(e)]. The law further

reinforces due process through transparency and public accountability

requirements, including open governance practices, public records, and disclosure

of gifts and honoraria [1 O.C. 103.4-6(b), 103.4-9(b)–(c)]. Finally, enforcement is

constrained by a requirement that all actions be taken in accordance with applicable

Oneida laws, preventing arbitrary or ad hoc application [1 O.C. 103.5].

A public meeting has not yet been held.

A fiscal impact statement prepared in accordance with the Legislative Procedures

Act has not yet been requested.

Page 2 of 8

10 of 289

Analysis to Draft 1

2026 03 18

SECTION 2. LEGISLATIVE DEVELOPMENT

A. Background. The Code of Ethics was previously adopted and amended as follows: minutes 10-21-91;

resolution BC-11-23-94-A; emergency amendment BC-04-12-06-JJ; amended BC-09-27-06-E.

B. Request for Amendments. The Code of Ethics was carried over from last four (4) terms.

Amendments to the Code of Ethics are being sought to strengthen accountability of employees,

elected officials, and appointed officials. On October 26, 2022, the Oneida Business Committee

adopted a motion to request the Legislative Operating Committee to consider deletion of section

103.7 from the Code of Ethics.

SECTION 3. CONSULTATION AND OUTREACH

▪

•

Representatives from the following departments or entities participated in the development of the

amendments to this Law and legislative analysis:

▪ Oneida Human Resources;

▪ Oneida Gaming;

▪ Oneida Police Department; and

▪ Oneida Law Office;

The following laws of the Nation were reviewed in the drafting of this analysis:

▪ Conflict of Interest law

▪ Removal law; and

▪ Boards, Committees, and Commissions law.

SECTION 4. PROCESS

A. The amendments to this Law comply with the process set forth in the Legislative Procedures Act.

▪ On October 4, 2023, the Legislative Operating Committee added this Law to its Active Files

List for amendments.

B. At the time this legislative analysis was developed the following work meetings had been held

regarding the development of the amendments to this law:

▪ April 1, 2025: LOC work session.

▪ May 5, 2025: LOC work session.

▪ May 14, 2025: LOC work session with Human Resources.

▪ June 6, 2025: LOC work session.

▪ July 28, 2025: LOC work session.

▪ October 17, 2025. LOC work session

▪ November 19, 2025. LRO work session with the Oneida Law Office.

▪ January 9, 2026: LOC work session with Human Resources and Oneida Law Office.

▪ January 15, 2026: LOC work session Human Resources.

▪ January 29, 2026: LOC work session.

▪ February 4, 2026: LOC work session.

▪ February 16, 2026: LOC work session.

▪ February 18, 2026: LOC work session.

▪ March 4, 2026: LOC work session.

Page 3 of 8

11 of 289

Analysis to Draft 1

2026 03 18

SECTION 5. CONTENTS OF THE LEGISLATION

▪

Definitions. The proposed amendments to the Law remove definitions for terms that are no longer

used in the law, including the following: Government Official [1 O.C. 103.2(a)], Administrative

Staff [1 O.C. 103.2(b)], Program [1 O.C. 103.2(c)], Program personnel [1 O.C. 103.2(d)],

Enterprise [1 O.C. 103.2(e)], Enterprise employees [1 O.C. 103.2(f)]. Definitions are added or

amended for the following terms: Administrative Staff [1 O.C. 103.3-1(a)], Conflict of Interest

(expanded) [1 O.C. 103.3-1(b)], Family Member [1 O.C. 103.3-1(e)], Nation [1 O.C. 103.3-1(f)],

Oneida people [1 O.C. 103.3-1(g)].

▪ Effect. Updating the definitions to incorporate new terms, remove obsolete ones, and revise

existing terms to reflect current practices enhances clarity and precision within the Law.

These updates reduce ambiguity by clearly specifying the meaning of each term in context,

thereby minimizing the risk of misinterpretation and legal disputes, and improving

accessibility for all readers. Definitions clarify the scope and parties subject to the Code,

and broadens conflict coverage to include real/apparent interests and immediate family

relationships. These changes also affirm Oneida identity by defining the community

explicitly, ensuring the law reflects relational accountability and cultural belonging. The

expanded Conflict of Interest definition strengthens ethical protections by including family

and political interests, not just financial ones.

Good mind and Sacred Trust Framework. The proposed amendments incorporate the Good Mind

teachings directly into the ethical foundation of the law. These teachings — including

Kahletsyaḻlésla (encouraging the best in each other), Kanolukhwát^sla (compassion and identity),

Kaʔnikuhli.yo̱ (openness of spirit), Kaʔtshatst^sla (strength of vision), Kalihwi.yo̱ (good words),

Twahwahtsilay̱ʌ́ (we are all family), and Yukwatsistay̱ʌ́ (the fire within) — are identified as core

expectations for OBC members. [1 O.C. 103.1-2].

▪ Effect. This change re-roots the Code in Oneida cultural teachings, reinforcing that ethical

leadership is not merely procedural but spiritual, relational, and reflective of ancestral

values. It supports community understanding that leaders are called to uphold balance,

compassion, truth, and unity when carrying out their responsibilities.

Great Law of Peace Integration. The proposed amendments incorporate the Great Law of Peace

into the definitions section as a guiding principle for leadership conduct and ethical deliberation.

[1 O.C. 103.3-1(c)].

▪ Effect. Incorporating the Great Law of Peace into the Code of Ethics reaffirms that OBC

members must carry themselves with calm deliberation, peace, and a sense of collective

responsibility. It places Haudenosaunee governance principles at the center of modern

legislative expectations, strengthening continuity between ancient teachings and

contemporary leadership.

Scope of Law Clarified. The proposed amendments to the Law update the scope of application

exclusively to Oneida Business Committee members, removing outdated references to government

officials, program personnel, and enterprise employees. [1 O.C. 103.1-1].

▪ Effect. This clarification helps the community understand exactly who is accountable under

the Code. It reinforces that ethical standards apply directly to the Oneida Business

Committee, whose leadership role carries added responsibilities grounded in the Nation’s

laws and values. By aligning expectations with the authority entrusted to elected leaders,

Page 4 of 8

12 of 289

Analysis to Draft 1

2026 03 18

▪

the amendments ensure that governance remains consistent, transparent, and responsive to

the needs of the Nation.

Unified Standards of Conduct. The proposed amendments to the Law consolidate all ethical

expectations into a single Standards of Conduct section. While the Scope section clarifies who the

Code applies to, this structural change clarifies where the expectations are found. By bringing all

standards into one location, the Code becomes easier for the community to understand and for

elected leaders to follow, replacing the former multi-section format that applied differently to

government officials, program personnel, and enterprise employees.

▪ Effect. A unified Standards of Conduct section makes the Code more accessible to the public

by collecting all expectations in one place. Community members no longer need to

navigate multiple sections to understand what is expected from elected leadership. This

change also reflects a shift in responsibility: OBC members hold the authority to act on

behalf of the Nation, and it is appropriate that the ethical standards be tailored directly to

their roles. The unified structure supports transparency and easier public engagement.

Conflicts of Interest Procedures Strengthened. The proposed amendments to the Law introduce

more detailed procedures for identifying, disclosing, and addressing conflicts of interest, including

required annual and situational disclosure forms, agenda placement, and mandatory abstention

when conflicts arise. [1 O.C. 103.4-2(a)–(c)].

▪ Effect. These updates require that decisions affecting the Nation are made fairly and without

personal interests affecting outcomes. By shifting to a structured, proactive approach, the

amendments reduce the likelihood of hidden conflicts or confusion about disclosure

obligations. For the community, this means increased confidence that OBC members act

with clarity of purpose and integrity consistent with Good Mind teachings.

Employment Application by OBC Members. The proposed amendments to the Law regulate when

and how a member of the Oneida Business Committee may apply for a position within the Nation

while still in office. The amendment requires an OBC member to provide written notice to the full

Committee before applying for any position that reports directly to the OBC. The notice must

identify the position sought and the hiring authority. The provision also requires the member to

refrain from participating in any hiring-related decisions, discussions, or processes for that position.

[1 O.C. 103.4-8(a)–(c)].

▪ Effect. This update increases fairness and transparency in internal hiring by ensuring that

OBC members do not use their elected position to gain an advantage when applying for

Tribal employment. It helps the community understand that while OBC members may

apply for positions, they must do so in a way that respects boundaries, avoids the

appearance of influence, and maintains integrity in the hiring process. By clearly defining

the required notice and prohibiting participation in hiring decisions, the law supports

consistent procedures, protects against conflicts of interest, and strengthens community

trust in the Nation’s employment practices.

Gift, Honoraria & Sponsored Event Reporting. The proposed amendments to the Law raises the

gift-reporting threshold to $1,000 and creates a new OBC Gift Disclosure Form, while assigning

responsibility for public records to the Office of the Nation Secretary. [1 O.C. 103.4-9(a)–(e)].

They also strengthen transparency by requiring OBC members to formally report any gift,

honorarium, or sponsored event meeting the reporting threshold, and to submit this information for

OBC acceptance as an agenda item. The amendments also require the Office of the Nation Secretary

▪

Page 5 of 8

13 of 289

Analysis to Draft 1

2026 03 18

▪

to maintain these disclosures as public records, ensuring community access to this information. [1

O.C. 103.4-9(b)–(c)].

▪ Effect. These updates help the community clearly see what gifts elected leaders receive and

how they are handled. Requiring OBC action prevents individual members from deciding

privately whether gifts are appropriate, and placing disclosures in the public record ensures

openness and accountability. This builds trust by making sure that gifts cannot influence

decisions without community awareness and oversight, and reinforces the expectation that

OBC members act in service of the Nation rather than personal benefit. This process

ensures there is a clear, workable system for determining when gifts are acceptable and

when they must be reported. Centralizing recordkeeping strengthens public oversight and

supports trust in the fairness and independence of governmental decisions.

▪ Attendance, Preparedness, and Meeting Decorum Requirements. The proposed amendments to

the Law add a new set of expectations governing an OBC member’s participation in official

meetings. These updates require OBC members to attend all scheduled meetings unless excused,

to arrive prepared after reviewing agenda materials, and to participate professionally and

respectfully throughout the proceedings. The section emphasizes that OBC members must avoid

disruptive behaviors, refrain from side conversations or distractions, respect the voices of others,

and uphold confidentiality in closed-session matters. [1 O.C. 103.4-12(a)–(d)].

▪ Effect. These additions remind both leaders and the community that the ability of the Nation’s

government to function effectively depends on the consistent presence and preparedness

of its elected officials. By clearly outlining expectations around attendance, respectful

engagement, and responsible conduct, the amendments reinforce that serving on the OBC

is a serious commitment requiring focus, reliability, and discipline. This supports smoother

decision-making, strengthens internal professionalism, and demonstrates to the community

that OBC members understand the importance of showing up, staying engaged, and

honoring their roles in carrying out the Nation’s business. This aligns with Haudenosaunee

values of collective deliberation and responsible service.

Other amendments. Overall, a variety of other amendments and revisions were made to the Law to

address formatting, drafting style, and organization that did not affect the substance of the Law.

SECTION 6. EXISTING LEGISLATION

A. Related legislation. The following laws of the Nation are related to the proposed amendments to this

Law:

▪ Boards, Committees, and Commissions Law. The purpose of the Boards, Committees, and

Commissions law is to govern boards, committees, and commissions of the Nation, including the

procedures regarding the appointment and election of persons to boards, committees and

commissions, creation of bylaws, maintenance of official records, compensation, and other items

related to boards, committees and commissions. [1 O.C. 105.1-1]. The underlying policy is to

have consistent and standard procedures for choosing and appointing or electing the most

qualified persons to boards, committees and commissions, for creation of bylaws governing

boards committees and commissions, and for the maintenance of information created by and for

boards, committees and commissions. [1 O.C. 105.1-2].

Page 6 of 8

14 of 289

Analysis to Draft 1

2026 03 18

▪

The Code of Ethics no longer applies to members of boards, committees, and commissions,

as these groups operate under a different structure and set of responsibilities than the

Oneida Business Committee. Instead, updates are being made to the Boards, Committees,

and Commissions Law to include ethical standards that are specifically designed for those

bodies. This ensures that board, committee, and commission members continue to be

guided by clear expectations for conduct, accountability, and professionalism—while

keeping the Code of Ethics focused on the unique authority and obligations of the Oneida

Business Committee.

Conflict of Interest law. The purpose of the Conflict of Interest law is for the Nation to ensure that all

employees, contractors, elected officials, officers, political appointees, appointed and elected members and all

others who may have access to information or materials that are confidential or may be used by competitors of

the Nation’s enterprises or interests be subject to specific limitations to which such information and materials

may be used in order to protect the interests of the Nation. [2 O.C. 217.1-1]. Its underlying policy is to

assert its proprietary rights to client lists, trade secrets and any other confidential data generated,

developed or commissioned for the Nation in the course of an employee s duties and

responsibilities and that all employees, and prospective employees, be made aware of their

obligation to uphold such rights. The Nation asserts that no persons who work for the Nation or

are responsible for safeguarding its interests nor their relatives, associates, partners, or anyone

connected with such persons should in any way benefit against or in competition with the Nation

s interests without full and complete prior disclosure to the Nation. [2 O.C. 217.1-2].

▪ This Law provides conflict-of-interest expectations for OBC members will now be

governed exclusively under the updated Code of Ethics. Conflict-of-interest expectations

for board, committee, and commission (BCC) members will be addressed within the

updated Boards, Committees, and Commissions Law. As a result, the Conflict of Interest

Law is being amended so that it will apply only to Nation employees, consistent with

how the law is used within employment-related systems. [1 O.C. 103.1-1].

Removal Law. The purpose of the Removal law is to govern the removal of persons elected to

serve on boards, committees and commissions of the Oneida Tribe of Indians of Wisconsin. [1

O.C. 104.1-1]. It is the policy of the Oneida Tribe of Indians of Wisconsin to provide an orderly

and fair process for the removal of persons elected to serve on boards, committees and

commissions. [1 O.C. 104.1-2].

▪ Under the proposed amendments to the Code of Ethics the Oneida Business Committee

remains subject to the Removal law. [1 O.C. 103.5].

SECTION 7. ENFORCEMENT AND ACCOUNTABILITY

▪

The Oneida Business Committee remains subject to all applicable laws and policies of the Nation

including the Removal law. [1 O.C. 103.5].

SECTION 8. OTHER CONSIDERATIONS

Fiscal Impact. Under the Legislative Procedures Act, a fiscal impact statement is required for all

legislation except emergency legislation [1 O.C. 109.6-1]. Oneida Business Committee resolution BC-1028-20-A titled, “Further Interpretation of ‘Fiscal Impact Statement’ in the Legislative Procedures Act,”

provides further clarification on who the Legislative Operating Committee may direct complete a fiscal

Page 7 of 8

15 of 289

Analysis to Draft 1

2026 03 18

impact statement at various stages of the legislative process, as well as timeframes for completing the

fiscal impact statement.

▪ Conclusion. The Legislative Operating Committee has not yet directed that a fiscal impact be

completed.

Page 8 of 8

16 of 289

ONEIDA NATION PUBLIC MEETING NOTICE

THURSDAY May 14, 2026, 12:15 pm

Norbert Hill Center-Business Committee Conference Room

N7210 Seminary Rd., Oneida, Wisconsin

Find Public Meeting Materials at

Oneida-nsn.gov/government/register/public meetings

Send Public Comments to

LOC@oneidanation.org

Ask Questions here

LOC@oneidanation.org

920-869-4417

CODE OF ETHICS LAW AMENDMENTS

The purpose of the Code of Ethics law is to establish clear standards of conduct rooted in the

values of the Oneida people, to guide the Oneida Business Committee in serving the Nation

with honor and responsibility. These standards reflect the sacred trust between the government

and the people, and are intended to promote integrity, uphold the will of the Nation, and preserve the confidence of the Oneida people. In a government founded upon the consent of the

people, it is the right of the Oneida to expect loyalty, honesty, and accountability from those

who serve.

The Code of Ethics law amendments will:

 Update the Code of Ethics so it clearly focuses on the Oneida Business Committee,

bringing all expectations for how leaders should conduct themselves into one

easy‑to‑understand law.

 Integrate the Great Law of Peace into the ethical foundation, affirming decision‑making

grounded in peace, unity, and thoughtful deliberation as cultural mandates for governance.

 Ground the ethical framework in the Good Mind teachings, infusing leadership obligations with humility, compassion, clarity, and community‑centered thinking.

 Articulate the concept of Sacred Trust, emphasizing leadership as a duty held on behalf

of past, present, and future generations rather than an individual entitlement.

 Regulate OBC members’ applications for positions that report directly to the Committee, preventing conflicts before they arise and strengthening procedural fairness.

 Strengthen expectations for meeting attendance, preparation, and professional engagement, acknowledging that presence and participation are integral

to carrying the Sacred Trust.

 Modernize gift and honoraria reporting by increasing financial

thresholds and updating reporting processes to better reflect contemporary governance realities including public disclosure.

 Codify a comprehensive list of prohibited behaviors—including retaliation, discrimination, misuse of office, and corruption—to uphold dignity and protect community confidence in leadership.

Individuals may attend the public meeting for the proposed amendments to the Code of Ethics

law in person at the Norbert Hill Center, or virtually through Microsoft Teams. If you wish to

attend the public meeting through Microsoft Teams please contact LOC@oneidanation.org.

PUBLIC COMMENT PERIOD CLOSES THURSDAY MAY 21, 2026

During the public comment period, anyone may submit written comments, questions or input.

Comments may be submitted to the Oneida Nation Secretary’s Office or the Legislative Reference Office in person, by U.S. mail, interoffice mail, or e-mail.

17 of 289

Draft 1 (Redline)

2026 03 18

Title 1. Government and Finances - Chapter 103

CODE OF ETHICS

<twaliw@seh

matters that will be followed

CODE OF ETHICS

103.1-1

Policy and Purposes

103.2-1

Enterprise

Definitions

103.3-1

Enforcement

Government

103.5-1

103.6-1

103.7-1

Gifts and Gratuities

103.4-1

Program

103.1. 103.1.

Purpose and Policy

103.4.

of Conduct

Adoption, Amendment, Repeal

103.5

Enforcement

Definitions

103.2.

103.3.

Standards

103.1. Purpose and Policy and Purposes

103.1-1. It is the policy of the Oneida Tribe of Indians of Wisconsin to promote the highest ethical

conduct in all of its elected and appointed officials, and employees. This Code of Ethics represents

a beginning, it is the very minimum standard of conduct which is expected. This Code is intended

to create a base from which all persons are expected to work upwards and strive to work toward

improving the health, safety and welfare of the Oneida Nation, citizens of the Nation, employees

of the Tribe, and persons living in and around the jurisdiction of the Oneida Tribe if Indians of

Wisconsin.

103.2. Definitions

(a) Government Official. A "government official" includes all persons who are elected or

appointed to serve on the Oneida Business Committee and any board, committee, or commission

created by the 103.1-1. Purpose. The purpose of this law is to establish clear standards of conduct

rooted in the values of the Oneida people, to guide the Oneida Business Committee in serving the

Nation with honor and responsibility. These standards reflect the sacred trust between the

government and the people, and are intended to promote integrity, uphold the will of the Nation,

and preserve the confidence of the Oneida people. In a government founded upon the consent of

1 O.C. 103 – Page 1

18 of 289

Draft 1 (Redline)

2026 03 18

the people, it is the right of the Oneida to expect loyalty, honesty, and accountability from those

who serve.

103.1-2. Policy. It is the policy of the Nation that Oneida Business Committee or Oneida

General Tribal Council.

(b) Administrative Staff. "Administrative Staff" includes all personnel employed and

involved in the functioning of the government.

Wisconsin not expected to create revenue for the Tribe or those activities not expected to

make a profit at any time. Further, this includes those persons that are employees of the

Tribe working in these areas. Examples of, but are not limited to, governmental services

include the Tribal School, Health Works, Maintenance, Multi-Purpose Center, Oneida

Community Library.

(d) Program personnel. "Program Personnel" are those persons who work in Programs

of the Oneida Tribe of Indians of Wisconsin.

(e) Enterprise. An "enterprise" includes all activities of the Oneida Tribe of Indians of

Wisconsin that are engaged in for the business of profit. Examples of, but not limited to,

enterprises are Oneida Printing, Oneida Construction, Oneida Promotions.

(f) Enterprise employees. "Enterprise Employees" are those persons employed in an

Oneida Enterprise.

103.3. Government

103.3-1. All government officials shall be subject to the Code of Ethics as set forth herein and to

the intent of the code as set forth above.

103.3-2. The Code of Ethics shall be as set out below, recognizing that the concept of ethical

conduct encompasses action as well as inaction, and represents an area of self regulation. Provided

further, that it is the policy of government officials to demonstrate the highest standards of personal

integrity, truthfulness, honesty, and fortitude in all public activities in order to inspire public

confidence and trust in the governmental officials of the Oneida Tribe of Indians of Wisconsin.

103.3-3. The following shall govern the interaction between government officials and their

constituents, co-officials, and employees:

(a) A government official shall create and maintain an independent and honorable political

system, and shall observe high standards of conduct toward achieving this goal, including,

but not limited to

(1) encouraging separation between departments or entities of tribal government,

and should avoid contact or duty that violates such a separation.

(2) avoid participation in action or decision making (except where participation is

in accordance with the traditions of the Tribe) that would present an appearance of

conflict of interest or an actual conflict of interest.

1 O.C. 103 – Page 2

19 of 289

Draft 1 (Redline)

2026 03 18

(b) A government official should respect and comply with the law and tradition of the

Tribe and should at all times act in a manner that promotes public confidence in the honesty

and impartiality of government officials, including but not limited to

(1) influence of family, social or other personal relationships influencing conduct

(2) using prestige of the office to advance private interests of others

(3) conveying use of special influence or being specially influenced.

office

(1) adhere to the laws, customs, and traditions of the Tribe

(2) be patient, dignified and courteous to constituents, co-officials, and others with

whom the official deals in an official capacity, and should require similar conduct

of others in official proceedings and those personnel subject to the official's

discretion and control.

(3) give to every person who is interested in an action time to be heard

(4) not comment to non-tribal members on any proceeding, session, or action

unless directed to do so by an official action of the Oneida General Tribal Council,

Oneida Business Committee, or their delegates.

(d) Government officials and their administrative staff shall protect the privileged

information to which they have access in the course of official duties, and be prudent in

the use of information acquired in the course of their duties. Further, they should not use

confidential information for any personal gain, or in a manner which would be detrimental

to the welfare of the employer.

103.3-4. Administrative responsibilities include, but are not limited to, work product and conduct

of staff as set out herein

(a) prohibiting staff from making statements on behalf of the Tribe or agency of the Tribe

without permission

(b) require staff to observe high standards of honesty and diligence

conduct which the official may become aware of.

103.3-5. A government official should disqualify shall carry themselves when their action or

inaction might reasonably be questioned, including, but not limited to

(a) personal bias

(b) knowledge that individually or any member of their family or spouse's immediate

family, or anyone residing in their household has a financial interest in the subject matter

of a proceeding or action, or has any other interest that could be substantially affected

provided however, that an official disqualified by the above may, instead of withdrawing, disclose

on the record the basis of their disqualification. Provided further that the government agency,

based on such disclosure, agree unanimously that the government official's participation is not

prejudicial or that the financial interest is unsubstantial, the official is no longer disqualified and

may participate in the proceeding or action. The agreement or disagreement shall be incorporated

in the record of the proceeding or action.in

1 O.C. 103 – Page 3

20 of 289

Draft 1 (Redline)

2026 03 18

103.3-6. A government official shall regulate their extra governmental activities to minimize the

risk of conflict with duties of their office.

103.3-7. A government official should maintain a distance in financial dealings that would tend

to reflect an influence for personal gain, including, but not limited to

(a) dealings that tend to reflect on their impartiality, interference with performance of

governmental duties, or exploit the governmental office

(b) involvement in businesses that have financial impact or other influence on tribal

businesses or actions.

governmental official, or where the traditions of the Tribe allow participation.

(d) granting, giving, or influencing the gift, bequest or loan of tribal services, property or

monies outside of normal and traditional procedures.

103.3-8. An official may participate in civic and charitable activities that do not detract from the

dignity of the office or interfere with the performance of official duties.

103.4. Program

103.4-1. The Code of Ethics set forth in this section shall govern the management and employees

involved in Tribal Programs.

103.4-2. This section sets out the minimum ethical standards required of program personnel.

However, program personnel are encouraged to keep the community informed on program affairs;

encourage communication between citizens and all program personnel; emphasize and practice

friendly and courteous service to the public; and seek to improve the quality and image of public

service.

103.4-3. Program personnel shall serve in such a way that they will not realize personal gain

frombrings honor to the performance of official duties, including, but not limited to

(a) seeking favor, personal aggrandizement or profit

(b) accepting a fee or gift from a fellow employee, a client, a customer, or a business

associate of their employer without the knowledgeOneida people and consent of the senior

manager

103.4-4. Program personnelgovernment. They shall demonstrate the highest possible standards of

personalwalk with integrity, truthfulness, honesty and fortitude in all public activities in order to

inspire public confidence and trust in public institutions, including, but not limited to

(a) dedication to the highest ideals of honor and integrity in all public and personal

relationships

(b) affirm the dignity and worth of the services rendered by the government and maintain

constructive, creative, and practical attitude toward community affairs and a deep sense of

social responsibility as a trusted public servant.

103.4-5. Program personnel will avoid any interest or activity that is in conflict with the conduct

of official duties, including, but not limited to

1 O.C. 103 – Page 4

21 of 289

Draft 1 (Redline)

2026 03 18

(a) entering into any activity which may be in conflict with the interest of the Oneida Tribe

of Indians of Wisconsin, or which would prejudice the ability to carry out objectively their

duties and responsibilities

(b) eliminating all forms of illegal discrimination, fraud, and mismanagement of public

funds, and support colleagues if they are in difficulty because of responsible efforts to

correct such discrimination, fraud, mismanagement or abuse

and from all partisan political activities which would impair performance as program

personnel.

103.4-6. Program personnel with hiring, termination, transfer authority should support, implement

and promote merit employment and programs of affirmative actions to assure equal employment

opportunity by recruitment, selection, and advancement of qualified persons from all elements of

society, including, but not limited to

(a) handling all matters of personnel on the basis of merit so that fairness and impartiality

govern a member's decisions, pertaining to appointments, pay adjustments, promotions and

discipline

(b) strive for personal professional excellence and encourage the professional development

of associates

to administer with professional competence, fairness, impartiality, efficiency and

effectiveness

(d) respect, support, study, and when necessary, work to improve the laws, polices and

other regulations which define relationships among public agencies, employees, clients and

all citizens

103.4-7. Program personnel should approach organization and operational duties with a positive

attitude and constructively support open communication, creativity, dedication and compassion,

including, but not limited to

(a) submitting policy proposals to supervisors and elected officials; providing them with

facts and advice on matters of policy as a basis for making decisions and setting community

goals

(b) upholding and implementing policies adopted by officials.

1 O.C. 103 – Page 5

22 of 289

103.4-8. Program personnel shall protect the privileged information to which they have

access in the course of official duties and be prudent in the use of information acquired in

the course of their duties. Further, they should not use confidential information for any

personal gain or in a manner which would be detrimental to the welfare of the employer.

103.5. Enterprise

103.5-1. The enterprises of the Oneida Tribe of Indians of Wisconsin shall follow the Code of

Ethics as listed in this section.laws of the Nation, and uphold the highest standards of ethical

conduct in all their duties. All Oneida Business Committee members strive to exhibit and uphold

the Nation’s core values of The Good Mind as expressed by On<yote>a=ka, which includes:

(a) Kahletsyal&sla. The heartfelt encouragement of the best in each of us.

(b) Kanolukhw@sla. Compassion, caring, identity, and joy of being.

(d) Ka>tshatst^sla. The strength of belief and vision as a People.

(e) Kalihwi=y%. The use of the good words about ourselves, our Nation, and our future.

(f) Twahwahts$lay<. All of us are family.

(g) Yukwats$stay<. Our fire, our spirit within each one of us.

103.2. Adoption, Amendment, Repeal

103.2-1. This law was adopted by the Oneida Business Committee members by resolution BC11-23-94-A, and amended by resolution BC-04-12-06-JJ, BC-09-27-06-E, and BC-XX-XX-XXX.

103.2-2. This law may be amended or repealed by the Oneida Business Committee members or

the General Tribal Council pursuant to the procedures set out in the Legislative Procedures Act.

103.2-3. Should a provision of this law or the application thereof to any person or circumstances

be held as invalid, such invalidity shall not affect other provisions of this law which are considered

to have legal force without the invalid portions.

103.2-4. In the event of a conflict between a provision of this law and a provision of another policy,

the provisions of this policy shall control.

103.2-5. This law is adopted under authority of the Constitution of the Oneida Nation.

103.3. Definitions

103.3-1. This section shall govern the definitions of words and phrases used within this law. All

words not defined herein shall be used in their ordinary and everyday sense.

(a) “Conflict of Interest” means any financial, personal, or political interest, real or

apparent, that could impair an elected official’s impartiality or create an appearance of

impropriety in performing Oneida Business Committee members duties, including

interests held by immediate family members. This includes any financial or familial interest

an Oneida Business Committee member or their immediate family members may have in

any transaction between the Nation and an outside party.

1 O.C. 103 – Page 1

23 of 289

(b) “Great Law of Peace” means the Haudenosaunee principles given by the Peacemaker

and carried through Hiawatha that brought peace to the original nations by teaching people

to use a Good Mind grounded in reason, compassion, unity, and the restoration of balance

among all relations. It guides how the people are to live together in peace and mutual

respect, using consensus and shared responsibility to maintain harmony in the community.

grandchild, great-grandparent, great-grandchild, mother-in-law, father-in-law, daughterin-law, son-in-law, brother-in-law or sister-in-law, including relationships attained through

legal adoption, consistent with Oneida Human Resource Department standards.

(d) “Nation” means the Oneida Nation.

(e) “Oneida people” means enrolled members of the Oneida Nation, individuals eligible

for enrollment with the Oneida Nation, and descendants of the Oneida Nation.

103.4. Standards of Conduct

103.4-1. Good Mind and Sacred Trust. All Oneida Business Committee members shall serve with

a Good Mind (see Section103.1-2) guided by wisdom, compassion, and responsibility and shall

avoid actions or situations that give rise to the appearance of impropriety, undue influence, or

favoritism. The principles that follow expand on the obligations of Good Mind and Sacred Trust

and set forth the foundational duties that guide the conduct of all Oneida Business Committee

members.

(a) Seventh Generation Stewardship. Oneida leaders act as temporary stewards on behalf

of past generations and the seven generations yet to come, making decisions with deliberate

regard for long-term impacts on the Nation’s people, lands, resources, and institutions.

(b) People as the Source of Authority. Authority derives from the Oneida people, not from

the office itself. Oneida leaders shall act in the people’s best interests, speak truthfully,

manage the Nation’s resources with integrity, and relinquish authority through established

processes when the people’s confidence is lost.

Oneida leaders shall maintain a heart of peace and goodwill, a mind committed to the

people’s welfare, and actions shaped by calm and thoughtful deliberation. “Sacred Trust”

means the duty to safeguard the Nation’s wellbeing as something held in care, not

possession.

(d) Land, Sovereignty, and Cultural Continuity. Oneida leaders shall protect and strengthen

the Nation’s sovereignty, lands, language, and cultural ways—an inheritance preserved

through generations of sacrifice—so that these gifts remain whole and vibrant for future

generations.

(e) Accountability and Conflicts of Interest. Public office exists solely to serve the Oneida

people. Using one’s position for personal, financial, or political gain violates this trust.

Oneida leaders shall disclose conflicts, avoid improper influence, refrain from participation

where a conflict exists, and recognize that the Nation’s resources and reputation belong to

the Oneida people, not to officeholders.

1 O.C. 103 – Page 2

24 of 289

(f) Ethical Covenant. This covenant binds Oneida leaders to govern with honesty and

transparency; to honor ancestral teachings; to protect sovereignty and lands; and to make

decisions worthy of the children who will inherit the Nation. This trust is sacred because it

carries the lives of the living, the memory of those who came before, and the future of those

yet unborn.

103.4-2. Conflicts of Interest. No Oneida Business Committee member shall take part in decisions

or activities where they or an immediate family member hold a direct financial, personal, or

political interest, as such actions compromise the integrity of service to the Nation.

(a) Duty to Disclose. Members of the Oneida Business Committee shall disclose any

potential or actual conflict of interest using the OBC Conflict of Interest Disclosure Form,

which shall be submitted for inclusion on an OBC meeting agenda. The disclosure shall be

presented for OBC acceptance, and the member shall refrain from participating in any

related discussions or decision-making, when appropriate, to uphold the integrity of

governance.

(b) Ongoing Duty to Disclose. Oneida Business Committee members who become aware

of a conflict of interest shall promptly disclose its nature and avoid participation in the

matter.

(1) The Oneida Law Office shall create both annual and as-needed conflict

disclosure forms.

(2) The Office of the Oneida Nation Secretary shall distribute, collect, and

maintain these forms.

(3) All Oneida Business Committee members shall submit disclosure forms

annually and within a reasonable time after a conflict arises or becomes known.

103.4-3. Stewardship of Confidential Information. Oneida Business Committee members shall

treat confidential information as sacred, using it only for the benefit of the Nation and never for

personal gain or harm. No Oneida Business Committee member shall use confidential information

obtained through their position to:

(a) Acquire a financial interest in any property, transaction, or enterprise that may be

affected by such information;

(b) Speculate or wager;

(d) Advance personal or political interests; or

(e) Assist another in doing any of the above.

103.4-4. Use of Nation Resources. Oneida Business Committee members are entrusted with the

resources of the Nation and shall act as responsible stewards. Misuse, misappropriation, or any

form of impropriety in handling the Nation’s funds or property is a violation of this sacred trust.

103.4-5. Fair Dealing and Impartiality. Oneida Business Committee members shall carry out their

duties with fairness, honesty, and impartiality, honoring the trust placed in them by the Oneida

people. Oneida Business Committee members shall:

1 O.C. 103 – Page 3

25 of 289

(a) Refrain from granting special treatment beyond what is available to others under the

law;

(b) Make decisions based solely on merit, facts, and the well-being of the Nation, free from

bias, favoritism, or personal interest;

trust.

(d) Treat all individuals with respect and dignity, and foster an environment of equity,

justice, and inclusion in governmental dealings.

103.4-6. Accountability and Transparency. Public service is a sacred responsibility. Oneida

Business Committee members are entrusted by the Oneida people to act with integrity, humility,

and accountability. Their actions shall reflect the values of the Nation and honor the trust placed

in them by the community.

(a) Duty to be Accountable: Oneida Business Committee members shall be answerable to

the Oneida people for their decisions, conduct, and use of authority; explain their actions,

accept responsibility for mistakes, and take corrective steps when necessary.

Accountability is not only a legal obligation, it is a cultural duty rooted in respect for the

people and the teachings of the Good Mind (see Section103.1-2).

(b) Transparency in Governance. Transparency is essential to maintaining the good mind

and the confidence of the people. Oneida Business Committee members shall:

(1) Conduct public business in a manner that is open, honest, and accessible to the

community;

(2) Provide timely and accurate information about decisions, policies, and the use

of Nation resources; and

(3) Ensure that records, reports, and proceedings are maintained and made available

in accordance with the laws and customs of the Nation.

voices of the people, respecting the wisdom of elders, the concerns of families, and the

guidance of traditional knowledge. Decisions shall reflect the collective good and be made

with the understanding that leadership is a service to the Nation, not a privilege.

103.4-7. Nepotism Prohibited. The Oneida people expect their leaders to act with integrity and

impartiality. Avoiding nepotism is essential to maintaining sacred trust between the government

and the community, and to ensuring that all Oneida people have equal opportunity to serve and

contribute to the Nation.

(a) Commitment to Fairness. Leadership shall be guided by fairness, respect, and the Good

Mind (see Section103.1-2). Favoring family members in employment, appointments, or

decision-making undermines the trust of the people and disrupts the balance that is essential

to good governance.

(b) Preferential Treatment Prohibited. No Oneida Business Committee member shall use

their position to secure employment, advancement, contracts, or other benefits for

immediate family members or close relatives. All decisions shall be made based on merit,

qualifications, and the best interests of the Nation.

1 O.C. 103 – Page 4

26 of 289

supervise, evaluate, or participate in employment decisions involving a family member.

The Nation shall implement procedures to ensure that hiring and promotion processes are

free from undue influence and favoritism.

103.4-8. Employment Applications by Oneida Business Committee Members. Employment

Application for Direct Report Positions.

(a) Oneida Business Committee service is a sacred duty that requires attention and

impartiality, Oneida Business Committee members who intend to apply for employment

in positions that report directly to the Oneida Business Committee shall provide written

notice to the Oneida Business Committee prior to applying.

(a) Notice of Intent. Written notice shall identify the position sought and the hiring

authority. The notice is information and does not require formal approval.

(b) Hiring Process Participation. Oneida Business Committee members shall not

participate in hiring decisions or processes for positions they seek.

Business Committee.

103.4-9. Gifts and Honorarium.

(a) Prohibition on Gifts for Business Privilege. No Oneida Business Committee member

shall accept any gift, gratuity, or honorarium of any value in exchange for, or as a condition

of, doing business with the Nation.

(b) Reporting Requirements. Oneida Business Committee members shall report any gift,

honorarium, or sponsored event with a fair market value of one thousand dollars ($1000)

or more that is given in connection with activities organized by or participated in on behalf

of the Nation. Such disclosures shall be made using the OBC Gift Disclosure Form and

submitted for inclusion on an OBC meeting agenda. The disclosure shall be presented for

Oneida Business Committee acceptance, and the member shall refrain from participating

in any related discussions or decision-making, when appropriate, to uphold the integrity of

governance.

(1) Sponsored events not paid for or reimbursed by the Nation or another

government, such as social, recreational, or entertainment events must be reported

as gifts.

(2) Events paid for or reimbursed by another government for official duties, such

as consultations, meetings, or training, are official business and not reportable

under this section.

103.4-9(b) shall be documented using the Gift Disclosure Form and submitted to the Office

of the Nation’s Secretary within ten (10) business days of receipt.

(1) The Office of the Secretary shall maintain a public record of all reported gifts

and honoraria; and

(2) The Oneida Law Office shall maintain and update the Gift Disclosure Form and

related procedures.

1 O.C. 103 – Page 5

27 of 289

(d) Gifts below the Reporting Threshold. Gifts or honoraria valued at nine hundred ninetynine dollars and ninety-nine cents ($999.99) or less are not required to be reported on the

Gift Disclosure Form.

(e) Cultural and Ceremonial Gifts. Gifts given in the context of traditional, ceremonial, or

cultural exchange shall be exempt from reporting requirements. Oneida Business

Committee members are encouraged to consult with the Oneida Law Office when in doubt.

103.4-10. Prohibited Conduct. Oneida Business Committee members are expected to walk with

the Good Mind (see Section103.1-2), honoring the trust of the people and the teachings of the

Great Law of Peace. The following conduct is prohibited as it undermines the integrity of

governance, the dignity of the Nation, and the responsibilities entrusted to those who serve. No

Oneida Business Committee member shall:

(a) Use their position for personal gain, financial benefit, or advancement of family,

friends, or associates.

(b) Engage in any form of bribery, coercion, or undue influence in the performance of their

duties.

information.

(d) Discriminate against or harass any individual based on race, gender, age, religion, tribal

affiliation, or any other protected status.

(e) Retaliate against any person who reports unethical behavior, misconduct, or violations

of this law.

(f) Falsify records, reports, or communications related to their Oneida Business Committee

member duties.

(g) Accept gifts, gratuities, or honoraria in violation of Section103.4-9.

(h) Participate in decisions where a conflict of interest exists, as defined in Section103.42.

(j) Engage in nepotism or favoritism in hiring, supervision, or contracting, as prohibited in

Section103.4-7.

(k) Act in a manner that brings dishonor to the Oneida people or undermines the public’s

trust in the Nation’s government.

103.4-11. Cultural Accountability. Oneida Business Committee members are reminded that their

conduct reflects not only on themselves but on the Nation as a whole. They are expected to uphold

the teachings of the Good Mind (see Section103.1-2), protect the well-being of the community,

and serve with humility, honor, and respect.

103.4-12. Attendance and Meeting Conduct. Oneida Business Committee members shall honor

their responsibility to participate fully and professionally in the governance of the Nation.

Attendance and conduct during meetings reflect the integrity of leadership and the trust placed in

the Oneida Business Committee by the Oneida people. Accordingly:

(a) Commitment to Presence and Preparedness. Oneida Business Committee members

shall attend all scheduled meetings unless excused or prevented by circumstances beyond

their control. Absences should be communicated promptly and with respect for the body’s

1 O.C. 103 – Page 6

28 of 289

ability to conduct business. Oneida Business Committee members are expected to arrive

prepared, having reviewed all materials necessary for informed decision-making.

(b) Engagement and Respectful Dialogue. Meetings shall be conducted in a manner the

upholds the Good Mind (see Section 103.1-2) and fosters constructive dialogue. Oneida

Business Committee members shall:

(1) Participate actively and thoughtfully, contributing to deliberations with clarity

and respect.

(2) Listen attentively to others, avoid interruptions, and ensure that all voices are

heard.

(3) Refrain from conduct that disrupts proceedings or diminishes the dignity of the

office.

facts, and the collective good of the Nation. Oneida Business Committee members shall:

(1) Avoid side conversations, electronic distractions, or any behavior that signals

disengagement.

(2) Maintain confidentiality of closed-session discussions and sensitive

information.

(3) Conduct themselves in a manner that reflects honor, impartiality, and

accountability.

(d) Responsibility for Governance Continuity. Attendance and participation are essential to

the functioning of the Nation’s government. Persistent failure to meet these expectations

may constitute a breach of sacred trust.

103.5. 103.5-2. This section sets out the minimum ethical standards required of enterprise

employees. However, enterprise personnel are encouraged to conduct themselves in such a way

as to maximize their input in a positive and knowledgeable manner and to accept such input such

that those suggestions benefit the enterprises of the Oneida Tribe of Indians of Wisconsin.

103.5-3. Enterprise employees are expected to have a commitment to integrity, which includes,

but is not limited to

(a) Integrity towards the customer. An enterprise employee is expected to:

(1) Never misrepresent the quality, features or availability of the Tribes products

or services or those of its competitors.

(2) Never engage in industrial espionage or commercial bribery

(3) Never unlawfully interfere with contracts between a competitor and a customer

(4) Never buy from suppliers, or hint that we will buy from them, on the condition

that they use tribal products or services.

The Tribe's competitive efforts rely on the merits of its products and services. Enterprise

employees should concentrate or anticipate and satisfy the needs of our customers, and

should not seek to limit the competitive opportunities of our rivals.

(b) Integrity towards the Tribe. An enterprise employee is expected to:

(1) Be honest with the Tribe's's time and property

1 O.C. 103 – Page 7

29 of 289

(2) Reporting to work as scheduled

(3) Doing full day's work

(4) Keeping absences to minimum and documented

(5) Handle customer contacts with the highest standards of professionalism and

courtesy

(6) Avoid any outside activity that could adversely affect the independence and

objectivity of your judgement, interfere with the timely and effective performance

of your duties and responsibilities, or that could discredit the Tribe or conflict, or

appear to conflict, with the Tribe's best interests.

(7) Preventing the loss, damage, misuse or theft of tribal property is part of every

employee's job. Tribal property should be protected through safeguards such as

locking desks, offices and unattended vehicles or facilities, restricting nonemployee

or other unauthorized access, avoidance of waste or excess, observing rules

regarding identification, package inspection, personal property registration.

Enterprise employees are expected to, both on and off the job, to support the Tribe's efforts

to succeed in the world-wide market place.

For each, integrity is a personal responsibility. No one may justify an illegal act by

claiming it was ordered by someone higher in management. No one, regardless or rank, is

ever authorized to direct an employee to commit an illegal, or unethical act.

(1) The Tribe expects any employee to report any violation of the Code of Ethics,

as well as any other dishonest or illegal acts of which they become aware in the

workplace, The Tribe will not tolerate reprisals against any employee who, in good

faith, makes such reports. Employees who report actions are protected by the laws

of the Oneida Tribe.

(2) The Tribe encourages enterprise employees as private citizens to participate in

public and civic affairs. Employees should ensure that no conflict of interest, either

actual or potential, exists between the Tribe and their duties in public or civic

affairs, whether elective or appointed, paid or voluntary.

(3) When spending tribal money, or your own for reimbursement later, or when

requesting services on the Tribe's behalf, make sure that the Tribe receives the

proper value in return and that the expenditure is for a legitimate business purpose.

Every employee who has control over company funds is personally accountable for

them.

(4) Employees are forbidden to engage in the following conduct:

(A) Illegal use, possession, distribution, transportation, sale, purchase or

transfer of controlled substances or drugs

(B) Intoxication on company time, premises, or other business

(D) Possession of unauthorized firearms

1 O.C. 103 – Page 8

30 of 289

(E) Using rude, abusive or obscene language with costumer, or around

customers

(F) Refusing to serve a costumer.

(d) Integrity to competitors. The Tribe is committed to engaging in a free and open market,

to the extent that preference laws enacted by the tribal government are in effect, enterprise

employees may not attempt to influence the sale or purchase of goods and services in any

way.

(1) The Tribe's competitive efforts must rely on the merits of its products and

services. Employees should concentrate on anticipating and satisfying the needs of

our customers, and should not seek to limit the competitive opportunities of our

rivals.

(2) The Tribe's policy is to honor our own copyright's and copyrights of others. To

that end, licenses or permission is needed when using any object, item, idea, etc.,

that is copyrighted or which is owned by another.

(3) Enterprise employees shall not give or receive inappropriate gifts or provide

unusual hospitality to customers or potential customers or their employees that will

unfairly influence their purchasing decision.

(4) Enterprise employees are required to report gifts other than promotional items

of nominal value promptly to your supervisor and then return them to the donor, if

possible, or dispose of them in another appropriate manner. Provided that, in any

differences between this Ethics Code and any Conflict of Interest Code, the latter

shall prevail.

(5) Enterprise employees should:

(A) Have no relationship, financial or otherwise, with any supplier or

competitor that might be construed as a conflict of interest, or that even

might appear to impair your judgement on behalf of the Tribe.

(B) Never accept or solicit, even indirectly, gifts, loans, "kick-backs",

special privileges, services, or unusual hospitality. Does not apply to low

value promotional items of a general advertising nature.

103.5-4. Enterprise employees are specifically encouraged to protect the Tribe's intellectual

property and proprietary information. Proprietary information is any information or knowledge

created, acquired or controlled by the Tribe that the Tribe has determined should not be published

or released to others. It includes, but is not limited to, financial and billing records, unannounced

products and services, technical information, sales and marketing data, and employee records. If

the release of the information could cause the Tribe the loss of a critical competitive advantage,

could hurt relationships with customers or could embarrass or harm fellow employees it is

considered proprietary.

When enterprise employees leave the Tribe, all documents and records containing

proprietary information must be returned to the Tribe. Further, there is a continuing obligation to

safeguard any information obtained during the course of their employment.

1 O.C. 103 – Page 9

31 of 289

103.5-5. All enterprise employees are required to conduct themselves according to the highest

ethical standards of integrity and honesty. Further, each employee is expected to comply with all

applicable tribal, federal, state and local laws. Finally, an employee should not undertake any

activity that is aimed at, or could reasonably have the effect of, retarding the success of the Tribe

in the market place, and should avoid any actions inconsistent with this commitment.

103.6. Enforcement.

103.6-1. This code shall be enforced according to the following:

(a) Government officials may be subject to either removal, if elected, or termination, if

appointed, for a violation of any portion of this ethics code as it applies to them.

(b) Programs and Enterprises shall be removed according to the procedures set out in the

Oneida Personnel Procedures and Policies Manual. Provided that, suspension while

investigation or termination is an appropriate action, and one offense is sufficient for

termination. Provided further, that any suspension shall be without pay.

103.7. Gifts and Gratuities

103.7-1. Notwithstanding any provision of this law, no governmental official, administrative staff,

employee of a program or enterprise, or a program or enterprise may accept a gift or gratuity of

any value for the privilege of doing business with the Oneida Tribe of Indians of Wisconsin.

103.7-2. Further, any person or entity listed in section 7-1 is required to report gifts of gratuities

with a value of $50.00 or more which is given:

(a) For activities participated in or organized by the Oneida Tribe; or

(b) To the person or entity listed in section 7-1 on behalf of the Oneida tribe.

Those gifts or gratuities with a value of $50.00 or more shall be document on form CE-1 and

forwarded to the Property Management Office within the Accounting Department of the Oneida

Tribe.

103.7-3. All gifts or gratuities having a value of $49.99 or less need not be documented on form

CE-1. However, no individual may retain any gift or gratuity meeting the definition set out in

section 7-2 for personal gain.

Enforcement. Enforcement of this law shall be conducted in accordance with all applicable laws

and regulations of the Nation.

End.

Adopted - Oneida Business Committee minutes, 10-21-91

Adopted - BC-11-23-94-A

Emergency Amendment - BC-04-12-06-JJ

Amended - BC-09-27-06-E (adoption of emergency amendment)

1 O.C. 103 – Page 10

32 of 289

Amended – BC- - - -

1 O.C. 103 – Page 11

33 of 289

Draft 1 (Clean)

2026 03 18

Title 1. Government and Finances - Chapter 103

<twaliw@seh

matters that will be followed

CODE OF ETHICS

103.1.

103.2.

103.3.

Purpose and Policy

Adoption, Amendment, Repeal

Definitions

103.4.

103.5

Standards of Conduct

Enforcement

103.1. Purpose and Policy

103.1-1. Purpose. The purpose of this law is to establish clear standards of conduct rooted in the

values of the Oneida people, to guide the Oneida Business Committee in serving the Nation with

honor and responsibility. These standards reflect the sacred trust between the government and the

people, and are intended to promote integrity, uphold the will of the Nation, and preserve the

confidence of the Oneida people. In a government founded upon the consent of the people, it is the

right of the Oneida to expect loyalty, honesty, and accountability from those who serve.

103.1-2. Policy. It is the policy of the Nation that Oneida Business Committee members shall carry

themselves in a way that brings honor to the Oneida people and government. They shall walk with

integrity, follow the laws of the Nation, and uphold the highest standards of ethical conduct in all

their duties. All Oneida Business Committee members strive to exhibit and uphold the Nation’s core

values of The Good Mind as expressed by On<yote>a=ka, which includes:

(a) Kahletsyal&sla. The heartfelt encouragement of the best in each of us.

(b) Kanolukhw@sla. Compassion, caring, identity, and joy of being.

(d) Ka>tshatst^sla. The strength of belief and vision as a People.

(e) Kalihwi=y%. The use of the good words about ourselves, our Nation, and our future.

(f) Twahwahts$lay<. All of us are family.

(g) Yukwats$stay<. Our fire, our spirit within each one of us.

103.2. Adoption, Amendment, Repeal

103.2-1. This law was adopted by the Oneida Business Committee members by resolution BC-1123-94-A, and amended by resolution BC-04-12-06-JJ, BC-09-27-06-E, and BC-XX-XX-XX-X.

103.2-2. This law may be amended or repealed by the Oneida Business Committee members or the

General Tribal Council pursuant to the procedures set out in the Legislative Procedures Act.

103.2-3. Should a provision of this law or the application thereof to any person or circumstances be

held as invalid, such invalidity shall not affect other provisions of this law which are considered to

have legal force without the invalid portions.

103.2-4. In the event of a conflict between a provision of this law and a provision of another policy,

the provisions of this policy shall control.

103.2-5. This law is adopted under authority of the Constitution of the Oneida Nation.

103.3. Definitions

1 O.C. 103 – Page 1

34 of 289

103.3-1. This section shall govern the definitions of words and phrases used within this law. All

words not defined herein shall be used in their ordinary and everyday sense.

(a) “Conflict of Interest” means any financial, personal, or political interest, real or apparent,

that could impair an elected official’s impartiality or create an appearance of impropriety in

performing Oneida Business Committee members duties, including interests held by

immediate family members. This includes any financial or familial interest an Oneida

Business Committee member or their immediate family members may have in any

transaction between the Nation and an outside party.

(b) “Great Law of Peace” means the Haudenosaunee principles given by the Peacemaker and

carried through Hiawatha that brought peace to the original nations by teaching people to use

a Good Mind grounded in reason, compassion, unity, and the restoration of balance among

all relations. It guides how the people are to live together in peace and mutual respect, using

consensus and shared responsibility to maintain harmony in the community.

grandchild, great-grandparent, great-grandchild, mother-in-law, father-in-law, daughter-inlaw, son-in-law, brother-in-law or sister-in-law, including relationships attained through

legal adoption, consistent with Oneida Human Resource Department standards.

(d) “Nation” means the Oneida Nation.

(e) “Oneida people” means enrolled members of the Oneida Nation, individuals eligible for

enrollment with the Oneida Nation, and descendants of the Oneida Nation.

103.4. Standards of Conduct

103.4-1. Good Mind and Sacred Trust. All Oneida Business Committee members shall serve with a

Good Mind (see Section103.1-2) guided by wisdom, compassion, and responsibility and shall avoid

actions or situations that give rise to the appearance of impropriety, undue influence, or favoritism.

The principles that follow expand on the obligations of Good Mind and Sacred Trust and set forth

the foundational duties that guide the conduct of all Oneida Business Committee members.

(a) Seventh Generation Stewardship. Oneida leaders act as temporary stewards on behalf of

past generations and the seven generations yet to come, making decisions with deliberate

regard for long-term impacts on the Nation’s people, lands, resources, and institutions.

(b) People as the Source of Authority. Authority derives from the Oneida people, not from

the office itself. Oneida leaders shall act in the people’s best interests, speak truthfully,

manage the Nation’s resources with integrity, and relinquish authority through established

processes when the people’s confidence is lost.

leaders shall maintain a heart of peace and goodwill, a mind committed to the people’s

welfare, and actions shaped by calm and thoughtful deliberation. “Sacred Trust” means the

duty to safeguard the Nation’s wellbeing as something held in care, not possession.

(d) Land, Sovereignty, and Cultural Continuity. Oneida leaders shall protect and strengthen

the Nation’s sovereignty, lands, language, and cultural ways—an inheritance preserved

through generations of sacrifice—so that these gifts remain whole and vibrant for future

generations.

1 O.C. 103 – Page 2

35 of 289

100

101

102

103

104

105

106

107

108

109

110

111

112

113

114

115

116

117

118

119

120

121

122

123

124

125

126

127

(e) Accountability and Conflicts of Interest. Public office exists solely to serve the Oneida

people. Using one’s position for personal, financial, or political gain violates this trust.

Oneida leaders shall disclose conflicts, avoid improper influence, refrain from participation

where a conflict exists, and recognize that the Nation’s resources and reputation belong to

the Oneida people, not to officeholders.

(f) Ethical Covenant. This covenant binds Oneida leaders to govern with honesty and

transparency; to honor ancestral teachings; to protect sovereignty and lands; and to make

decisions worthy of the children who will inherit the Nation. This trust is sacred because it

carries the lives of the living, the memory of those who came before, and the future of those

yet unborn.

103.4-2. Conflicts of Interest. No Oneida Business Committee member shall take part in decisions

or activities where they or an immediate family member hold a direct financial, personal, or political

interest, as such actions compromise the integrity of service to the Nation.

(a) Duty to Disclose. Members of the Oneida Business Committee shall disclose any

potential or actual conflict of interest using the OBC Conflict of Interest Disclosure Form,

which shall be submitted for inclusion on an OBC meeting agenda. The disclosure shall be

presented for OBC acceptance, and the member shall refrain from participating in any related

discussions or decision-making, when appropriate, to uphold the integrity of governance.

(b) Ongoing Duty to Disclose. Oneida Business Committee members who become aware of

a conflict of interest shall promptly disclose its nature and avoid participation in the matter.

(1) The Oneida Law Office shall create both annual and as-needed conflict

disclosure forms.

(2) The Office of the Oneida Nation Secretary shall distribute, collect, and

maintain these forms.

(3) All Oneida Business Committee members shall submit disclosure forms

annually and within a reasonable time after a conflict arises or becomes known.

103.4-3. Stewardship of Confidential Information. Oneida Business Committee members shall treat

confidential information as sacred, using it only for the benefit of the Nation and never for personal

gain or harm. No Oneida Business Committee member shall use confidential information obtained

through their position to:

(a) Acquire a financial interest in any property, transaction, or enterprise that may be affected

by such information;

(b) Speculate or wager;

(d) Advance personal or political interests; or

(e) Assist another in doing any of the above.

103.4-4. Use of Nation Resources. Oneida Business Committee members are entrusted with the

resources of the Nation and shall act as responsible stewards. Misuse, misappropriation, or any form

of impropriety in handling the Nation’s funds or property is a violation of this sacred trust.

1 O.C. 103 – Page 3

36 of 289

128

129

130

131

132

133

134

135

136

137

138

139

140

141

142

143

144

145

146

147

148

149

150

151

152

153

154

155

156

157

158

159

160

161

162

163

164

165

166

167

168

169

103.4-5. Fair Dealing and Impartiality. Oneida Business Committee members shall carry out their

duties with fairness, honesty, and impartiality, honoring the trust placed in them by the Oneida

people. Oneida Business Committee members shall:

(a) Refrain from granting special treatment beyond what is available to others under the law;

(b) Make decisions based solely on merit, facts, and the well-being of the Nation, free from

bias, favoritism, or personal interest;

(d) Treat all individuals with respect and dignity, and foster an environment of equity,

justice, and inclusion in governmental dealings.

103.4-6. Accountability and Transparency. Public service is a sacred responsibility. Oneida

Business Committee members are entrusted by the Oneida people to act with integrity, humility, and

accountability. Their actions shall reflect the values of the Nation and honor the trust placed in them

by the community.

(a) Duty to be Accountable: Oneida Business Committee members shall be answerable to the

Oneida people for their decisions, conduct, and use of authority; explain their actions, accept

responsibility for mistakes, and take corrective steps when necessary. Accountability is not

only a legal obligation, it is a cultural duty rooted in respect for the people and the teachings

of the Good Mind (see Section103.1-2).

(b) Transparency in Governance. Transparency is essential to maintaining the good mind

and the confidence of the people. Oneida Business Committee members shall:

(1) Conduct public business in a manner that is open, honest, and accessible to the

community;

(2) Provide timely and accurate information about decisions, policies, and the use of

Nation resources; and

(3) Ensure that records, reports, and proceedings are maintained and made available

in accordance with the laws and customs of the Nation.

voices of the people, respecting the wisdom of elders, the concerns of families, and the

guidance of traditional knowledge. Decisions shall reflect the collective good and be made

with the understanding that leadership is a service to the Nation, not a privilege.

103.4-7. Nepotism Prohibited. The Oneida people expect their leaders to act with integrity and

impartiality. Avoiding nepotism is essential to maintaining sacred trust between the government and

the community, and to ensuring that all Oneida people have equal opportunity to serve and

contribute to the Nation.

(a) Commitment to Fairness. Leadership shall be guided by fairness, respect, and the Good

Mind (see Section103.1-2). Favoring family members in employment, appointments, or

decision-making undermines the trust of the people and disrupts the balance that is essential

to good governance.

(b) Preferential Treatment Prohibited. No Oneida Business Committee member shall use

their position to secure employment, advancement, contracts, or other benefits for immediate

family members or close relatives. All decisions shall be made based on merit, qualifications,

and the best interests of the Nation.

1 O.C. 103 – Page 4

37 of 289

170

171

172

173

174

175

176

177

178

179

180

181

182

183

184

185

186

187

188

189

190

191

192

193

194

195

196

197

198

199

200

201

202

203

204

205

206

207

208

209

210

supervise, evaluate, or participate in employment decisions involving a family member. The

Nation shall implement procedures to ensure that hiring and promotion processes are free

from undue influence and favoritism.

103.4-8. Employment Applications by Oneida Business Committee Members. Employment

Application for Direct Report Positions.

(a) Oneida Business Committee service is a sacred duty that requires attention and

impartiality, Oneida Business Committee members who intend to apply for employment in

positions that report directly to the Oneida Business Committee shall provide written notice

to the Oneida Business Committee prior to applying.

(a) Notice of Intent. Written notice shall identify the position sought and the hiring authority.

The notice is information and does not require formal approval.

(b) Hiring Process Participation. Oneida Business Committee members shall not

participate in hiring decisions or processes for positions they seek.

Business Committee.

103.4-9. Gifts and Honorarium.

(a) Prohibition on Gifts for Business Privilege. No Oneida Business Committee member

shall accept any gift, gratuity, or honorarium of any value in exchange for, or as a condition

of, doing business with the Nation.

(b) Reporting Requirements. Oneida Business Committee members shall report any gift,

honorarium, or sponsored event with a fair market value of one thousand dollars ($1000) or

more that is given in connection with activities organized by or participated in on behalf of

the Nation. Such disclosures shall be made using the OBC Gift Disclosure Form and

submitted for inclusion on an OBC meeting agenda. The disclosure shall be presented for

Oneida Business Committee acceptance, and the member shall refrain from participating in

any related discussions or decision-making, when appropriate, to uphold the integrity of

governance.

(1) Sponsored events not paid for or reimbursed by the Nation or another

government, such as social, recreational, or entertainment events must be reported as

gifts.

(2) Events paid for or reimbursed by another government for official duties, such as

consultations, meetings, or training, are official business and not reportable under

this section.

(c) Gift Disclosure Form and Public Record. Gifts or gratuities meeting the criteria in 103.49(b) shall be documented using the Gift Disclosure Form and submitted to the Office of the

Nation’s Secretary within ten (10) business days of receipt.

(1) The Office of the Secretary shall maintain a public record of all reported gifts and

honoraria; and

(2) The Oneida Law Office shall maintain and update the Gift Disclosure Form and

related procedures.

1 O.C. 103 – Page 5

38 of 289

211

212

213

214

215

216

217

218

219

220

221

222

223

224

225

226

227

228

229

230

231

232

233

234

235

236

237

238

239

240

241

242

243

244

245

246

247

248

249

250

251

252

(d) Gifts below the Reporting Threshold. Gifts or honoraria valued at nine hundred ninetynine dollars and ninety-nine cents ($999.99) or less are not required to be reported on the

Gift Disclosure Form.

(e) Cultural and Ceremonial Gifts. Gifts given in the context of traditional, ceremonial, or

cultural exchange shall be exempt from reporting requirements. Oneida Business Committee

members are encouraged to consult with the Oneida Law Office when in doubt.

103.4-10. Prohibited Conduct. Oneida Business Committee members are expected to walk with the

Good Mind (see Section103.1-2), honoring the trust of the people and the teachings of the Great Law

of Peace. The following conduct is prohibited as it undermines the integrity of governance, the

dignity of the Nation, and the responsibilities entrusted to those who serve. No Oneida Business

Committee member shall:

(a) Use their position for personal gain, financial benefit, or advancement of family, friends,

or associates.

(b) Engage in any form of bribery, coercion, or undue influence in the performance of their

duties.

information.

(d) Discriminate against or harass any individual based on race, gender, age, religion, tribal

affiliation, or any other protected status.

(e) Retaliate against any person who reports unethical behavior, misconduct, or violations of

this law.

(f) Falsify records, reports, or communications related to their Oneida Business Committee

member duties.

(g) Accept gifts, gratuities, or honoraria in violation of Section103.4-9.

(h) Participate in decisions where a conflict of interest exists, as defined in Section103.4-2.

(j) Engage in nepotism or favoritism in hiring, supervision, or contracting, as prohibited in

Section103.4-7.

(k) Act in a manner that brings dishonor to the Oneida people or undermines the public’s

trust in the Nation’s government.

103.4-11. Cultural Accountability. Oneida Business Committee members are reminded that their

conduct reflects not only on themselves but on the Nation as a whole. They are expected to uphold

the teachings of the Good Mind (see Section103.1-2), protect the well-being of the community, and

serve with humility, honor, and respect.

103.4-12. Attendance and Meeting Conduct. Oneida Business Committee members shall honor their

responsibility to participate fully and professionally in the governance of the Nation. Attendance and

conduct during meetings reflect the integrity of leadership and the trust placed in the Oneida

Business Committee by the Oneida people. Accordingly:

(a) Commitment to Presence and Preparedness. Oneida Business Committee members shall

attend all scheduled meetings unless excused or prevented by circumstances beyond their

control. Absences should be communicated promptly and with respect for the body’s ability

to conduct business. Oneida Business Committee members are expected to arrive prepared,

having reviewed all materials necessary for informed decision-making.

1 O.C. 103 – Page 6

39 of 289

253

254

255

256

257

258

259

260

261

262

263

264

265

266

267

268

269

270

271

272

273

274

275

276

277

278

279

280

281

282

283

(b) Engagement and Respectful Dialogue. Meetings shall be conducted in a manner the

upholds the Good Mind (see Section 103.1-2) and fosters constructive dialogue. Oneida

Business Committee members shall:

(1) Participate actively and thoughtfully, contributing to deliberations with clarity

and respect.

(2) Listen attentively to others, avoid interruptions, and ensure that all voices are

heard.

(3) Refrain from conduct that disrupts proceedings or diminishes the dignity of the

office.

facts, and the collective good of the Nation. Oneida Business Committee members shall:

(1) Avoid side conversations, electronic distractions, or any behavior that signals

disengagement.

(2) Maintain confidentiality of closed-session discussions and sensitive information.

(3) Conduct themselves in a manner that reflects honor, impartiality, and

accountability.

(d) Responsibility for Governance Continuity. Attendance and participation are essential to

the functioning of the Nation’s government. Persistent failure to meet these expectations may

constitute a breach of sacred trust.

103.5. Enforcement. Enforcement of this law shall be conducted in accordance with all applicable

laws and regulations of the Nation.

End.

Adopted - Oneida Business Committee minutes, 10-21-91

Adopted - BC-11-23-94-A

Emergency Amendment - BC-04-12-06-JJ

Amended - BC-09-27-06-E (adoption of emergency amendment)

Amended – BC- - - -

1 O.C. 103 – Page 7

40 of 289

r'\.

Oneida Nation

Oneida Business Committee

Legislative Operating Committee

PO Box 365 • Oneida, WI 54155-0365

Oneida-nsn.gov

=DODDDD=

ONEIDA

Legislative Operating Committee

March 18, 2026

Pardon and Forgiveness Law

Amendments

Submission Date: 2/5/26

LOC Sponsor: Jonas Hill

Public Meeting: N/A

Emergency Enacted: N/A

Summary: This item was added to the Active Files List on February 18, 2026 at the request

of the Oneida Business Committee to allow flexibility in pardon eligibility when fines prevent

payment.

2/18/26 LOC: Motion by Jennifer Webster to add the Pardon and Forgiveness Law Amendments to

the Active Files List with Jonas Hill as the sponsor; seconded by Kirby Metoxen.

Motion carried unanimously.

2/25/26:

Work Meeting. Present: Kelly McAndrews, Grace Elliott. The purpose of this meeting

was to review attorney McAndrew’s comments on the proposed amendments to the

Pardon and Forgiveness law.

2/27/26:

Work Meeting. Present: Grace Elliott, Peggy VanGheem. The purpose this meeting

was to review attorney VanGheem’s comments on the proposed amendments to the

Pardon and Forgiveness law.

3/4/26:

Work Meeting. Present: Jameson Wilson, Jennifer Webster, Jonas Hill, Kirby

Metoxen, Carolyn Salutz, Kristal Hill, Fawn Billie, Clorissa Leeman, Grace Elliott.

The purpose of this meeting was to provide an update and complete a read through of

the amendments for LOC review and initial approval to move forward through the

legislative process.

Next Steps:

▪ Approve the draft Pardon and Forgiveness law amendments, legislative analysis, and public

meeting packet for the Pardon and Forgiveness law amendments and schedule a public

meeting to be held on May 14, 2026.

Page 1 of 1

A good mind. A good heart. A strong fire.

41 of 289

Analysis to Draft 1

2026 03 18

PARDON AND FORGIVENESS

LAW AMENDMENTS

LEGISLATIVE ANALYSIS

SECTION 1. EXECUTIVE SUMMARY

Intent of the

Legislation or

Amendments

Purpose

Analysis by the Legislative Reference Office

▪ Create an exception allowing applicants with outstanding penalties/fines to

proceed only if the application is for employment purposes and the applicant

meets the requirements for a conditional waiver under 126.6-3. [1 O.C.

126.6-2(d)].

▪ Establish the full conditional waiver framework, including:

▪ waiver applies only to employment eligibility;

▪ outstanding penalties/fines remain fully enforceable;

▪ mandatory payment agreement (18 months or extended to 3 years if

>$5,000);

▪ requirements for Pardon and Forgiveness Committee

recommendation;

▪ good-cause exception for missed payments;

▪ grounds for rescission for non-payment. [1 O.C. 126.6-3].

▪ Allow an applicant proceeding under the conditional waiver

(employment-only) to submit proof of a Pardon and Forgiveness

Committee-approved payment agreement instead of proof of full payment. [1

O.C. 126.6-4(a)(12; 126.6-4(b)(11)].

▪ Clarify that a pardon or forgiveness does not affect restrictions imposed under

the Nation’s Safe Neighborhoods law, in addition to existing sex-offender

requirements. [1 O.C. 126.9-1(c)].

▪ Require the Oneida Secretary’s Office to monitor payment-related conditions

and provide quarterly reports to the Pardon and Forgiveness Committee; and

clarify that monitoring is solely for eligibility enforcement, not decisionmaking. [1 O.C. 126.9-4].

▪ Authorize the OBC to rescind a pardon/forgiveness when a person fails to

meet a payment condition under 126.6-3, with notice and a 30-day cure

period; reinstates all prior ineligibilities. Includes subsections specifying:

▪ rescission is an eligibility action, not an employment action;

▪ notice must be issued per 126.10-4. [1 O.C. 126.10-7].

The purpose of this law is to establish a fair, efficient, and formal process through

which individuals may seek relief from certain barriers created by past actions.

Specifically, the Law provides a process for:

▪ Tribal members to receive pardons for criminal convictions;

▪ Tribal members to receive forgiveness for acts that make them ineligible for

Tribal housing or other Tribal benefits; and

▪ Tribal and non-Tribal individuals to receive forgiveness for acts that make them

ineligible for Tribal employment, occupational licenses, certifications, permits,

housing, or other Tribal benefits [1 O.C. 126.1-1(a)].

Page 1 of 7

42 of 289

Analysis to Draft 1

2026 03 18

Affected Entities

Related Legislation

Enforcement

Due Process

The Law further aims to ensure that decisions on pardons and forgiveness are made

based on demonstrated rehabilitation, trustworthiness, and commitment to lawful

behavior. It clarifies that a pardon or forgiveness does not override obligations

imposed by other jurisdictions and does not permit employment in occupations

where individuals are legally disqualified [1 O.C. 126.1-2].

Oneida Business Committee; Office of the Oneida Secretary (records); Pardon and

Forgiveness Committee, Oneida community members.

Personnel, Policies, and Procedures; Safe Neighborhoods.

▪ Individuals may be automatically ineligible if they are under investigation,

appealing a termination, incarcerated, or have outstanding penalties/fines,

unless they qualify for the employment-only conditional waiver under 126.6-3

[1 O.C. 126.6-2].

▪ Applications may be denied, returned, or removed if incomplete, and

misrepresentation can result in denial or later rescission of a granted pardon or

forgiveness [1 O.C. 126.6-5–6].

▪ Failure to appear at a hearing allows the Committee to postpone action or

recommend denial if documentation is not provided within ten (10) days [1

O.C. 126.8-3].

▪ After relief is granted, the OBC or Committee may impose conditions (e.g.,

restitution, community service) and restrictions on employment or other

benefits, and applicants must comply to retain restored eligibilities [1 O.C.

126.9-2–3].

▪ The Secretary’s Office must monitor compliance with payment conditions and

submit quarterly reports under the new monitoring requirement [1 O.C.

126.9-4].

▪ The OBC may rescind a pardon, forgiveness, or conditional waiver for failure

to meet payment obligations, reinstating all prior ineligibilities after notice and

a 30-day cure period [1 O.C. 126.10-7].

The Pardon and Forgiveness Law provides several due process protections to ensure

that applicants receive fair treatment throughout the pardon or forgiveness process.

Applicants have the right to a public hearing with at least thirty (30) days’ notice

sent by certified mail and posted in prominent locations, giving them adequate time

to prepare [1 O.C. 126.8-1]. They also have the ability to request alternate

arrangements, such as appearing by video conference, when residing outside

Wisconsin or when attendance is otherwise impractical—thus ensuring access to

participation even when physical presence is difficult [1 O.C. 126.8-2]. During the

hearing, applicants may provide oral testimony, submit documents, and respond to

questions; victims and witnesses may also participate directly or through notarized

statements, supporting transparency and full consideration of relevant information

[1 O.C. 126.8-4]. Due process is also reinforced by allowing applicants ten (10)

days to provide documentation if they miss a hearing for legitimate reasons,

preventing automatic denial without an opportunity to be heard [1 O.C. 126.8-3].

After the hearing, due process continues through structured, accountable

decision-making requirements. The Committee must deliberate in executive session

and issue a formal written recommendation explaining the reasons for approval or

denial, which is forwarded to the Oneida Business Committee (OBC) with all

supporting materials [1 O.C. 126.8-5]. The OBC must then make the final decision

by resolution in open session, including the reasons for the decision and a listing of

the specific crimes pardoned or acts forgiven, ensuring a clear and reviewable

record [1 O.C. 126.10-3]. Applicants must receive written notice of the final

Page 2 of 7

43 of 289

Analysis to Draft 1

2026 03 18

Public Meeting

Fiscal Impact

decision within ten (10) business days [1 O.C. 126.10-4]. Even in rescission

proceedings—added through these proposed amendments—individuals are entitled

to notice and thirty (30) days to provide proof of compliance before the OBC may

revoke a pardon, forgiveness, or conditional waiver, preserving fundamental

fairness before any loss of eligibility occurs [1 O.C. 126.10-7]. Collectively, these

provisions embed procedural fairness at each stage and ensure that decisions

affecting rights and opportunities are made transparently, with meaningful

opportunities for participation.

A public meeting has not yet been held.

A fiscal impact statement prepared in accordance with the Legislative Procedures

Act has not yet been requested.

SECTION 2. LEGISLATIVE DEVELOPMENT

A. Background. The Pardon and Forgiveness law was previously adopted and amended as follows:

Resolution BC-05-25-11- A and amended by Resolution BC-01-22-14-B.

B. Request for Amendments. The Pardon and Forgiveness law was added to the Active Files List on

February 18, 2026 at the request of the Oneida Business Committee.

SECTION 3. CONSULTATION AND OUTREACH

▪

•

Representatives from the following departments or entities participated in the development of the

amendments to this Law and legislative analysis:

▪ Pardon and Forgiveness Committee and

▪ Oneida Law Office;

The following laws of the Nation were reviewed in the drafting of this analysis:

▪ Personnel, Policies, and Procedures, and

▪ Safe Neighborhoods.

SECTION 4. PROCESS

A. The amendments to this Law comply with the process set forth in the Legislative Procedures Act.

▪ On February 18, 2026, the Legislative Operating Committee added this Law to its Active Files

List for amendments.

B. At the time this legislative analysis was developed the following work meetings had been held

regarding the development of the amendments to this law:

▪ February 25, 2026: LRO work session with Oneida Law Office.

▪ February 27, 2026: LRO work session with Oneida Law Office.

▪ March 4, 2026: LOC work session.

▪ Additionally, several email communications with the Pardon and Forgiveness Committee

occurred between February 23, 2026 and February 26, 2026.

SECTION 5. CONTENTS OF THE LEGISLATION

▪

Definitions. The proposed amendments add and expand several definitions to support the new

conditional-waiver and rescission procedures. Definitions are added or amended for the following

Page 3 of 7

44 of 289

Analysis to Draft 1

2026 03 18

▪

terms: Conditional Waiver [1 O.C. 126.3-1(d)], Employment Purposes [1 O.C. 126.3-1(j)],

Outstanding Penalties, Fines, or Other Debts (expanded) [1 O.C. 126.3-1(o)] and Rescind [1 O.C.

126.3-1(r)].

▪ Effect. Updating and expanding these definitions clarifies key concepts governing eligibility,

outstanding debts, employment-only applications, and rescission. These changes enhance

clarity in the Law, reduce ambiguity, and ensure consistent interpretation. They also support

the new conditional-waiver process by clearly defining the terms used to determine when an

applicant may be considered despite outstanding financial obligations. Definitions strengthen

procedural transparency and ensure parties understand the meaning and implications of new

mechanisms introduced in later sections.

Good mind and Sacred Trust Framework. The proposed amendments incorporate the Good Mind

teachings directly into the ethical foundation of the law. These teachings — including Kahletsyaḻlésla

(encouraging the best in each other), Kanolukhwát^sla (compassion and identity), Kaʔnikuhli.yo̱

(openness of spirit), Kaʔtshatst^sla (strength of vision), Kalihwi.yo̱ (good words), Twahwahtsilay̱ʌ́ (we

are all family), and Yukwatsistay̱ʌ́ (the fire within) — are identified as core expectations for OBC

members. [1 O.C. 126.1-2].

▪ Effect. This change re-roots the Code in Oneida cultural teachings, reinforcing that ethical

leadership is not merely procedural but spiritual, relational, and reflective of ancestral values.

It supports community understanding that leaders are called to uphold balance, compassion,

truth, and unity when carrying out their responsibilities.

Eligibility Exception for Employment-Only Applications. The proposed amendments create a narrow

eligibility exception allowing applicants with outstanding penalties or fines to proceed when the

application is made solely for employment purposes and the individual qualifies for a conditional

waiver. [1 O.C. 126.6-2(d)].

▪ Effect. This amendment allows individuals whose only barrier to employment eligibility is

unpaid financial obligations to have their applications considered, provided they enter an

approved payment plan under Section 126.6-3. This improves fairness by recognizing that

individuals may be employable even if they have outstanding debts, while still requiring

accountability for repayment. The effect is not to forgive any fines but to allow the employment

review to proceed under structured conditions.

Creation of Conditional Waiver Framework. The proposed amendments to the Law create A new

section—Conditional Waiver—is created to establish detailed requirements for when the Committee

may recommend an exception to ineligibility. This section includes: criteria for eligibility; required

written payment agreements; standard and extended repayment timelines; mandatory conditions

under Section 126.9-3; a good-cause exception for missed payments; and provisions linking

non-payment to rescission under Section 126.10-7.[1 O.C. 126.6-3].

▪ Effect. The new Conditional Waiver provides an avenue for employment eligibility without

altering or forgiving unpaid penalties or fines. It creates a structured, accountability-focused

mechanism to allow hiring while requiring applicants to demonstrate good-faith repayment

efforts. The framework strengthens the Law by promoting economic stability and

rehabilitation, while maintaining the integrity of outstanding obligations. The effect is to

balance individual opportunity with responsibility through a regulated and enforceable process.

Page 4 of 7

45 of 289

Analysis to Draft 1

2026 03 18

▪

Application Documentation Modified. The proposed amendments to the Law allow applicants

proceeding under the Conditional Waiver to submit proof of a Committee-approved payment agreement

in place of proof of full payment of penalties or fines. [1 O.C. 126.6-4(a)(12)], [1 O.C. 126.6-4(b)(11)].

▪ Effect. These amendments align application requirements with the new Conditional

Waiver process, ensuring applicants are not excluded solely because they have not yet

completed repayment. This supports accessibility and ensures consistency in how

employment-only applications are processed under the amended eligibility structure.

▪

Sex-Offender Restrictions Clarified. The proposed amendments to the Law specify that a Tribal pardon

does not affect registration, tracking, or other restrictions, including those imposed under the Nation’s

Safe Neighborhoods law. [1 O.C. 126.9-1(c)].

▪ Effect. This change reinforces public-safety protections by ensuring that pardons do not

override legal obligations associated with sex-offender status. It clarifies the continuing

applicability of safety-related restrictions and prevents misinterpretation regarding the impact

of a Tribal pardon.

Monitoring Requirements Added. The proposed amendments to the Law require the Tribal Secretary’s

Office to monitor compliance with payment-related conditions and provide quarterly reports to the

Committee. [1 O.C. 126.9-4].

▪ Effect. This amendment institutionalizes oversight of repayment obligations associated with

conditional waivers. By assigning an office to track compliance, the Law ensures consistent

enforcement, enhances accountability, and supports the OBC’s ability to determine when

rescission is warranted.

Rescission for Non-Payment Codified. The proposed amendments to the Law authorizes the OBC to

rescind a pardon or forgiveness when an individual fails to meet payment conditions imposed under

126.6-3, after notice and a 30-day opportunity to cure. [1 O.C. 126.10-7].

▪ Effect. This amendment establishes a clear legal mechanism for restoring prior ineligibilities

when an individual does not comply with repayment requirements. It ensures the Conditional

Waiver system is enforceable, protects the integrity of eligibility standards, and prevents

misuse of the waiver process. It also clarifies that rescission is an eligibility action, not an

employment disciplinary action.

SECTION 6. EXISTING LEGISLATION

A. Related legislation. The following laws of the Nation are related to the proposed amendments to this

Law:

▪ Personnel, Policies and Procedures. The purpose of the Personnel, Policies and Procedures

law is to provide employees with a ready source of information about employee related Oneida

Nation policies and procedures. The law addresses recruiting, selection policy, compensation and

benefits, employee relations, safety and health, program/enterprise rules and regulations,

recordkeeping, and privacy and confidentiality of employee records.

▪

The proposed amendments to the Pardon and Forgiveness law establish a narrow

eligibility exception for applications made solely for employment purposes, allowing

individuals with outstanding fines or penalties to proceed if they qualify for a conditional

waiver under [1 O.C. 126.6(2)(d)]. This change applies only where unpaid financial

obligations are the individual’s sole barrier to employment and requires participation in

Page 5 of 7

46 of 289

Analysis to Draft 1

2026 03 18

▪

an approved payment plan pursuant to [1 O.C. 126.6(3)]. The amendments do not forgive

or eliminate any fines or penalties; rather, they allow employment-related applications to

move forward under structured conditions that maintain accountability while preventing

financial barriers from permanently excluding otherwise qualified individuals from

employment.

Safe Neighborhoods law. The purpose of the Safe Neighborhoods law is not to impose a criminal

penalty but rather to serve the Nation’s compelling interest to promote, protect, and improve the health, safety,

and welfare of the reservation population by prohibiting sex offenders from loitering or residing in specified

areas around locations where vulnerable populations, including children, regularly congregate. This law

recognizes the right of sex offenders to reenter the community. Therefore, through this law the Nation balances

its responsibility to sex offenders with its responsibility to protect the surrounding community by promoting

regulatory measures which provide protections for the community that do not wholly prohibit sex offenders

from being part of this community. [3 O.C. 310.1-1]. It is the underlying policy of the law that due to the high

rate of recidivism for sex offenders, the Nation declares that sex offenders are a serious threat to the public

safety of vulnerable populations, including children, if regulatory measures are not in place that protect the

community by reducing opportunity and temptation by prohibiting sex offenders from being present on or

residing in specified areas designated as places where vulnerable populations commonly congregate. [3 O.C.

310.1-2].

▪ The proposed amendments to the Pardon and Forgiveness law are narrowly tailored and

apply solely to employment-related purposes. These amendments do not alter, limit, or

affect the Safe Neighborhoods law in any way. All protections and provisions of the Safe

Neighborhoods law remain fully in effect.

SECTION 7. ENFORCEMENT AND ACCOUNTABILITY

▪

The Pardon and Forgiveness Law enforces compliance through a combination of

eligibility controls, application requirements, hearing enforcement, and post-relief

oversight. Individuals may be deemed automatically ineligible if they are under

investigation, appealing a termination, incarcerated, or have outstanding penalties or

fines, unless they qualify for the employment-only conditional waiver under 126.6-3 [1

O.C. 126.6-2]. Applicants who fail to provide complete information or who misrepresent

facts may have their applications denied, returned, or removed from consideration, and

misrepresentation discovered after a pardon is granted may result in rescission [1 O.C.

126.6-5–6]. Hearing attendance is enforced by authorizing the Committee to postpone a

determination or recommend denial if the applicant does not appear and does not provide

valid documentation within ten days [1 O.C. 126.8-3].

Once a pardon, forgiveness, or conditional waiver is granted, the Law enforces continued

compliance through conditions, restrictions, monitoring, and rescission. The Oneida

Business Committee or the Screening Committee may impose restrictions on

employment or other Tribal benefits, or conditions such as restitution or community

service, and applicants must comply with these terms to retain their restored eligibilities

[1 O.C. 126.9-2–3]. Under the newly added monitoring requirement, the Tribal

Secretary’s Office must track compliance with payment-related conditions and provide

quarterly reports to the Committee [1 O.C. 126.9-4]. The Law’s strongest enforcement

Page 6 of 7

47 of 289

Analysis to Draft 1

2026 03 18

tool is the rescission authority, which allows the OBC to revoke a conditional waiver,

pardon, or forgiveness if an individual fails to meet payment conditions, reinstating all

prior ineligibilities after proper notice and opportunity to cure [1 O.C. 126.10-7].

SECTION 8. OTHER CONSIDERATIONS

Fiscal Impact. Under the Legislative Procedures Act, a fiscal impact statement is required for all

provides further clarification on who the Legislative Operating Committee may direct complete a fiscal

impact statement at various stages of the legislative process, as well as timeframes for completing the

fiscal impact statement.

▪ Conclusion. The Legislative Operating Committee has not yet directed that a fiscal impact be

completed.

Page 7 of 7

48 of 289

ONEIDA NATION PUBLIC MEETING NOTICE

THURSDAY May 14, 2026, 12:15 pm

Find Public Meeting Materials at

Oneida-nsn.gov/government/register/public meetings

Norbert Hill Center-Business Committee Conference Room

N7210 Seminary Rd., Oneida, Wisconsin

Send Public Comments to

LOC@oneidanation.org

Ask Questions here

LOC@oneidanation.org

920-869-4417

PARDON AND FORGIVENESS LAW AMENDMENTS

The purpose of the Pardon and Forgiveness law is to establish a fair, efficient, and formal process through which individuals may seek relief from certain barriers created by past actions.

The Pardon and Forgiveness law amendments will:

 Create an exception allowing applicants with outstanding penalties or fines to proceed

when the application is for employment purposes and the applicant meets the requirements for a conditional waiver.

 Align the Law’s policy with the principals of the Good Mind.

 Establish the full conditional waiver framework, including:

 Waiver applies only to employment eligibility;

 Outstanding penalties/fines remain fully enforceable;

 Mandatory payment agreement (18 months or extended to 3 years if >$5,000);

 Requirements for Pardon and Forgiveness Committee recommendation;

 Good-cause exception for missed payments;

 Grounds for rescission for non-payment.

 Allow an applicant proceeding under the conditional waiver (employment-only) to submit proof of a Pardon and Forgiveness Committee approved payment agreement instead

of proof of full payment.

 Clarify that a pardon or forgiveness does not affect restriction imposed under Oneida’s

Safe Neighborhood’s law, in addition to existing sex-offender requirements.

 Authorize the OBC to rescind a pardon/forgiveness when a person fails to meet a payment condition, with notice and a 30 day cure period;

 Clarify that rescission is an eligibility action, not an employment

action.

Individuals may attend the public meeting for the proposed amendments

to the Pardon and Forgiveness law in person at the Norbert Hill Center, or virtually through

Microsoft Teams. If you wish to attend the public meeting through Microsoft Teams please

contact LOC@oneidanation.org.

PUBLIC COMMENT PERIOD CLOSES THURSDAY MAY 21, 2026

During the public comment period, anyone may submit written comments, questions or input.

Comments may be submitted to the Oneida Nation Secretary’s Office or the Legislative Reference Office in person, by U.S. mail, interoffice mail, or e-mail.

For more information on the proposed amendments to the Pardon and Forgiveness law please review the public meeting packet at oneida-nsn.gov/government/register/public meetings.

49 of 289

Draft 1 (Redline)

2026 03 18

Title 1. Government and Finances - Chapter 126

PARDON AND FORGIVENESS

Tsi>n@hte <hutatwani=y%ne Olihw@=ke

of what they will be free of matter

126.1. Purpose and Policy

126.2. Adoption, Amendment, Conflicts

126.3. Definitions

126.4. Pardon and Forgiveness Screening Committee

Responsibilities

126.5. Tribal Secretary’s Office Responsibilities

126.6. Pardon and Forgiveness Eligibility and Application

126.7. Fees

126.8. Hearings

126.9. Conditions and Restrictions

126.10. Oneida Business Committee

126.1. Purpose and Policy

126.1-1. Purpose.

(a) The purpose of this Law is to provide a fair, efficient and formal process by which:

(1) a Tribal member may receive a pardon for the conviction of a crime(s); or

(2) a Tribal member may receive forgiveness for acts that render him or her

ineligible for housing with the Tribe or other Tribal benefits.

(3) a Tribal member or non-Tribal member may receive forgiveness for acts that

render him or her ineligible for Tribal employment; an occupational license,

certification or permit issued by the Tribe; housing through the Tribe; or other

Tribal benefit.

(b) This Law defines the duties and responsibilities of the Oneida Pardon and Forgiveness

Screening Committee, Oneida Business Committee, Oneida Tribal Secretary’s Office, and

other persons involved in the granting or denial of pardons and forgiveness.

126.1-2. Policy. It is the policy of the Oneida Tribe of Indians of Wisconsin to grant pardons or

forgiveness to individuals upon demonstration of full rehabilitation, trustworthiness and/or

commitment to lawful behavior. Nothing contained herein shall be construed as permitting the

employment of individuals who are otherwise disqualified for employment from certain

occupations under Tribal, State or Federal Law. Receipt of a pardon or forgiveness does not affect

obligations imposed as part of a sentence or conviction in another jurisdiction.

In carrying out this policy, the Nation upholds and reflects the core values of The Good Mind as

expressed by On<yote>a=ka, which includes:

(a) Kahletsyal&sla. The heartfelt encouragement of the best in each of us.

(b) Kanolukhw@sla. Compassion, caring, identity, and joy of being.

(d) Ka>tshatst^sla. The strength of belief and vision as a People.

(e) Kalihwi=y%. The use of the good words about ourselves, our Nation, and our future.

(f) Twahwahts$lay<. All of us are family.

(g) Yukwats$stay<. Our fire, our spirit within each one of us.

126.2. Adoption, Amendment, Conflicts

126.2-1. This Law was adopted by the Oneida Business Committee by Resolution BC-05-25-11A and amended by ResolutionResolutions BC-01-22-14-B, and BC-XX-XX-XX-X.

126.2-2. This Law may be amended pursuant to the procedures set out in Tribal law by the Oneida

1 O.C. 126 – Page 1

50 of 289

Business Committee or the Oneida General Tribal Council.

126.2-3. Should a provision of this Law or the application thereof to any person or circumstances

be held as invalid, such invalidity shall not affect other provisions of this Law which are considered

to have legal force without the invalid portions.

126.2-4. In the event of a conflict between a provision of this Law and a provision of another law,

ordinance, policy, regulation, rule, resolution, or motion, the provisions of this Law shall control.

Provided that, this Law repeals Resolution BC-7-31-02-A: Resolution Adopting a New Oneida

Pardon Ordinance.

126.2-5. This Law is adopted under authority of the Constitution of the Oneida Tribe of Indians

of Wisconsin.

126.3. Definitions

126.3-1. This section shall govern the definitions of words and phrases used within this Law. All

words not defined herein shall be used in their ordinary and everyday sense.

(a) “Applicant” shall meanmeans an individual who is applying for a pardon or forgiveness

from the Tribe.

(b) “Certified mail” shall meanmeans mail sent through either the United States Postal

Service or the Tribal Inter-Office Certified system that provides proof of delivery and

receipt.

(d) “Conditional Waiver” means a temporary exception to the ineligibility criteria under

section 126.6-2(d) for employment-related application; it does not constitute a pardon or

forgiveness and does not alter, waive, or satisfy any outstanding monetary obligation.

(e) “Conditions” shall meanmeans a requirement or prerequisite event or activity.

(ef) “Conflict of interest” shall meanmeans a conflict between the private interests and the

official responsibilities of the committee member.

(fg) “Conviction” shall meanmeans an individual was either found guilty or entered a plea

of guilty or no contest to charges of a crime in any court of competent jurisdiction.

(gh) “Court of competent jurisdiction” shall meanmeans any court or forum that has the

power and authority to properly exercise jurisdiction over a dispute or interpret and/or

enforce laws.

(hi) “Crime” shall meanmeans any act, default, or conduct punishable as a felony or a

misdemeanor.

(i) “(j) “Employment purposes” means seeking eligibility for employment with the Nation

or to remove a bar to continued employment with the Nation, including positions subject

to background eligibility determinations.

(k) “Forgiveness” shall meanmeans the formal and public act of acknowledging or

excusing an individual’s actions or behavior that makes him or her ineligible for Tribal

employment, an occupational license, certification or permit issued by the Tribe, housing

through the Tribe or other Tribal benefit

(jl) “Hearing” shall meanmeans a public hearing, a noticed public forum in which an

applicant has an opportunity to present a case for obtaining a pardon or forgiveness from

the Tribe.

(km) “Individual” shall meanmeans a Tribal member seeking a pardon for a conviction of

a crime, a Tribal member seeking forgiveness for an act(s) that makes him or her ineligible

for housing with the Tribe or other Tribal benefit(s) or anyone seeking forgiveness for an

act(s) that renders him or her ineligible for employment, an occupational license,

certification or permit issued by the Tribe.

1 O.C. 126 – Page 2

51 of 289

100

101

102

103

104

105

106

107

108

109

110

111

112

113

114

115

116

117

118

119

120

121

122

123

124

125

126

127

128

129

130

(ln) “Family member” shall meanmeans a spouse, child sibling, parent, grandparent,

grandchild, step-parent, step-child, in-law or legal guardian.

(m) “Pardon” shall mean(o) “Outstanding penalties, fines, or other debts” means any

unpaid monetary obligations owed to the Nation or arising from any Tribal, State, Federal,

or Municipal court order, judgement, stipulation, or payment requirement, including but

not limited to penalties, fines, fees, repayment obligations, or court-ordered financial

conditions that are due and payable.

(p) “Pardon” means the formal and public act of acknowledging or excusing a Tribal

member’s criminal conviction that makes him or her ineligible for Tribal employment, an

occupational license, a certification or permit issued by the Tribe, housing through the

Tribe, or other Tribal benefit.

(nq) “Prominent locations” shall include, but not be limited to, the following: the Tribal

newspaper; at least one (1) local newspaper with regular distribution within the Reservation

boundaries; one (1) regional Indian newspaper; and the Tribe’s official website.

(or) “Rescind” means to formally revoke, cancel, or withdraw a previously granted pardon

or forgiveness through Oneida Business Committee resolution, thereby restoring all prior

ineligibilities and returning the applicant to the status that existed before the pardon or

forgiveness was granted.

(s) “Restriction” shall meanmeans a limitation or constraint imposed.

(pt) “Tribal” or “Tribe” shall meanmeans the Oneida Tribe of Indians of Wisconsin.

(qu) “Victim” shall meanmeans a person or entity against whom an offense, either civil or

criminal, has been committed.

126.4. Pardon and Forgiveness Screening Committee Responsibilities

126.4-1. A Committee is hereby created for the purpose of carrying out the provisions of this Law.

126.4-2. Authority. The Committee shall:

(a) promulgate internal standard operating procedures necessary to govern its proceedings;

(b) review and process applications for a pardon or forgiveness in an orderly and

expeditious manner;

Human Resources Department;

(d) conduct and preside over hearings;

(e) provide formal, written recommendations to the Oneida Business Committee to

approve or deny a pardon or forgiveness application; and

(f) take other actions reasonably related to the purpose of the Committee.

126.5. Tribal Secretary’s Office Responsibilities

126.5-1. The Tribal Secretary’s Office shall assist the Committee with carrying out the provisions

of this Law and assist individuals in applying for a pardon or forgiveness. The Tribal Secretary’s

Office shall:

(a) create and implement procedures necessary to process pardon and forgiveness

applications.

(b) accept pardon and forgiveness applications.

(d) forward pardon and forgiveness applications to the Committee when the background

investigations are complete.

(e) maintain a record of all pardon and forgiveness applications filed, every pardon and

forgiveness request granted or denied, and the reasons for each action.

1 O.C. 126 – Page 3

52 of 289

131

132

133

134

135

136

137

138

139

140

141

142

143

144

145

146

147

148

149

150

151

152

153

154

155

156

157

158

159

160

161

162

163

164

165

166

167

168

169

170

171

172

173

174

175

176

177

178

(f) maintain a complete and accurate record of all proceedings, including all

correspondence, transcripts, documents, evidence, and appearances made in connection

with the applications.

(g) perform other duties in connection with matters under this Law as may be requested

by the Committee.

126.6. Pardon and Forgiveness Eligibility and Application

126.6-1. Eligibility. A Tribal member may receive a pardon for any criminal conviction(s), or a

forgiveness for an act(s) that renders the Tribal member ineligible for housing with the Tribe or

other Tribal benefit(s); and any individual may receive forgiveness for an act(s) that renders the

individual ineligible for Tribal employment, an occupational license, certification or permit issued

by the Tribe.

(a) Upon completion of incarceration, parole, probation and/or deferred prosecution,

Tribal members shall be eligible to apply for a pardon.

(b) One (1) year after an act is committed, or affirmed through the conclusion of any appeal

process, an individual shall be eligible to apply for pardon or forgiveness.

126.6-2. Ineligibility. An individual is ineligible for a pardon or forgiveness if he or she is:

(a) being investigated for an act and if found to have committed such act, would be

ineligible for the benefit he or she is seeking; or

(b) appealing a termination and the termination makes him or her ineligible for the benefit

he or she is seeking; or

agreement; or

(d) has any outstanding penalties or fines.; however, this paragraph does not apply to

an application made solely for employment purposes under Section 126.1-1(a)(3) when

outstanding penalties or fines are the only unmet eligibility requirement and the applicant

qualifies for a conditional waiver under Section 126.6-3.

126.6-3. Conditional Waiver. A conditional waiver is not a pardon or forgiveness and does not

waive or reduce any penalties, fines, or debts owed to the Nation or any other government. It

temporarily lifts the employment-related ineligibility under Section 126.6-2(d) solely for the

purpose of allowing an applicant to be considered for employment with the Nation. The conditional

waiver exists only within the Committee’s authority to recommend an exception to eligibility

requirements; it does not authorize the Nation to negotiate, modify, or forgive financial obligations

imposed by any court or governmental body.

(a) The Committee may recommend approval despite Section 126.6-2(d) only when:

(i) the application is solely for employment purposes as defined in Section 126.31(j);

(ii) outstanding penalties or fines are the sole basis for ineligibility; and

(iii) the applicant enters a written payment agreement with the Pardon and

Forgiveness Committee requiring full payment within eighteen (18) months from

the OBC resolution date. A payment agreement under this section may consist of

any documentation demonstrating how the applicant will satisfy the outstanding

obligation and does not require negotiation, approval, or participation from any

Tribal, State, Federal, or Municipal government. The payment agreement functions

solely as evidence that the applicant is actively addressing the eligibility condition

and is not an agreement between the Nation and any outside jurisdiction.

(b) Any recommendation under this section shall include a mandatory condition under

Section 126.9-3(a) requiring full payment within eighteen (18) months and compliance

1 O.C. 126 – Page 4

53 of 289

179

180

181

182

183

184

185

186

187

188

189

190

191

192

193

194

195

196

197

198

199

200

201

202

203

204

205

206

207

208

209

210

211

212

213

214

215

216

217

218

219

220

221

222

223

224

225

226

with an approved installment plan.

Section 126.10-7 and immediate reinstatement of prior ineligibility.

(d) Nothing in this section authorizes the Committee to forgive, modify, reduce, or

negotiate penalties or fines imposed by any government; the waiver pertains only to

employment eligibility with the Nation.

(e) Exception for Larger Outstanding Obligations. Notwithstanding Section 126.6-3(a)(iii)

and 126.6-3(b), the Committee may recommend a conditional waiver under the following

extended timeframes, based on the total amount of outstanding penalties or fines:

i. Obligations of five thousand dollars ($5,000) or less. The applicant may be

granted up to eighteen (18) months from the OBC resolution date to satisfy the

outstanding obligation, provided all other requirements of this section are met.

ii. Obligations greater than five thousand dollars ($5,000). The applicant may be

granted up to three (3) years from the OBC resolution date to satisfy the

outstanding obligation provided:

(A) the applicant submits a written payment plan demonstrating the ability

to complete payment within the extended period;

(B) the Committee determines that the extended timeframe is necessary to

prevent unreasonable hardship; and

plan.

(f) Good-Cause Exception for Missed Payment. A missed payment under an approved

repayment plan may be excused upon a finding of good cause, provided that:

i. The applicant submits a written explanation within thirty (30) days of the missed

payment;

ii. The Committee determines that the missed payment resulted from good cause,

which may include but is not limited to unforeseen medical emergencies, loss of

income, or other significant and verifiable circumstances; and

iii. The applicant resumes payment under a revised schedule approved by the

Committee within thirty (30) days of the good-cause determination.

126.6-3. Initiating an Application. Applications for a pardon or forgiveness may be obtained from

the Tribal Secretary’s Office or on the Tribal website. Completed applications shall be filed with

the Tribal Secretary’s Office in person, during normal Tribal business hours, or sent by certified

mail to the Tribal Secretary at P.O. Box 365, Oneida, WI 54155.

126.6-4. Required Application Information. Each applicant is responsible for submitting all

required materials and authorizations.

(a) A completed pardon application shall include the following:

(1) a copy of the applicant’s Tribal enrollment card.

(2) a copy or copies of any discharge papers from incarceration or jail.

(3) official verification of any successful completion date of the probation, parole

or deferred prosecution.

(4) any necessary releases for investigations and/or background checks.

(5) any authorizations from a probation officer to release information.

(6) the required non-refundable fee as specified under 126.6.

(7) a personal written statement, including the reason(s) for requesting a pardon

and a description and documentation of the applicant’s efforts towards selfimprovement.

(8) information regarding the conviction(s) for which the applicant is seeking a

1 O.C. 126 – Page 5

54 of 289

227

228

229

230

231

232

233

234

235

236

237

238

239

240

241

242

243

244

245

246

247

248

249

250

251

252

253

254

255

256

257

258

259

260

261

262

263

264

265

266

267

268

269

270

271

272

273

274

pardon, including:

(A) date(s) upon which the crime(s) occurred;

(B) location(s) where the crime(s) occurred;

(D) jurisdiction(s) which imposed the sentence(s).

(9) verification of attendance or successful completion of any counseling, therapy,

or rehabilitative programs such as anger management or coping skills classes.

(10) letters of reference or support from people well-regarded in the community.

Such letters shall detail the applicant’s accomplishments or contributions to the

community or attest to the applicant’s rehabilitation and trustworthiness. These

may include, but are not limited to:

(A) clergy or other spiritual leaders.

(B) employers and/or community members.

(D) organizers of support groups the applicant attends or has attended.

(11) any other information relevant to the applicant’s conviction(s) or rehabilitation

efforts.

(12) proof of payment of all penalties and fines. For application proceeding under

Section 126.6-3, proof of a Committee-approved payment agreement satisfies the

requirement to document outstanding penalties or fines.

(b) A completed forgiveness application shall include the following:

(1) a copy of the applicant’s Tribal enrollment card, if applicable.

(2) the applicant’s employment record prior to the act, if applicable.

(3) the applicant’s background records.

(4) the act that triggered the applicant’s ineligibility.

(5) the impact of the act on the Tribe.

(6) the length of time since the act.

(7) a written statement from the applicant demonstrating remorse for the violation.

(8) two (2) letters of recommendation, with no more than one (1) recommendation

coming from a person who is a family member of the applicant.

(9) the required non-refundable fee as specified under 126.6.

(10) any additional credible and relevant information.

(11) proof of payment of all penalties and fines. For application proceeding under

Section 126.6-3, proof of a Committee-approved payment agreement satisfies the

requirement to document outstanding penalties or fines.

126.6-5. Failure of the applicant to provide a complete application, or any of the required

information and/or materials may result in:

(a) the application being returned with a request for more information; or

(b) the application being removed from consideration; or

126.6-6. Applicant Misrepresentations. Any applicant who misrepresents, omits, or falsifies any

information on the application or during the pardon process shall be denied a pardon. If a pardon

is granted and it is later determined that there is misrepresented or false information, or pertinent

information was purposefully omitted, the Oneida Business Committee shall have the right to

rescind the pardon.

126.7. Fees

126.7-1. Each application shall be accompanied by a non-refundable fee as set by the Oneida

1 O.C. 126 – Page 6

55 of 289

275

276

277

278

279

280

281

282

283

284

285

286

287

288

289

290

291

292

293

294

295

296

297

298

299

300

301

302

303

304

305

306

307

308

309

310

311

312

313

314

315

316

317

318

319

320

321

322

Business Committee in a resolution. Said payment shall be made payable to the Oneida Tribe in

the form of a:

(a) money order; or

(b) cashier’s check; or

Services, will be providing the funds for the application fee.

126.8. Hearings

126.8-1. Notice of the Hearing. The Committee shall conduct quarterly hearings and provide

official notice to the applicant by certified mail, including the date, time and location of the

hearing, at least thirty (30) calendar days prior to the hearing. Notice shall also be posted in

prominent locations at least thirty (30) calendar days prior to the hearing. If alternate arrangements

have been made under 126.8-2, notice shall be posted in prominent locations with as much advance

notice as possible and as time permits.

(a) Notice of the hearings scheduled for the year shall be posted on the Tribal website and

periodically in the Tribal newspaper.

(b) Hearings shall take place at a regularly scheduled time and location to be determined

by the Committee and shall be open to the public.

126.8-2. Alternate Hearing Arrangements. Applicants who reside out of the State of Wisconsin

who are unable to attend a hearing may submit a written request by certified mail to the Tribal

Secretary’s Office for alternate arrangements to appear by video conference and/or to reschedule

the hearing date. If alternate arrangements are unavailable, the applicant may withdraw the

application up to three (3) business days prior to the hearing without penalty, and may re-apply for

a pardon at any time.

126.8-3. Failure of Applicant to Attend Hearing. Failure of the applicant to appear at the hearing

may result in the Committee postponing making a determination on the application or

recommending the Oneida Business Committee deny the application.

(a) Applicants with a legitimate reason for failing to appear for a hearing shall have ten

(10) calendar days from the date of the missed hearing to provide documentation to the

Committee. Such documentation may include, but is not limited to; a Doctor’s excuse,

accident/police report, or funeral notice.

126.8-4. Testimony and Notarized Statements. The Committee shall obtain oral testimony at the

hearing from the applicant, and any victims, witnesses or other persons supporting or opposing the

pardon or forgiveness.

(a) Victims, witnesses, and other persons unavailable for a scheduled hearing may submit

a notarized statement for consideration.

(b) The Committee may institute recesses and postponements as they see fit.

(d) The Committee may require the applicant to provide further documentation.

(1) Within five (5) business days of the hearing, the Committee shall send a written

request by certified mail to the applicant for the additional documentation.

(2) The applicant shall submit the documentation to the Tribal Secretary’s Office

within thirty (30) calendar days after receiving the request for the documentation.

Failure of the applicant to provide any of the required documentation may result in:

(A) the application being removed from consideration; or

(B) denial of the application.

126.8-5. Deliberations and Recommendation. After the hearing, the Committee shall go into

executive session for deliberations.

1 O.C. 126 – Page 7

56 of 289

323

324

325

326

327

328

329

330

331

332

333

334

335

336

337

338

339

340

341

342

343

344

345

346

347

348

349

350

351

352

353

354

355

356

357

358

359

360

361

362

363

364

365

366

367

368

369

370

(a) The Committee shall consider all information gathered from the hearing, the

application, the background investigation, and any testimony or notarized statements when

determining whether to recommend that the application be approved or denied.

(1) The Committee shall be responsible for weighing the appropriateness of

granting a pardon or forgiveness.

(b) Recommendation. After considering the factors provided, the Committee shall make

a decision and compose a formal, written recommendation for each application, including

reasons to approve or deny the application within sixty (60) days after the pardon or

forgiveness hearing. The recommendation, including any dissenting opinions issued by

the Committee shall be forwarded to the Oneida Business Committee within thirty (30)

calendar days after making a decision, along with the following materials for review:

(1) All information from the application and the background investigation;

(2) Any notarized statements submitted;

(3) A proposed draft resolution; and

(4) An audio recording of the hearing, upon request by an Oneida Business

Committee member.

126.9. Conditions and Restrictions

126.9-1. Pardons. Certain convictions may affect a Tribal member’s rights under state or federal

law, or result in restrictions being placed on a Tribal member, regardless of whether a Tribal pardon

has been granted.

(a) Civil Rights. A pardon by the Tribe does not guarantee the restoration of all civil rights,

and each recipient of a Tribal pardon is responsible for determining whether the pardon

affects any non-Tribal restrictions or limitations that may be applicable pursuant to the

conviction.

(b) Employment. Individuals convicted of a crime that is “substantially related” to the care

of another person or animal may be subject to extended or permanent restrictions on

licensing or professional credentials in fields relating to such caretaking. A Tribal pardon

shall not affect these restrictions.

tracking or other restrictions or obligations imposed upon sex offenders, including any

restrictions imposed through the Nation’s Safe Neighborhoods law.

(d) Voting Rights. Each state, and the federal government are empowered to determine

whether felons may vote in elections, caucuses, referendums or any other venue dependent

on the votes of citizenry. The granting of a Tribal pardon shall not supersede the rights of

these jurisdictions to determine the eligibility of voters.

126.9-2. Other Restrictions. The Committee’s written recommendation to the Oneida Business

Committee to approve an applicant’s request for a pardon or forgiveness may also recommend the

Oneida Business Committee impose restrictions on the applicant. If the Committee does not

recommend a restriction, the Oneida Business Committee shall have the authority to place

restrictions on the applicant before approving the pardon or forgiveness request. Restrictions shall

specify the time lines attached to them, which may expand over a period of months, years, or

indefinitely.

(a) Restrictions shall be clearly defined and may include the following:

(1) The applicant is ineligible for a transfer, promotion or job reassignment.

(2) The applicant may be prohibited from:

(A) Handling cash and/or merchandise.

(B) Having Tribal property sign-off authority.

1 O.C. 126 – Page 8

57 of 289

371

372

373

374

375

376

377

378

379

380

381

382

383

384

385

386

387

388

389

390

391

392

393

394

395

396

397

398

399

400

401

402

403

404

405

406

407

408

409

410

411

412

413

414

415

416

417

418

(D) Supervising or caring for children or the elderly.

(E) Any other restrictions the Oneida Business Committee determines as

appropriate.

(b) When restrictions are imposed for a period of greater than five (5) years, the applicant

may, after five (5) years, apply to have the restrictions modified or lifted. The request to

modify or lift restrictions will follow the same process required to request a pardon.

of such restriction prior to becoming employed by the Tribe.

126.9-3. Conditions. The Committee may also recommend that an applicant requesting a pardon

or forgiveness be required to complete conditions before the applicant is granted the pardon or

forgiveness. If the Committee does not recommend a condition, the Oneida Business Committee

shall have the authority to place conditions on the applicant before approving the pardon or

forgiveness request.

(a) Conditions shall be clearly defined and may include the following:

(1) perform community service hours within a Tribal Department.

(2) payment of restitution to the Tribe.

(3) any other conditions the Oneida Business Committee determines

appropriate.

126.9-4. Monitoring. The Tribal Secretary’s Office shall monitor compliance with all

payment-related conditions and provide quarterly status reports to the Committee until those

conditions have been fully satisfied. Monitoring payment conditions is an integral component of

enforcing eligibility requirements and does not constitute a ministerial or administrative processing

function of the Secretary’s Office. The Secretary’s Office conducts this monitoring solely to

determine whether the required eligibility conditions have been met and does not exercise

decision-making authority regarding eligibility determinations or the continuation of any

conditional waiver.

126.10. Oneida Business Committee

126.10-1. The Oneida Business Committee shall consider all of the information received by the

Committee prior to making a determination on whether to issue or deny a pardon or forgiveness

application. The Oneida Business Committee may accept, reject or modify the Committee’s

recommendation.

126.10-2. Deliberations. Deliberations by the Oneida Business Committee shall take place in

executive session. The Oneida Business Committee may request, by written notice, that the

applicant be present during the deliberations to provide oral testimony or to answer questions. The

notice shall be provided to the applicant thirty (30) days prior to the deliberations and shall contain

the time, place and date of the deliberations.

126.10-3. Final Decision. The Oneida Business Committee shall issue or deny the pardon or

forgiveness in open session, by resolution, including the reasons therefor and shall include for the

record a clear indication of any decision and shall list the specific crimes to be pardoned or acts to

be forgiven. This decision is final and cannot be appealed. Applicants may be eligible to re-apply

for a pardon or forgiveness one (1) year from the date of the most recent denial of a pardon or

forgiveness.

126.10-4. Notification. Notification of the final decision shall be sent to the applicant from the

Tribal Secretary’s office by certified mail or personally served within ten (10) business days

following the decision. Applicants have a right to documentation of the final decision along with

the resolution, and the reason(s) for the final decision.

1 O.C. 126 – Page 9

58 of 289

419

420

421

422

423

424

425

426

427

428

429

430

431

432

433

434

435

436

437

438

439

440

441

442

443

444

445

446

447

448

449

450

451

452

453

454

455

126.10-5. Resolution. To grant or deny a pardon or forgiveness, a majority vote of the Oneida

Business Committee is required.

126.10-6. Eligibilities. Unless otherwise directed by the Oneida Business Committee, a pardon

or forgiveness may fully or partially restore some Tribal eligibilities lost as a result of a conviction

or act including:

(a) employment; and/or

(b) an occupational license, certificate or permit; and/or

(d) other Tribal benefit.

126.10-7. Recission for non-payment. If an individual does not satisfy a payment condition

imposed under Section 126.6-3, the OBC may rescind the pardon or forgiveness by resolution.

Before rescission occurs, the individual shall receive notice and be given thirty (30) days from the

date of that notice to provide proof of payment or otherwise demonstrate compliance. If the

individual does not provide such proof within the thirty-day period, the OBC may proceed with

rescission. Upon rescission, all prior ineligibilities are reinstated.

(a) For the purposes of this section, “individual” means a person who has been granted a

conditional waiver under Section 126.6-3.

(b) Rescission is a determination of eligibility status under this Law and is not an

employment action. Any employment related consequences are processed separately under

applicable personnel policies.

accordance with Section 126.10-4.

End.

Adopted – BC-2-19-93-I

Adopted – BC-11-13-93-B (Oneida Pardon Procedures Policy)

Adopted – BC-11-24-93-B (Temporary Pardons)

Adopted – BC-7-31-02-A

Adopted – BC-05-25-11-A

Adopted – BC-01-22-14-B

Emergency Adoption – BC-04-28-21-A

Emergency Extended – BC-10-27-21-A (Emergency Expired)

Amended – BC-XX-XX-XX-X

1 O.C. 126 – Page 10

59 of 289

Draft 1 (Clean)

2026 03 18

Title 1. Government and Finances - Chapter 126

PARDON AND FORGIVENESS

Tsi>n@hte <hutatwani=y%ne Olihw@=ke

of what they will be free of matter

126.1. Purpose and Policy

126.2. Adoption, Amendment, Conflicts

126.3. Definitions

126.4. Pardon and Forgiveness Screening Committee

Responsibilities

126.5. Tribal Secretary’s Office Responsibilities

126.6. Pardon and Forgiveness Eligibility and Application

126.7. F

This text is long and has been trimmed here. Open the source document for the complete record.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.