Element:
Personal and Substantial Participation
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IF you (either individually or by directing others) decide, supervise, recommend, approve/disapprove, determine, fund, advise, or investigate any significant aspect of or otherwise contribute to a government matter...
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THEN you have participated personally and substantially.
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Personal means active participation, including the direct and active supervision of a subordinate in a matter.
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Substantial means that your participation is of significance to the matter, even if not determinative.
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Ministerial actions - those not involving individual judgment or discretion - are not likely to rise to the level of substantial participation.
