Both Michael Goguen, the main investor in PROOF Research, and Larry Murphy, the company’s CEO, confirmed to HuffPost that Zinke still owns a small percentage of the company’s stock—1,000 shares out of nearly 57 million.

Presidential nominees for Cabinet positions must disclose all assets worth $1,000 or more on their executive branch financial disclosure report under the category “other assets and income.” A review of Zinke’s disclosure submitted to the Office of Government Ethics (OGE) in January 2017 and certified by then-head of the OGE, Walter Schaub, found that Zinke did not disclose an interest in PROOF Research. His annual congressional financial disclosures from 2015 and 2016 also did not list stock in the company.

Because PROOF Research is a private company, pinpointing a definitive market value for its stock is somewhat tricky. Goguen, a wealthy former Silicon Valley venture capitalist who has invested large sums of money in Whitefish-area companies and philanthropic causes, told HuffPost that as the company’s primary shareholder, he estimates Zinke’s 1000 shares as “worth less than $2,000, and probably closer to $1,000.” Murphy said in a phone interview that he estimates the value of Zinke’s shares at “around $1,000.” Goguen later backtracked somewhat on his estimation, qualifying that a previous audit of the company valued one share at $0.85, which would put the value of Zinke’s shares at $850.

Interior Department spokeswoman Heather Swift said that Zinke’s shares would be valued as less than $1,000—”far below the reporting thresholds for the executive branch.”

“The Secretary is committed to the highest ethical standards and his first meeting as secretary was with the Department’s senior ethics officers,” Swift said via email, adding that Zinke owns 1,000 shares out of 57 million. According to Swift, “Zinke’s last two purchases of the shares were at valuations of 25 cents per share and 40 cents per share, which would put their fair market valuation between $250 and $400.” Beyond the two share purchases she cited, Swift did not specify about other purchases.

But beyond the disclosure concerns, there is the matter of what access this relationship may grant the company at the Department of Interior. According to Zinke’s work calendar , he and his top aides met with a group of PROOF Research executives and a company lobbyist on April 11, 2017. The schedule entry was titled, “Brief Update of Proof Research.”

The company’s delegation included its president and founder K.K. Jense, CEO Larry Murphy, director of research and development John Clements, and Brian Kelly of BK Strategies, the company’s registered lobbyist in Washington, D.C. The calendar described Kelly as “Man About Town,” with an added side note: “Loves Whitefish, MT.” Proof Research’s most recent business filings with the state of Montana show that Kelly is also a director of the company.

Murphy told HuffPost in an email that the company periodically seeks out meetings with various public officials to discuss matters of interest to the company, adding that “[w]e don’t generally comment on the substance of those discussions.” In a follow-up phone conversation, Murphy explained that the company met with Zinke last year mainly because of the “Montana connection,” in an attempt to determine “whether the Secretary knew of any needs in the government for the company’s products.”

Murphy said that during the meeting Zinke primarily listened to company’s executives and requested an update on its operations. The company’s top executives visit Washington annually for trade shows, he said, and their D.C. representative will try to organize meetings with public officials while they are in town.

Federal lobbying disclosures show that Kelly has lobbied the U.S. House of Representatives and the Department of Defense on behalf of the company since 2015, on issues including “defense appropriations and authorizations” and “carbon fiber barrels.” PROOF Research has received at least one government contract in the last year—$11.4 million from the Department of Defense to develop advanced hybrid-composite muzzle brakes and medium-caliber barrels for future weapon systems.

Interior spokeswoman Swift did not respond to questions about Zinke’s meeting with PROOF Research executives and its lobbyist.

Virginia Canter, executive branch ethics counsel at the government watchdog Citizens for Responsibility and Ethics in Washington (CREW) and former White House associate counsel for Presidents Bill Clinton and Barack Obama, said the case raises several red flags. “The fact that he met with company executives is troubling since by law he’s required to recuse himself from participating in particular matters that would directly and predictably affect the company. “

“Zinke is required to report assets such as private company stocks with a fair market value of over $1,000,” said Canter. “And the fact that he met with company executives is troubling since by law he’s required to recuse himself from participating in particular matters that would directly and predictably affect the company. “