SALEM — Oregon ethics investigators will examine whether former Gov. John Kitzhaber and first lady Cylvia Hayes violated state laws that bar public officials from accepting expensive gifts and misusing their positions for personal gain.

The Oregon Government Ethics Commission will also investigate whether the couple publicly disclosed actual or potential conflicts of interest as the law requires. Commissioners voted unanimously Friday morning to proceed from an initial inquiry to a full investigation.

The commission said investigators will examine whether Kitzhaber and Hayes benefited financially from private contracts she landed by virtue of her public position.

“In this case, the available information indicates that Ms. Hayes may have accepted paid contracts that would not have been available to her but for her holding of her official position as policy advisor and First Lady with the Office of the Governor,” an ethics investigator wrote in a report summarizing the initial inquiry.

The commission’s vote Friday starts a 180-day clock to complete the inquiry and recommend whether to pursue civil penalties, although officials also have the option to extend the investigations by 30 days. Investigators may well need the extra time: According to investigative reports released Friday, the Oregon Department of Justice has more than 4 million pages of records that could be relevant to the review.

Kitzhaber has maintained he did nothing wrong. He also insisted, before resigning in February 2015, that he and his staff were sensitive to potential conflicts of interest and made sure to separate Hayes’ public work from the consulting jobs that paid her more than $200,000 since Kitzhaber’s third term started in 2011.

Janet Hoffman, the former governor’s attorney, said in a letter to the commission this month that members “should not pursue an investigation of this politically motivated complaint because there is no substantial objective basis to believe that a violation of the ethics laws may have been committed. Rather, these allegations arose in the context of a political election and ensuing media frenzy that resulted in the resignation of a popular, effective governor who chose to put his public duty before the defense of his reputation.”

The ethics commission resumed its preliminary investigation of Hayes and Kitzhaber last month, after the U.S. Department of Justice concluded its 28-month criminal influence-peddling investigation of the couple and decided not to file criminal charges. The Oregon Department of Justice ended its criminal probe in February.

Tung Yin, a professor at Lewis & Clark Law School in Portland, said it could be easier for ethics investigators to build cases against Kitzhaber and Hayes for a couple reasons. First, the burden of proof is lower than in criminal matters. Second, the Supreme Court ruling last year that overturned corruption convictions of former Virginia Gov. Bob McDonnell and his wife set a high bar for proving public corruption at the federal level.

“It’s the same facts that they would be investigating,” Yin said of the state ethics panel. “But if they can prove the particular facts, they might be able to fit those more easily into the Oregon statutes than what the federal investigators would have been able to do.”

If the commission determines Kitzhaber and Hayes violated ethics laws, the potential civil penalties could range from $5,000 for accepting gifts above the limit and for failing to disclose conflicts of interest, up to $10,000 for willfully violating the law against misuse of one’s public position. However, a 2015 analysis by The Oregonian revealed the commission negotiated lower penalties in every case involving a public official since 2008.

The reviews stem from complaints filed with the commission in 2014, asking it to look into reports Hayes used her unpaid position as a policy adviser to the governor on environmental and economic policies to benefit her career as a paid advocate on those same issues. There were also reports Kitzhaber’s associates helped create jobs for Hayes, whom the governor listed on state disclosures as a member of his household.

In addition to scrutinizing Hayes’ paid contracts, the commission’s staff will look into Hayes’ use of employees in the governor’s office to book personal business travel, track news on “issues that concerned her private consulting business” and schedule meetings related to her contracts, according to a commission report.

Investigators will also delve into whether Hayes’ acceptance of a temporary spokesperson, paid for by the Oregon Business Council, constituted a gift in excess of Oregon’s $50 limit. The council also paid for a consultant to work with Hayes on policy matters.

In laying out the case for a full investigation of Kitzhaber, ethics investigators pointed to an email exchange between the governor and his top staffers in August 2011 regarding Hayes’ role in the governor’s office. Kitzhaber referred to Hayes’ $118,000 fellowship with an advocacy group called the Clean Economy Development Center, a job arranged by an adviser who worked for both Kitzhaber’s campaign and administration.

“Cylvia needs to be advocating the same clean economy policy in her role as a spokesperson/advocate for the Governor’s Office and her role as a Clean Economy Fellow,” Kitzhaber wrote. “There cannot be any daylight between them.”

The governor went on to explain that was the reason Hayes needed “a role in developing the policy itself.” The Oregonian obtained the email exchange, which took place over personal email accounts, through a public records request to Kitzhaber’s former chiefs of staff.

Additionally, the ethics investigator referenced news reports based on public records that revealed Hayes was pushing for the state to adopt an alternative economic measure called the Genuine Progress Indicator at the same time the advocacy group Demos was paying her to promote the tool.

The investigator also pointed to emails between Kitzhaber and Hayes that a state IT employee leaked to Willamette Week. In May 2013, Kitzhaber wrote to Hayes that his only priority was for her to be happy. To that end, Kitzhaber said he would “help support in any way I can moving your career to the next level and for you to be known and sought after as a national and international speaker, consultant and messenger.”