A fundraiser held for her on Jan. 16, invited members of Winnipeg's arts community and asked for a $50 donation per person.
CBC has obtained a copy of the invitation for the fundraiser. It reads "Invitees are primarily members of the cultural community in Winnipeg. Shelly is interested in meeting with you and hearing your views."
Conflict of interest rules say public office holders must not ask for donations from people who might lobby them.
Brian Bowman, chair of the Winnipeg Art Gallery's board of governors, was invited but didn't go.
"The invitation lead me to believe that if I attended, I would have been attending a partisan event on behalf of the Winnipeg Art Gallery," said the Winnipeg lawyer Wednesday. "I made the personal decision that it wasn't appropriate."
Bowman wouldn't comment directly on the ethics commissioner's investigation, but said he hopes the outcome of the whole affair doesn't hurt Winnipeg's arts community.
"I would hate to think that this isolated incident would in any way shape or form aggravate the relationships between members of the arts community and of course the minister," he said adding as heritage minister, Glover has been supportive of the Winnipeg Art Gallery.
"She's attended functions that we've had, most recently our Gallery Ball."
The Royal Manitoba Theatre Centre was also on the invitation list. A spokesperson said MTC is not commenting.
But other members of Winnipeg's cultural community who were invited to the event have told CBC they too were uncomfortable being asked to donate to the minister who makes funding decisions about their organizations, but they declined to go on the record.
Invitation "asked for trouble"
Saskatchewan Liberal MP Ralph Goodale, who initially asked the ethics commissioner to look into the matter, said he's not surprised to hear that.
"It tells me that this is a situation that shouldn't have happened," he said.
"It's natural that people in the arts community would feel that queasiness that, one the one hand, they want to have a good relationship with the minister. On the other hand, it should not be conditional upon fundraising activity."
Goodale said it's clear that the invitation includes the very elements politicians are warned to be careful of combining.
"Ministerial responsibility, the issue of fundraising and the people who were targeted by this invitation, all of those three things should not appear on the same piece of paper," he said. "Otherwise I think you're asking for trouble. And it obviously looks like a troubling situation, or Ms Dawson would not be conducting an investigation."
It's not the first time the St. Boniface MP has been under investigation.
Glover was also investigated for overspending during the 2011 election.
She was found to have overspent by $2,267. She has promised to underspend by that amount if she runs again.
Glover was not available to comment Wednesday on the ethics commissioner's investigation.
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