However, Gallagher and Nikoloff say their government bosses knew about their businesses and had failed the pair by not advising them about potential conflicts of interest.
"We maintain that the CERA legal team, leadership and CERA's external legal team were aware of what we were doing with our outside business interests," the pair said in a statement.
"We trusted (relied on) the people around us to provide the necessary advice."
"They chose not to advise us there was a potential conflict. We acknowledge we should have declared what we were doing in writing."
They also said Heron's report found they had integrity and that allegations of criminality were unfounded.
The State Services Commission says the third man, Cleverly, was not involved in the other two men's business operations but should have shown better care and judgement.