2015 SUMMARY OF ETHICS RULES
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`ECONOMIC DEVELOPMENT
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`ADMINISTRATION
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`ETHICS LAW
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` ETHICS LAW AND PROGRAMS DIVISION
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` OFFICE OF THE ASSISTANT GENERAL COUNSEL FOR ADMINISTRATION
` UNITED STATES DEPARTMENT OF COMMERCE
`202-482-5384 – ethicsdivision@doc.gov – www.commerce.gov/ethics
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`Ethics
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`Voip-Pal Ex. 2094
`IPR2016-01198 and IPR2016-01201
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`PUBLIC SERVICE IS A PUBLIC TRUST
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`As an employee of the Economic Development Administration (EDA), you have been
`placed in a position of trust and are held to a high standard of ethical conduct. You not
`only have an obligation to perform your duties to the best of your abilities but also to
`familiarize yourself with Government ethics rules and policies and to comply with
`applicable restrictions, both when performing your Government duties and, in some
`cases, when engaging in personal activities when off duty and after leaving Federal
`service.
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`This contains a summary of ethics rules based on Federal conflict of interest statutes,
`regulations set forth in the Standards of Ethical Conduct for Employees of the Executive
`Branch, and other ethics laws and Department of Commerce policies. Additional
`information is available from the website of the Ethics Law and Programs Division at
`www.commerce.gov/ethics. However, it is always best to seek specific advice from an
`ethics official about the rules or their application to a specific situation.
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`Ethics Law and Programs Division: To obtain advice about ethics laws, you can
`contact a Commerce ethics official at: ethicsdivision@doc.gov or 202-482-5384.
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`Designated Agency Ethics Official for the U.S. Department of Commerce:
`Barbara S. Fredericks – Assistant General Counsel for Administration
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`Alternate Designated Agency Ethics Official:
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`David Maggi – Chief of the Ethics Law and Programs Division
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`Office of the Assistant General Counsel for Administration: In addition to
`information about ethics laws and policies, information on employment and labor law
`and general law issues is available on the website of the Office of the Assistant General
`Counsel for Administration:
`http://www.commerce.gov/os/ogc/office-assistant-general-counsel-administration.
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`Employment and Labor Law Division: To obtain advice about employment and
`labor law issues, you can contact an employment law attorney at 202-482-5017.
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`General Law Division: To obtain advice about appropriations laws, Federal
`advisory committees, joint projects, preservation and release of documents, and
`other general administrative law issues, you can contact a general law attorney at
`202-482-5391.
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`Office of Inspector General – The Ethics Law and Programs Division provides advice
`but does not investigate allegations of violations of law. To report fraud, waste, abuse,
`or other violations of law, or to request an investigation, contact the Office of Inspector
`General Hotline at 800-424-5197 or 202-482-2495 or hotline@oig.doc.gov.
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`2015 EDA Summary of Ethics Rules – page 1
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`GENERAL ETHICAL PRINCIPLES
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`1. Public service is a public trust, requiring employees to place loyalty to the
`Constitution, the laws and ethical principles above private gain.
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`2. Employees shall not hold financial interests that conflict with the conscientious
`performance of duty.
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`3. Employees shall not engage in financial transactions using nonpublic Government
`information or allow the improper use of such information to further any private
`interest.
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`4. An employee shall not, except as permitted in ethics regulations, solicit or accept
`any gift or other item of monetary value from any person or entity seeking official
`action from, doing business with, or conducting activities regulated by the
`employee’s agency, or whose interests may be substantially affected by the
`performance or non-performance of the employee’s duties.
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`5. Employees shall put forth honest effort in the performance of their duties.
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`6. Employees shall not knowingly make unauthorized commitments or promises of any
`kind purporting to bind the Government.
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`7. Employees shall not use public office for private gain.
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`8. Employees shall act impartially and not give preferential treatment to any private
`organization or individual.
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`9. Employees shall protect and conserve Federal property and shall not use it for other
`than authorized activities.
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`10. Employees shall not engage in outside employment or activities, including seeking
`or negotiating for employment, that conflict with official Government duties and
`responsibilities.
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`11. Employees shall disclose waste, fraud, abuse, and corruption to appropriate
`authorities.
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`12. Employees shall satisfy in good faith their obligations as citizens, including all just
`financial obligations, especially those–such as Federal, State, or local taxes–that are
`imposed by law.
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`13. Employees shall adhere to all laws and regulations that provide equal opportunity for
`all Americans regardless of race, color, religion, sex, national origin, age, or
`handicap.
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`14. Employees shall endeavor to avoid any actions creating the appearance that they
`are violating the law or the ethical standards set forth in ethics regulations. Whether
`particular situations create an appearance that the law or these standards have
`been violated shall be determined from the perspective of a reasonable person with
`knowledge of the relevant facts.
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`2015 EDA Summary of Ethics Rules – page 2
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`MISUSE OF GOVERNMENT RESOURCES
` Basic Principle: Do Not Steal
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`As an EDA employee you have access to equipment, services, supplies, and other
`resources that are paid for by the Government to promote public programs. Even the
`authority of your position, nonpublic information, and your EDA title are considered
`public property. You must be careful to use such resources only for Government
`purposes or, in a few cases, personal purposes that are specifically authorized, as listed
`below.
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`PROHIBITED USES
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`You cannot use:
`- a Government credit card for personal
`purchases (except those specifically
`authorized);
`- access to the internet or an email
`account from a Government computer
`or mobile device:
`- to view sexually explicit material;
`- for for-profit activities or to run a
`business;
`- for political purposes, including by
`sending email to support or oppose
`a candidate or political party;
`- for prohibited discriminatory
`conduct;
`- for lobbying activities;
`- for any unlawful purpose or any
`activity that would bring discredit on
`the Department.
`- nonpublic information for any personal
`purpose, such as to make
`investments;
`- your Government title for personal
`purposes (except in connection with a
`publication in a scientific or technical
`journal (with a disclaimer) or as part of
`a general biographical description);
`- Government time for personal
`activities; or
`- your Government authority to help
`yourself or others on personal matters.
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`2015 EDA Summary of Ethics Rules – page 3
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`PERMITTED USES
`You can use:
`- access to the Internet and a personal
`email account for personal research or
`to send a personal email;*
`- Government printers and copiers for
`personal purposes* if such use does
`not consume excessive resources;
`- your Government title for personal
`purposes if not likely to appear as
`acting in an official capacity, as part of
`general biographical information (such
`as a biographical sketch in a book or
`on Facebook®), or when writing for a
`scientific or technical publication (if the
`publication includes a disclaimer that
`the views are your own and not the
`Department’s); and
`- frequent flier miles or other travel
`benefits earned from Government
`travel for personal purposes, including
`vacation travel.
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`* unless it is for a business purpose, a
`political purpose, a lobbying activity,
`will result in additional charges to the
`Government, is discriminatory,
`concerns sexually explicit materials,
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`would violate a law, or would bring
`discredit to the Government
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`PERMITTED GIFTS
`You can accept an unsolicited gift or
`invitation if it is:
`- offered by someone with no business
`before Commerce and not offered
`because of your Government
`position;*
`- from a relative or friend;
`- $20 or less in value (and you received
`$50 or less in gifts from the same
`source during the year);*
`- an invitation to a widely-attended
`gathering and your supervisor has
`approved your attendance;*
`- a meal at which you are speaking in
`an official capacity;
`- a discount available to the public as a
`whole or to all Federal employees;
`- offered because of your spouse’s
`employment;
`- a card, plaque, or other item of little
`intrinsic value;
`- an award for which you received
`approval from an ethics official;*
`- a business meal overseas with
`non-U.S. citizens present if the cost is
`less than the local per diem;*
`- a meal, lodging, or travel related to an
`outside business relationship;* or
`- from a foreign government and valued
`at $375 or less.
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`GIFTS AND BRIBES
` Basic Principle: Avoid Undue Influence
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`There are three types of gifts you may encounter as a Government employee: personal
`gifts offered to you from someone outside the Government, personal gifts offered to you
`from another Federal employee, and a gift or donation offered to you for use by EDA for
`agency programs or operations, including for your official travel. Each of these types of
`gifts is covered by different rules. In addition, criminal statutes bar you from accepting a
`bribe, which is an offer of anything of value to take action (or fail to take action) as a
`Government employee, or a “salary supplementation,” which is a payment by anyone
`other than the U.S. Government to do your job.
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`PERSONAL GIFTS FROM NON-GOVERNMENT SOURCES
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`PROHIBITED GIFTS
`You cannot accept a gift or invitation if it
`is:
`- offered by someone that is regulated
`by Commerce, has or seeks business
`with Commerce, or can be affected by
`performance of your Government
`duties (unless it is listed as permitted
`in the column on the left);
`- offered because of your Government
`position (unless it is listed as permitted
`in the column on the left); or
`- specifically to take action (or fail to
`take action) as a Government
`employee.
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`* This provision does not apply if you
`are a political appointee and the donor
`of the gift or the host of the event is a
`registered lobbying organization
`(unless it is a 501(c)(3) organization or
`a media company) or if the invitation
`was extended by a registered lobbyist.
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`2015 EDA Summary of Ethics Rules – page 4
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`GIFTS (continued) GIFT
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`PERSONAL GIFTS FROM OTHER FEDERAL EMPLOYEES
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`PERMITTED GIFTS
`You can accept a gift or invitation from
`another Federal employee if it is:
`- not from a subordinate;
`- $10 or less in value;
`- for a special, major non-recurring
`event (such as the birth or adoption of
`a child, retirement, serious illness, or
`wedding);
`- food shared in the office;
`- a gift of personal hospitality at the
`employee’s home; or
`- a gift to you as a host or hostess (such
`as wine or flowers).
`You can also offer a gift to a supervisor
`if it is listed above as the type of gift that
`is permitted.
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`PROHIBITED GIFTS
`You cannot accept a gift or invitation
`from another Federal employee if it is
`offered by a subordinate, unless it is:
`- $10 or less,
`- for a major life event,
`- food shared in the office, or
`- a host or hostess gift.
`You also cannot offer a gift to a
`supervisor unless it is listed as a gift that
`is permitted (see the column to the left).
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`GIFTS TO THE ECONOMIC DEVELOPMENT ADMINISTRATION
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`PROHIBITED AGENCY GIFTS
`You cannot accept a gift or donation for
`EDA if:
`- it is a gift of services (other than for
`travel);
`- it will not further an agency mission;
`- acceptance will create an appearance
`of undue influence on agency
`activities, which in most cases bars
`acceptance of a gift from:
`- an agency contractor (or bidder)
`- an agency grantee (or applicant); or
`- someone with an interest in a
`controversial matter before EDA; or
`- it is for Government travel and it:
`- was solicited or
`- is for first-class travel.
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`PERMITTED AGENCY GIFTS
`You can accept a gift or donation of
`property or travel for EDA if:
`- it will further a Government program,
`- it is approved by the appropriate
`agency official, and
`- acceptance will not create an
`appearance of loss of impartiality
`regarding agency programs or
`operations (which generally means
`that the donor is not an EDA
`contractor or grantee).
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`2015 EDA Summary of Ethics Rules – page 5
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`CONFLICTS OF INTEREST AND DISQUALIFICATIONS
` Basic Principle: No Self-Dealing and No Special Favors
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`You have a conflict of interest when your personal interests—or the interests of those
`close to you (your spouse, minor child, household member, or partner)—might differ
`from the interests of the Government and, therefore, might raise a question about
`actions you take as an EDA employee. Ethics laws address this problem by requiring
`employees to disqualify themselves from working on matters in which there are such
`conflicts. Conflicts of interest can be created because of your financial interests,
`positions you hold outside the Government, or personal relationships you have.
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`FINANCIAL CONFLICTS OF INTEREST
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`PERMITTED ACTIONS
`No Conflict – No Disqualification
`You can work on matters regarding a
`financial interest:
`- in a stock* or bond* valued at $15,000
`or less;
`- in a broadly-diversified mutual fund;*
`- in a sector-specific fund* (a fund that
`invests in a specific industry sector or
`state or foreign country) valued at
`$50,000 or less;
`- held by an adult child (if not living in
`your household); or
`- covered by a conflict of interest waiver.
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`PROHIBITED ACTIONS
`Conflict of Interest
`– Disqualification Required
`You cannot work on a matter if agency
`action will affect:
`- a company in which you hold:†
`- stock* of greater than $15,000,
`- stock* of greater than $25,000
`regarding a policy matter affecting
`the company as a member of an
`industry sector,
`- stock* totaling greater than $50,000
`in companies that will be affected by
`the matter at issue, or
`- interests in a sector-specific mutual
`fund* greater than $50,000; or
`- financial interests you hold† that are
`not securities traded on a U.S.
`exchange, such as real estate,
`partnership holdings, securities traded
`only on a foreign exchange, stock
`options, patent rights, etc.; or
`- a company, organization, or other
`entity with which you:
`- are employed;
`- serve as an officer; or
`- serve on a governing board.
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`ACTIONS PERMITTED IN PART
`Limited Disqualification –
`Disqualification Required Regarding
`Some Issues
`You can participate in general policy
`matters, but not in matters involving
`specific parties, that will affect:
`- a company in which you hold† stock*
`valued at $15,001-$25,000,
`- financial interests of a member of your
`household who is not a spouse or
`minor child, or
`- financial interests covered by a
`conflict of interest waiver.
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`* if traded on a U.S. exchange
`† or your spouse, minor child, household member, or general partner holds
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`2015 EDA Summary of Ethics Rules – page 6
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`CONFLICTS OF INTEREST BASED ON PERSONAL RELATIONSHIPS
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`PERMITTED ACTIONS
`No Conflict – No Disqualification
`You can work on a matter in which one
`of the parties is (or is represented by)
`someone with whom you have a
`personal relationship if:
`- the relationship concerns:
`- a close friend,
`- a former employer or client you
`worked for more than one year ago
`(career employees) or more than two
`years before your appointment
`(political appointees),
`- an organization in which you are a
`member but not active (other than by
`attending meetings and paying
`dues), or
`- someone with whom your business
`dealings are limited to routine
`consumer transactions or
`- you have received special
`authorization to work on the matter
`notwithstanding the involvement of
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`someone with whom you have a close
`personal or business relationship
`(which is obtained through the Ethics
`Law and Programs Division).
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`PROHIBITED ACTIONS
`Conflict of Interest
`– Disqualification Required
`You cannot work on a matter in which
`one of the parties is (or is represented
`by):
`- someone with whom you have a
`business or financial relationship;
`- a close relative;
`- an organization in which you are
`active;
`- the employer or client (or prospective
`employer or client) of your parents,
`spouse, or dependent child;
`- someone with whom were employed
`or served as an agent, attorney,
`consultant, contractor, director,
`general partner, or trustee during the
`past year; or
`- if you are a political appointee, for a
`period of two years after your
`appointment, someone with whom you
`were employed or served as an agent,
`attorney, consultant, contractor,
`director, general partner, or trustee
`during the two years before your
`appointment.
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`CONFLICTS OF INTEREST AND DISQUALIFICATIONS
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`RESTRICTIONS ON INVESTMENTS AND ACTIVITIES
`If disqualification due to a financial interest or outside employment or active
`participation in an organization will prevent you from performing important
`Government duties, you should not make the investment or engage in the activity. In
`addition, you cannot:
`- use nonpublic information gained from Federal employment to make an investment
`decision or
`- if you file a public financial disclosure report (OGE Form 278) (such as if you are a
`political appointee or SES member), invest in an Initial Public Offering (IPO) except
`in the same manner as is available to members of the public generally.
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`2015 EDA Summary of Ethics Rules – page 7
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`NON-FEDERAL EMPLOYMENT AND ACTIVITIES
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` Basic Principle: Avoid Divided Loyalties B
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`Work outside EDA or engaging in other personal activities is permitted if it will not impair
`your ability to perform your Government duties, will not create the perception that you
`are using your public office for private gain, and is not expressly prohibited by law.
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`PROHIBITED ACTIVITIES
`- You cannot be employed by, or hold a
`position with, a foreign government.
`- You cannot contact a Federal agency
`or Federal court on behalf of someone
`else (but see the permitted activities in
`the column on the left for exceptions).
`- You cannot be employed by someone
`whose financial interests can be
`affected by performance of your
`Federal duties (unless such duties can
`be easily reassigned).
`- You cannot hold a position as an
`officer or board member of an
`organization whose financial interests
`can be affected by performance of
`your Federal duties (unless such
`duties can be easily reassigned).
`- You cannot be paid for teaching,
`speaking, or writing about programs,
`policies, and operations of Commerce,
`unless it is teaching a course that is
`part of the regular curriculum of an
`educational institution.
`- If you are a noncareer SES member,
`you cannot be paid for teaching,
`speaking, or writing about a
`Commerce subject matter area, unless
`it is teaching a course that is part of
`the regular curriculum of an
`educational institution and prior
`approval is given.
`- If you are a noncareer SES member or
`Presidential appointee, there are limits
`on outside earned income and work or
`affiliation with organizations that create
`a fiduciary relationship.
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`PERMITTED ACTIVITIES
`- You can work for anyone who does
`not have matters before your office
`(unless otherwise prohibited (see the
`column to the right)).
`- You can teach and write for pay if the
`subject is not related to the programs,
`policies, or operations of Commerce.
`- You can teach and write about
`Commerce programs, operations, and
`policies if you do not disclose
`nonpublic information and are not paid
`(but prior agency review is required in
`some cases and prior approval is
`required for noncareer SES members).
`- You can contact a Federal agency on
`behalf of:
`- your spouse, child, or parent; an
`estate or trust you administer; or
`someone for whom you have a
`power of attorney but only if you
`receive prior approval;
`- another Federal employee in a
`personnel matter if you do not
`receive payment; or
`- a Federal employee organization
`unless it concerns Government
`financial benefits, a claim against the
`Government, or is in the context of
`an administrative proceeding.
`- You can practice law as a personal
`activity if you do not represent clients
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`before a Federal agency or a Federal
`court and do not advise on matters in
`which the U.S. Government has an
`interest.
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`2015 EDA Summary of Ethics Rules – page 8
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`POLITICAL ACTIVITIES
` Basic Principle: Do Not Mix Politics and Public Service
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`It is important that the public have confidence that Government employees will
`conscientiously implement the policies of the President and senior Administration
`officials without regard to the employees’ own political affiliations and that Government
`resources will not be used to try to influence elections. At the same time, Federal
`employees have a right to participate in elections as private citizens. To insulate
`Government employees from undue political influence, to ensure the objectivity of
`Government operations, and to protect employees’ rights as citizens, Federal law
`imposes restrictions on some political activities of employees while ensuring the right to
`engage in other political activities, as summarized below.
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`PERMITTED ACTIVITIES
`All Employees: You can:
`- give funds to a candidate or party;
`- attend a political fund-raiser, rally, or
`other campaign event;
`- vote;
`- sign a political petition;
`- display a political bumper sticker on
`your car, wear a political button (when
`not on duty and not on Federal
`premises), and put a political sign on
`your lawn; and
`- run for office in a non-partisan
`election.
`Employees who are not career SES
`members: You can also:
`- assist in the management of a
`campaign;
`- serve as an officer in a political group;
`- make telephone calls and otherwise
`solicit votes (but not funds) for a
`candidate;
`- stuff envelopes for a campaign; and
`- speak at a political event.
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`PROHIBITED ACTIVITIES
`All Employees: You cannot:
`- engage in political activities while on
`Government premises;*
`- engage in political activities while on
`duty;*
`- use Government resources for political
`activities, including your agency title,
`or access to email or the internet;
`- ask for or accept political contributions
`(even during non-duty hours) (except
`that if you are a Government union
`member you can seek contributions
`from a non-subordinate union member
`for a union multi-candidate fund);
`- host a political fund-raiser;
`- use the authority of your Government
`position to support or oppose a
`partisan candidate or political party;
`- run as a candidate in a partisan
`election (except as an independent
`candidate in local elections in
`Washington, D.C., its suburbs, and
`other designated areas); or
`- ask for or accept volunteer services
`from a subordinate.
`Career SES members: You also
`cannot:
`- assist a campaign (even during
`non-duty hours) or
`- hold office in a political organization.
`* unless you are a Presidential appointee in a Senate-confirmed position
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`2015 EDA Summary of Ethics Rules – page 9
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`SEEKING EMPLOYMENT AND POST-EMPLOYMENT ACTIVITIES
` Basic Principle: Avoid Divided Loyalties
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`SEEKING EMPLOYMENT OUTSIDE THE GOVERNMENT
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`You are free to look for career opportunities outside the Federal Government but cannot
`work as a Federal employee on any matter that would affect anyone you have
`contacted about possible future employment or who has contacted you about such
`employment, until you or the other party indicate the end of discussions.
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`Notice Requirements: If you are a member of the SES, a political appointee, or
`someone otherwise required to file a public financial disclosure report (OGE Form 278),
`you must notify an ethics official within three days of the employment contact that you
`will not participate in matters affecting the financial interests of the prospective
`employer. If you are a procurement official for a procurement valued at $100,000 or
`more, you must notify your supervisor and an ethics official about employment contacts.
`
`POST-EMPLOYMENT RESTRICTIONS ON ALL EMPLOYEES
`
`
`
`
`
`
`
`
`
`PROHIBITED ACTIVITIES
`PERMITTED ACTIVITIES
`
`After leaving Federal service you
`You can engage in an activity after
`
`cannot:
`leaving Federal service that:
`
`- represent others before a Federal
`- does not entail representing others
`
`
`agency or court regarding a specific-
`before the Federal Government;
`
`party matter on which you worked;
`- entails representing others before the
`
`- represent others before a Federal
`Federal Government regarding a
`
`agency or court within two years of
`matter on which you did not participate
`
`leaving EDA regarding a specific-party
`and was not under your official
`
`
`matter that was under your official
`responsibility during your last year of
`
`responsibility during your last year of
`Federal service (unless you are a
`
`Federal service;
`senior employee and the activity is
`
`- disclose or use nonpublic information,
`listed as prohibited in the column on
`
`such as personal privacy, procurement
`the right;
`
`
`and treaty negotiation information;
`- entails representing others before the
`
`- receive payments compensation for
`Federal Government on a matter that
`
`the representational activities of others
`does not involve specific parties
`
`(such as partners) before the Federal
`(unless you are a senior employee and
`
`Government during a period you
`the activity is listed as prohibited
`
`worked for the Government; or
`below); or
`
`- for two years, accept employment with
`- entails representing the District of
`
`or perform services for a firm to which
`Columbia or, as an elected official, a
`
`EDA provided economic assistance if
`state or local government before the
`
`you worked on that assistance at EDA.
`Federal Government.
`
`(Also see the additional restrictions below if you are a senior employee, political
`appointee, procurement official, or attorney.)
`
`2015 EDA Summary of Ethics Rules – page 10
`
`

`

`
`POST-EMPLOYMENT RESTRICTIONS (continued)
`
`
`ADDITIONAL POST-EMPLOYMENT RESTRICTIONS ON ALL SENIOR EMPLOYEES
`(employees with a base pay of $158,554.50 or more)
`
`
`
`PERMITTED ACTIVITIES
`In addition to the activities listed above
`as permitted for all employees, you can:
`- represent an institution of higher
`education, a hospital, or a medical
`research organization before EDA or
`Commerce concerning a matter that is
`not a specific-party matter on which
`you worked or which was under your
`official responsibility.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`PROHIBITED ACTIVIITES
`In addition to the restrictions listed
`above that apply to all employees, if you
`are a senior employee you cannot,
`within one year after leaving Federal
`service:
`- represent others before EDA (or, for
`the Assistant Secretary, the entire
`Department of Commerce);
`- represent a foreign government before
`any branch of the U.S. Government
`(including Congress); or
`- assist or advise a foreign government
`regarding its dealings with the United
`States Government.
`(Also see the additional restrictions
`below if you are a political appointee,
`procurement official, or attorney.)
`
`
`
`
`
`
`
`ADDITIONAL POST-EMPLOYMENT RESTRICTIONS ON POLITICAL APPOINTEES
`
`
`
`PERMITTED ACTIVITIES
`
`In addition to the activities listed above
`as allowed for all employees, you can:
`- represent an institution of higher
`education, a hospital, or a medical
`research organization before EDA or
`Commerce concerning a matter that is
`not a specific-party matter on which
`you worked or which was under your
`official responsibility.
`
`PROHIBITED ACTIVITIES
`In addition to the restrictions listed
`above that apply to all employees (and
`senior employees, if applicable), if you
`are a political appointee you cannot:
`- for the remainder of the President’s
`term serve as a lobbyist before any
`political appointee in the Executive
`Branch and
`- if you are a senior employee, for two
`years represent others before EDA or,
`for the Assistant Secretary, the entire
`Department of Commerce.
`(Also see the additional restrictions
`below if you are a procurement official
`or attorney.)
`
`
`
`
`
`2015 EDA Summary of Ethics Rules – page 11
`
`

`

`
`
`POST-EMPLOYMENT RESTRICTIONS (continued)
`PO
`
`
`
`ADDITIONAL POST-EMPLOYMENT RESTRICTIONS ON PROCUREMENT
`OFFICIALS AND ATTORNEYS
`
`
`
`PERMITTED ACTIVITIES
`See the list above for what
`is permitted for all
`employees.
`
`
`
`
`PROHIBITED ACTIVITIES
`
`In addition to the restrictions listed above you cannot
`
`engage in the following activities if you are in one of
`
`the positions identified below.
`
`
`
`PROCUREMENT OFFICIALS AND
`
`
`PROGRAM MANAGERS
`
`If you are a procurement official or program manager,
`
`you cannot accept compensation from the contractor
`
`of a procurement of $10,000,000 or more within one
`
`year of working on the procurement.
`
`
`
`
`ATTORNEYS
`
`If you are a member of a bar, you cannot engage in
`
`any activities prohibited by bar rules, including in
`
`some cases providing behind-the-scenes legal
`
`
`services.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`2015 EDA Summary of Ethics Rules – page 12
`
`

`

`
`
`FINANCIAL DISCLOSURE AND ETHICS TRAINING
` Basic Principles: Tell the Whole Truth and Keep Informed
`
`Employees holding certain positions are required to disclose certain financial and
`employment interests, positions held outside the Government, the acceptance of gifts
`and travel reimbursements, and agreements regarding past or future employment.
`Disclosure reports are used by Department ethics officials to advise employees
`regarding conflicts of interest and means to avoid or resolve conflicts. The financial
`disclosure reports of the most senior officials are available to members of the public. It
`is important that information provided on financial disclosure reports be accurate.
`Employees who file such reports, as well as other employees, are required to attend
`ethics briefings, either annually or every three years.
`
`
`
`
`
`
`
`
`
`
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`
`
`
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`
`
`PROCUREMENT OFFICIALS AND
`OTHER EMPLOYEES WITH DUTIES
`THAT AFFECT THE PUBLIC
`- OGE Form 450 Filers -
`
`REPORTS: If you are a procurement
`official or have duties that could affect
`members of the public, you may be
`designated as required to file a
`confidential financial disclosure report
`(OGE Form 450); if so, you must:
`- file a new entrant OGE Form 450
`within 30 days of entering into your
`position and
`- file an annual OGE Form 450 every
`year by February 15.
`This form is available on the website of
`the Ethics Law and Programs Division –
`www.commerce.gov/ethics. Your
`human resources office can advise you
`on whether you are required to file an
`OGE Form 450.
`
`ETHICS TRAINING: You are required
`to receive ethics training:
`- by attending an ethics briefing once
`every three years and
`- by reviewing ethics materials (which
`
`are provided by the Ethics Law and
`Programs Division) during years in
`which you do not attend an ethics
`briefing.
`
`MEMBERS OF THE SENIOR
`EXECUTIVE SERVICE,
`POLITICAL APPOIN