Conflicting Financial Interests

Criminal Rule: You may not do government work on a particular matter that will affect the financial interest of:

• You
• Your spouse
• Your minor children
• Your general partner
• Organizations with which you're negotiating or have arrangements for future employment, or
• Any organization for which you serve as an employee, officer, director, trustee, or general partner

If you think you may have a conflicting financial interest, consult your DoD ethics official immediately to determine the appropriate remedy.

Bribery and Graft

Rule: You may not seek or accept anything of value, other than your salary, for being influenced in your official duties.

Commercial Dealings Between DoD Employees

Rule: You may not knowingly solicit or make solicited sales to personnel who are junior in rank, grade, or position (or their families). This includes insurance, stocks, real estate, cosmetics, household supplies, and other such goods and services.

Rule: Maintain your impartiality. Don't participate in any particular DoD matter if:

• the matter is likely to affect the financial interest of a member of your household, or a person with whom you have a "covered relationship" is involved in the matter, and
• a reasonable person with knowledge of the relevant facts could question your impartiality.

Who may be in a "covered relationship"?

• A member of your household or a relative with whom you're close,
• Someone with whom you have or seek to have a business relationship, other than a routine consumer transaction,
• An organization (other than a political party) in which you actively participate,
• Someone with whom you had, within the last year, a close business relationship, such as partnership or employment, or
• Someone with whom your spouse, parent, or dependent child has (or seeks to have) a close business relationship, such as partnership or employment.

Misuse of Position

Rule: You may not use, or permit the use of, your Government position, title, or any authority associated with your office:

• To induce or coerce another person to provide any benefit to you or anyone with whom you are affiliated
• A senior VP from Blatz Corp. recently resigned from Blatz to become a senior official in DoD. Shortly after his arrival, the official's office is tasked to decide whether or not to renew Blatz's contract with DoD. Because the senior official was employed by Blatz within the last year, he may not make the decision
• The General Counsel has been asked by his college to serve on the Alumni Association. He may serve in his personal capacity, but may not allow his position as General Counsel to be used on the college letterhead or other promotional literature.
• To imply that DoD or the Government endorses personal activities
• To endorse any product, service, or enterprise, except as provided by statute or regulation

Rule: You may raise funds for organizations in your personal capacity, but you may not use your official title, position, or authority to fundraise, nor may you solicit subordinates or prohibited sources.

Rule: You may accept payment for teaching, speaking, or writing that is unrelated to your official duties and that was not prepared on official time. If your employment by DoD is identified, you must make a disclaimer.

Rule: If you file a financial disclosure report, you need your supervisor's prior written approval before you engage in business activity or employment with a DoD "prohibited source" (see page 2). Presidential appointees and certain non-career employees have additional restrictions – consult your ethics counselor.

Rule: You may not have outside employment or activities that would materially impair your ability to perform your duties.

Seeking Employment

Rule: If you are seeking non-Federal employment (e.g., sending resumes to select employers), you may not do Government work on a particular matter that will affect the financial interests of any of your prospective employers. You must give a written disqualification statement to your supervisor.

Benefits That You May Keep

1. Frequent Flyer benefits earned on official travel such as points or miles, upgrades, or access to carrier clubs or facilities. These benefits must have been obtained under the same terms as those at no additional cost to the government. They may be used for: official travel (tickets) or upgrades (to premium class other than first class), when on official travel.
2. Benefits (including frequent flyer miles or rebates) resulting from use of personal credit card or affinity card when use of a personal credit card is authorized for such purchases.
3. Benefits given for voluntarily surrendering your airplane seat while TDY for a seat on a later flight. You may volunteer ONLY if the delay does not adversely affect your official duties and does not result in additional cost to the Government.
4. On-the-spot upgrades in transportation or accommodation, if generally available
5. Benefits such as "Gold Card Memberships and any resulting benefits.
6. Life insurance benefits offered to you by travel management contractors.

Benefits That the Government Keeps

1. Vouchers given to compensate you for being involuntarily bumped from a plane.
2. Prizes won, while TDY, in contests closed to the general public.
3. Gifts given to or won by you while TDY at a conference, hotel, or while renting a car, where you have not taken any affirmative action, including:
   • Door Prizes
   • Buy-one-get-one-free vouchers
   • Sweepstake prizes