QUARTERLY ETHICS VTC TRAINING

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QUARTERLY ETHICSVTC TRAINING

• DEPARTMENT OF THE ARMY
• OFFICE OF THE GENERAL COUNSEL
• (ETHICS FISCAL)
• www.hqda.army.mil/ogc/eandf.htm

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ETHICS FISCAL STAFF

• Mr. Matt Reres
• Deputy General Counsel
• Alternate Designated Agency Ethics Official
  (ADAEO)
• Mr. Brent Green
• Mr. Paul Hancq
• Ms. Sandy Stockel
• Mr. Christian Marrone
• LTC Beth Berrigan
• Ms. Cindy Kelson - Paralegal

ETHICS COUNSELORS
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AGENDA

• New SecArmy Initiatives
• Mr. Matt Reres
• Acquisition Ethics Training
• Ms. Sandy Stockel
• FDM
• COL Jim Quinn
• SF 278 - helpful hints
• COL Jim Quinn
• Questions

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SecArmy Initiatives

• 3 Memos April 2005
• Commitment to Ethics
• Ethics Training
• FDM Directive

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Commitment to Ethics

• Discussion of importance of federal ethics
• Directs every Soldier civilian employee to
  review
• Federal oath of office
• 5 USC 3331
• Army statutory requirement of exemplary behavior
• 10 USC 3583
• Principles of Ethical Conduct (Code of Ethics)
• E.O. 12731
• No requirement to capture and report review

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Face-to-Face Ethics Training

• Reaffirms face-to-face ethics training for ALL
  Soldiers and civilian employees
• Annual Requirement
• Continue to report numbers monthly to SOCO
• Annual acquisition ethics training
• Annual ethics training for acquisition personnel
• In addition to the annual ethics training
  discussed above
• Development of Acquisition Ethics Training Plan
  (AETP) and Acquisition Ethics Training
• OGC (EF) Ms. Stockel
• OASA (ALT)
• AR 350-1 change

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FDM

• Directive memorandum
• Directs implementation of FDM Army-wide
• Available to all SF 278 filers
• Directs development of FDM process for OGE 450
  filers

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ACQUISITION ETHICS TRAINING

• Ms. Sandy Stockel
• OGC(EF)
• [phone]

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Acquisition Ethics Training

• Training materials
• Working to identify the population for training
• Mr. Bolton ASA(ALT)
• Memorandum directing training to certain
  positions
• OGC(EF) manage program once up and running
• Report to OASA(ALT) on progress
• Command will maintain training records

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Acquisition Ethics Training

• 2005

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OVERVIEW

• Introduction
• Procurement Integrity Act (PIA)
• Bribery
• Gifts
• Allowing for Time-Off
• Traveling with Contractors
• Recommendation For Contractor Personnel
• Organizational Conflicts of Interest
• Seeking Employment
• Working for Contractors after Government
  Employment

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INTRODUCTION

• Working with Contractors in the Federal Workplace

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Why Are We Here?
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Ex-Air Force Official Gets Prison Time

• Boeing Received Special Treatment in Procurement
• By Renae Merle and Jerry Markon
• Washington Post Staff Writer
• Saturday, October 2,2004 Page A01

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Facts

• The defendant, since July 28, 2004, now
  acknowledges that she did favor the Boeing
  Company in certain negotiations as a result of
  her employment negotiations and other favors
  provided by Boeing to the defendant. Defendant
  acknowledges that Boeings employment of her
  future son-in-law and her daughter in 2000, at
  the defendants request, along with the
  defendants desire to be employed by Boeing,
  influenced her government decisions in matters
  affecting Boeing. That as a result of the loss of
  her objectivity, she took actions which harmed
  the United States to include the following

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GIFTS

• Prohibited from accepting a gift
• Because of your position (remember bribe!)
• From a prohibited source Contractor employees
  are prohibited sources
• No solicitation for retirement or other gift for
  Government employee

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YOU MAKE THE CALL!

• The support contractor for your organization
  wants to offer ALL of the Soldiers and government
  employees of the organization free tickets to the
  home opener for the Washington Nationals! The
  contractor hopes that this will further promote
  the partnership b/w the Army and the contractor
  personnel. The tickets have a face value of 25
  but the contractor paid 15/piece for the
  tickets.
• May the Soldiers and employees accept the
  tickets?

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ANSWER

• Contractor is a prohibited source - no gifts are
  permissible unless exception applies
• 20/50 rule
• No look to face value not what contractor paid
• Discount or benefit?
• No offered only to those within the
  organization
• Personal Relationship?
• No offered because of status

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Traveling with Contractors
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Can Army Contractor Employees Share
Transportation?

• It depends. There are three scenarios.
• Scenario 1 -- Army employee will perform
  official travel and contractor employee offers to
  let him or her ride along in a vehicle.
• Scenario 2 -- Army employee will perform
  personal travel and contractor employee offers to
  let him or her ride along in a vehicle.
• Scenario 3 - Army employee will perform official
  travel and offers to let contractor employee ride
  along in a vehicle paid for by the Army.

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RECOMMENDATIONS AND AWARDS FOR CONTRACTOR
PERSONNEL
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RECOMMENDATIONS FOR CONTRACTOR PERSONNEL

• Remember
• Impartiality
• Employees shall act IMPARTIALLY and not give
  preferential treatment to any private
  organization or individual
• General Principle 8
• Evaluation of performance of contractor
• Evaluation of performance is a matter handled
  within contracting channels

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YOU MAKE THE CALL!

• You are the administrative staff supervisor for
  an organization. The receptionist for your
  organization is a contractor employee. He has
  worked in support of the organization for 2 years
  and has done a terrific job. He has decided to
  pursue a college education and has asked you for
  a letter of recommendation discussing his job
  performance work ethic. He intends to include
  the letter of recommendation with his college
  application.
• Can you provide the letter of recommendation to
  the contractor employee?

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Post-Government Employment Restrictions
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Post-Government Employment Restrictions

• Representational Restrictions18 U.S.C. 207
• Prohibits representing another before U.S.
  Government with intent to influence
• Lifetime ban
• 2-year ban
• 1-year cooling-off period for senior employees
• 1-year ban on senior employees representing
  foreign entities

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QUESTIONS
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FDM - Update

• COL Jim Quinn
• SOCO

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Financial Disclosure Management

• Ongoing since August 2003
• Three stages 278, 450 and training/ management
  
• 278 tested in 2004 and rolled out to Army in 2005
• Digital signature available mid-April
• DoD and other services testing now

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FDM

• Through 9 May 2005
• 239 filers are registered in the system
• 89 filers have submitted 2005 reports
• 59 filers have drafted 2005 reports
• Filers may also be registered as supervisors
• Registrants have access to their report(s) and
  those they supervise

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QUESTIONS
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SF 278 Helpful Hints

• COL Jim Quinn
• Mr. Brian Howell
• SOCO

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SF 278 TIPS FOR FILING

• Answer all the questions
• Dont provide too much (or too little)
  information
• Add a comment if necessary
• Remember to attach job description
• Remember post-govt employ certification

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SF 278 COMMON ERRORS

• Fill in all the blanks
• none block
• amount of income
• Exact income necessary for filers outside
  employment
• Only the word salary for job of spouse
• Need city and state for real estate

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SF 278 COMMON ERRORS

• Fund name not family
• Changes in Schedule A must be accounted for in
  Schedule B
• Civilian employment?
• See also Schedule C, Part II, Schedule D, Part
  I
• No assets?
• Verify no bank account

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SF 278 COMMON ERRORS

• If rental property, then mortgage and vice versa
• Do not report TSP or other government income
• Roth or IRA alone are insufficient, as is
  brokerage accounts and 401(k)

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QUESTIONS