Ethics_4_HR

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Ethics Training for NRCS Liaisons
Fundraising
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Ethics Training for NRCS LiaisonsFundraising
FUNDRAISING USDA employees can and do engage in
fundraising activities. This module reviews
the dos and donts of fundraising, both on and
off the job.
First, some definitions so we will all be clear
what is meant
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Ethics Training for NRCS LiaisonsFundraising

• Fundraising, for our purposes here, is basically
  
• Raising funds for a nonprofit organization, other
  than a political organization through
• the solicitation of funds or sale of items, or
• employee official participation in the conduct of
  an event where any portion of the cost of
  attendance or participation may be taken as a
  charitable tax deduction by a person incurring
  that cost.

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Ethics Training for NRCS LiaisonsFundraising

• Active and visible participation in the
  promotion, production, or presentation of the
  event includes
• serving as honorary chairperson
• sitting at the head table and
• standing in a reception line.
• It does not necessarily include
• mere attendance provided the employees
  attendance is not used to promote the event.
• giving an official speech at a non-profit
  fundraiser.

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Ethics Training for NRCS LiaisonsFundraising

• Active and visible participation in the
  promotion, production, or presentation of the
  event
• does not include
• A Non-Monetary Charity Drive in which
  solicitation for the drive is limited to the
  pursuit of in-kind items
• toys,
• clothing,
• food, or
• household items.

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Ethics Training for NRCS LiaisonsFundraising

• Prohibited Source means
• Any person, company, or organization that
• Is seeking official action from USDA.
• Has or seeks to do business with USDA.
• Conducts operations regulated by USDA.
• Seeks to influence USDAs policies or
  regulations.
• Has interests that may be affected by your
  official duties.
• Is an organization, a majority of whose members
  are prohibited sources.

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Ethics Training for NRCS LiaisonsFundraising
Proscribed Political Fundraising is Soliciting,
accepting or receiving a campaign contribution
for partisan political purposes from any person
or organization. There is a narrow exception
for union members to solicit other union members
for the Union Political Action Committee (PAC)
provided the persons solicited are not
subordinates.
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Ethics Training for NRCS LiaisonsFundraising
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Ethics Training for NRCS LiaisonsFundraising
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Ethics Training for NRCS LiaisonsFundraising
Official Fundraising
You may not engage in official fundraising
outside the... Combined Federal Campaign
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Ethics Training for NRCS LiaisonsFundraising
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Ethics Training for NRCS LiaisonsFundraising
Official Fundraising - Authorized Exclusions
But there are three caveats
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Ethics Training for NRCS LiaisonsFundraising

• Official Fundraising (cont.)
• But there are three caveats
• Only seek funds from employees. Never solicit
  non-Federal entities.
• Respect employees right to decline to
  participate.
• Dont hold a fundraiser during the Fall (CFC is
  underway)

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Ethics Training for NRCS LiaisonsFundraising

• Official Speeches at Non-Profit Fundraisers
• An employee may be approved to present an
  official speech at a non-profit fundraising event
  on a subject related to official duties.
• It is okay provided
• The event is determined to be an appropriate
  forum for the dissemination of the information
  presented and as long as the employee doesnt
  request donations or other support for the
  organization.
• The event sponsor does not use the employees
  attendance as a draw or to imply official
  endorsement of the organization. The employees
  name and title should not be on the invitation to
  the event, but it is okay to list the employee as
  a speaker on the program handed out at the event.
  

Contact your servicing ethics advisor prior to
accepting the invitation.
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Ethics Training for NRCS LiaisonsFundraising
End of Summary on Official Fundraising
Now on to we can do in our personal capacity!
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Ethics Training for NRCS LiaisonsFundraising
Personal Fundraising
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Ethics Training for NRCS LiaisonsFundraising
Personal Fundraising and Special Government
Employees

• A Special Note

SGEs may fundraise as may any other private
citizen (for any political or charitable cause)
when not fulfilling your part-time Federal
responsibilities, provided you do not solicit
persons who have an interest in what you do when
you are wearing your Federal hat.
SGEs are employees on temporary appointments of
no more than 130 days during any 365-day period.
SGEs are often appointed to work for USDA as
Collaborators, Experts, and Panel Members have
more freedom to fundraise.
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Ethics Training for NRCS LiaisonsFundraising
Fundraising for Gifts Between Employees
For more info, see the training module, on Gifts
Between Employees! on the USDA Ethics Website.
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Ethics Training for NRCS LiaisonsFundraising
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Ethics Training for NRCS LiaisonsFundraising

• Non-Monetary Charity Drives (Cont.)
• With management approval, you can set up
  collection boxes in the public part of a Federal
  building as long as you dont
• Involve the exchange of money
• Disrupt the workplace
• Aggressively pursue donations from your fellow
  employees
• Abuse the guidelines set out in the Standards of
  Ethical conduct at Subpart G Misuse of Position

Before setting out a box, talk to the building
manager and make sure you understand all
applicable GSA and agency regulations.
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Ethics Training for NRCS LiaisonsFundraising
A Quick Word About Political Fundraising
Dont.
No Federal employee may solicit, accept, or
receive political contributions in either his or
her official or unofficial capacity except under
the narrow exception for Federal workers unions
mentioned earlier.
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Ethics Training for NRCS LiaisonsFundraising
Lets See What We Learned -- Scenario One
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Ethics Training for NRCS LiaisonsFundraising
As his supervisor, how do you respond?
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Ethics Training for NRCS LiaisonsFundraising
As his supervisor, how do you respond?
A is wrong. Although Jimmy is free to engage in
this fundraiser on his own time, thats not the
case while on the job. Remember, the CFC is the
only authorized fundraiser in the Federal
workplace. If he were to obtain prior approval
from OPM through his personnel office, he could
proceed.
B is correct! You refuse his request explaining
that the CFC was established as the sole
fundraising event in the workplace. You could
also advise him that OPM does consider requests
for official fundraising outside the yearly
campaign. If he were to obtain prior approval
from OPM through HRMD, he could proceed.
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Ethics Training for NRCS LiaisonsFundraising
Lets See What We Learned -- Scenario Two
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Ethics Training for NRCS LiaisonsFundraising

• Is the Chiefs Approval all that is required to
  carry out this event?

A. Yes B. No
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Ethics Training for NRCS LiaisonsFundraising

• Is the Chiefs Approval all that is required to
  carry out this event?

A. Yes B. No
A is wrong. While approval for the collection of
in-kind donations for disaster relief is
appropriately pursued at the Secretarys or
concerned Agency Heads level, only OPM may
approve the collection of funds.
B is correct. The authority to provide in-kind
assistance for disaster relief is delegated to
the Secretary and concerned Agency Heads.
However, official fundraising outside the CFC
requires prior approval from OPM.
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Ethics Training for NRCS LiaisonsFundraising
Lets See What We Learned -- Scenario Three
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Ethics Training for NRCS LiaisonsFundraising
Do you approve or disapprove of the activity?

• Approve.
• Approve, with certain restrictions.
• Disapprove.

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Ethics Training for NRCS LiaisonsFundraising
Do you approve or disapprove of the activity?

• A. Approve.
• Wrong. Yes, he may attend in his official
  capacity and present on matters related to his
  official duties. However, to do so he must obtain
  the agencys determination that the event
  provides an appropriate forum for his
  presentation. Brian must also avoid requesting
  donations, serving as honorary chairperson,
  sitting at a head table during the event, and
  standing in a reception line. If his attendance
  is approved, the ethics office may also approve
  his spouse to attend under the gift exclusion for
  widely attended gatherings.
• B. Approve, with certain restrictions.
• Correct.
• Disapprove.
• Wrong. Too conservative.

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Ethics Training for NRCS LiaisonsFundraising
Lets See What We Learned Scenario Four
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Ethics Training for NRCS LiaisonsFundraising
Lets See What We Learned Scenario Four

• Would your action comply with ethics regulations?
• Yes
• No.

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Ethics Training for NRCS LiaisonsFundraising
Lets See What We Learned Scenario Four

• Would your action comply with ethics regulations?
• Yes
• Wrong. Even on your own time using your own
  resources, your personal solicitation of
  prohibited sources is not authorized. Leave the
  personal solicitation of prohibited sources to a
  church member who isnt a USDA employee. Or,
  limit your solicitations to those businesses
  excluded from the definition of a prohibited
  source.
• No.
• Correct. You must avoid personally soliciting
  anything from a prohibited source

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Ethics Training for NRCS LiaisonsFundraising
Lets See What We Learned Scenario Four
Lets try a different angle. Suppose you belong
to a recognized employee organization established
to benefit USDA employees.

• Can you solicit prohibited sources in this
  instance?
• Yes.
• No.

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Ethics Training for NRCS LiaisonsFundraising
Lets See What We Learned Scenario Four
If you belong to a recognized employee
organization established to benefit USDA
employees, can you solicit a prohibited source?
A. Yes. Wrong. As Federal employees we may not
solicit prohibited sources, period B. No.
Correct.
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Guidance Regarding Liaisons
Questions?