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ETHICS QUIZ

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					Handout ETHICS SCENARIOS

Module #204

Audience: career Federal employees (all GS levels) within the U.S. Forest Service. In every scenario, imagine this is an employee either at the Regional or Forest (SO or DO) level. 1 Remember: Always ask yourself the following questions: 1. Is this prohibited source? 2. Am I acting in my personal or official capacity? 3. Would my actions cause an actual or an appearance of a conflict of interest OR loss of impartiality? Lobbying Qs Calling your representative 2 Q: Jane is a hydrologist working in a Ranger District. She realizes that, if the National Forest within which her District exists would receive additional government funds, she will be able to conduct some innovative water monitoring studies. She decides to call her Congressional representatives to lobby for additional funding/support for the Forest Service. She calls during office hours stating that she is in a position to understand the ramifications of the failure to appropriate funds to the Forest Service. Is this okay? A: No. Jane can not use federal money, supplies, equipment, or personnel to lobby for appropriated funds. We can not lobby in our official capacity unless it is to push legislation to legislators and/or their staff to advocate the position of the agency. Q: What if Jane made the calls while she was off-duty? A: Even during her own time, Jane may not use her name/title/position to lobby for the Forest Service to obtain appropriated funds. Q: What if Jane made the calls while she was off-duty, and she refrained from using her name/title/position? Would it be okay to voice her opinion as a citizen? A: Yes, Jane may call her Congressional representatives to voice her personal opinion about political issues as this is a fundamental right of being a U.S. citizen. However, she can not use her title/position/authority or any federal resources to do so. Q: Jane still remains quite informed about political activities. This time, she realizes the mission of the Forest Service will be adversely affected should the State legislature succeed in passing a water and land use bill. She believes the best chance to protect her program is to lobby State legislators. Can she do this? A: Yes, she is acting in furtherance of the public interest. Moreover, she is not unlawfully lobbying (this is not before the U.S. Congress) or representing (this is not before a Federal official or agency). The answer is, yes, she can do it. Campaigning for a friend/family 3

Many of the questions are a modified version of questions from USDA ethics training; the modifications are an effort to make the scenarios more applicable to Forest Service employees. The citation to the USDA ethics training is noted where applicable. 2 See http://www.usda-ethics.net/training/index.htm “Political Activity.” 3 See http://www.usda-ethics.net/training/index.htm “Political Activity.”

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Q: Nico, a civil engineer working in a Forest Supervisor’s Office, is excited that his friend is running for the State legislature. He has been writing speeches for his friends and attending fundraisers off-duty using his own resources. May he continue to write speeches and attend fundraisers for his friend? A: Yes, he may volunteer for campaign activities such as writing or giving speeches during his off-duty time. The Hatch Act (5 U.S.C. 7823(a)) provides the parameters for federal employees’ political activities. Most volunteer activities are permissible, except for soliciting contributions. Q: Nico is so excited about his friend’s potential position that he would like to wear his friend’s political badge all day. May he wear the badge? A: Nico can not wear the political badge in the office. Nico may not engage in any campaign activity on government premises including wearing buttons and/or distributing campaign materials. Q: Nico, still politically active, would like to work as events organizer on the campaign staff of a controversial Congressional candidate. Can he do this? A: Yup, he may be a voluntary events organizer. He may volunteer for any campaign activity except soliciting contributions. Organizing these activities may even include writing or giving speeches. He may also be employed by the committee for pay, but in either case he cannot perform this work on duty time. Q: Nico’s wife decides to run for local office in a partisan election. She wants to hold a fundraiser. Can Nico attend the fundraiser? A: Yes, he may attend with a few caveats. The function may be held at his home and he may attend. His name or title may not be used on the invitations. Further, he may at no time accept donations on his wife's behalf but, instead, he may direct donors to other campaign workers.

Fundraising Qs High school fundraiser 4 Q: Svetlana is a botanist working in a Ranger District who works and lives in a small town. She chairs a fundraising drive for the local high school on her personal time. She signs a letter seeking donations. Five hundred copies of the letters are mailed to the local citizens and businesses in the town. The letter makes no mention of her official title or position, but one of her FS subordinates and one prohibited source, JT Timber, Inc., receives copies. Is she is trouble? A: Nope! Unless an unusually high percentage of mailings are received by prohibited sources (e.g. JT Timber, Inc.) or subordinates, then a mailing of this size would not normally be considered “personally soliciting.” However, if Svetlana was a line-officer or District Ranger, because of her visible position in a small town, she might be more prudent about who authors the letter. Time for Girl Scout cookies! 5 Q: Andrea is an economist in the Regional Office. Her daughter is in Girl Scouts. She calculated the amount of money her daughter could earn if Andrea sold a hundred boxes at work. The numbers looked promising! Andrea would like to place a pile of cookie boxes on her desk with a little sign saying “My daughter is a Girl Scout—cookies here!” She’d like to also send an email out to co-workers announcing the presence of delicious cookies around the office! Can she do this?

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See http://www.usda-ethics.net/training/index.htm “New Employee Introduction.” See http://www.usda-ethics.net/training/index.htm “Fundraising.”

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A: It feels pretty mean to deny Girl Scouts, but you must in this situation. Andrea can not personally solicit from her co-workers any amount of money albeit for Girl Scout cookies under 5 CFR 2635.203, Subpart H. Now, if her co-workers were to approach her without her solicitation, she could sell the cookies off-duty outside of the office, but she can not solicit or promote the sale of the cookies at her desk. Only OPM would be able to approve such fundraising and, unless it’s for disaster relief, that is unlikely. Giving a speech at fundraising events 6 Personal Capacity Q: Jackson, the soil specialist in a Ranger District, would like to attend a fundraising event for the Soil Scientists of the America Association (SSAA) on Saturday afternoon. As a member of SSAA, the fundraiser staff has offered to waive his fee for dinner and allocate 10 minutes for him to speak at the event. Is this acceptable? A: Jackson may speak at the event in his personal capacity so long as he does not promote or produce the event (e.g. sitting at the head of the table, stand in the reception line, or serve as an honorary chairperson). Also, he may accept the waiver of the fee so long as he is not working on Saturday afternoon. He can not use his title/position to endorse SSAA under 5 CFR 2635 in the promotion materials (invitation) or during his speech. Official Capacity Q: Carlo, the Volunteer Program coordinator for the Regional Office, received an invitation to speak at an annual awards and fundraising dinner to be attended by more than 400 businesses, political and nonprofit leaders. Carlo will speak on policy issues related to the Region’s volunteer programs. His supervisor approved of this speech. Awards will be presented to certain individuals for their efforts to promote volunteerism in America. Most of the proceeds raised from the dinner will be donated to a Montana state-wide initiative on volunteers. The cost of attending the dinner was waived for Carlo. May he attend? A: Yes, Carlo may attend and communicate Department policy at the event but he should proceed with caution. Employees assigned to present information on behalf of the Agency at a conference or other event may accept free attendance regardless of the number of attendees or diversity of views presented. In his official capacity, Carlo may NOT participate in fundraising activities (unless it is CFC). This means he needs to be cautious. He can not permit the use of his official title or position to promote the cause. He can not solicit funds or endorse the fundraising in any way while he gives an official speech on Forest Service volunteer programs. Participation with outside organizations General membership Q: Jose, a wilderness specialist in the Regional Office, would like to become a member of the Environmental Awareness Organization (EAO). EAO has national and regional chapters. EAO has been a party to lawsuits against the Forest Service in the past. EAO is a prohibited source. May Jose become a member of EAO? A: That depends. He may, in his personal capacity, become a member by giving money and/or supporting the organization. However, he can not use his title/position with the Forest Service to promote EAO. Nor can Jose accept active participant, leadership or fiduciary positions with EAO.

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See http://www.usda-ethics.net/training/index.htm “Fundraising.”

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Q: Sera, a fuels supervisor in a Ranger District, would like to become a member of an organization that support Logging on Public Lands (LOPL). OLPL has national and regional chapters. LOPL is a prohibited source. May Sera become a member of LOPL? A: Same as above, it depends. She may, in her personal capacity, become a member by giving money and/or supporting the organization. However, she can not use her title/position with the Forest Service to promote LOPL. Nor can Sera accept active participant, leadership or fiduciary positions with LOPL. Leadership positions – personal capacity 7 Q: Maria, a smokejumper for the Regional Office, would like to become a member for the Society of Cancer Survivors. As a cancer survivor, she would like to be spokesperson for their regional chapter. Would this be permissible? A: Yes, in her personal capacity (own time using own resources) Maria may assume leadership roles for the Society of Cancer Survivors since it is not a prohibited source. However, Maria can not use her title/position to promote the Society. Q: Darlene is the Grants and Agreements Coordinator in the Regional Office. She also is on the board of directors of a physical fitness advocacy group (FITYES) in her personal capacity. FITYES wants to seek a grant from U.S. Department of Health and Human Services (US HHS) to study obesity in America. At the Director’s meeting, she casts a vote to seek a grant from US HHS. Is this okay? A: Yes, this is acceptable as in her personal capacity she may vote to seek the grant. Q: What if Darlene discusses the proposal with her Supervisor and asks if he would call the head of the U.S. HSS and “put in a good word” about the grant application? A: No, this would be an unethical representation, even though to an official who has no direct involvement in the official action. Q: Given her experience as Grants & Agreements Coordinator, FITYES asks Darlene to write a grant application for them to U.S. Department of Health and Human Services. May Darlene write this grant? A: Yes, in her personal capacity it would not be a violation of 18 U.S.C. §203. Q: Assume that FITYES seeks to do business with the USDA Forest Service by partnering and sharing funds for fitness projects across the region. This will make FITYES a prohibited source. Should Darlene remain on its Board of Directors? A: No, she should not. Since FITYES is a prohibited source, even in her personal capacity, Darlene’s position on the Board of Directors will cause an actual or apparent loss of impartiality for the Forest Service. Darlene should speak with her supervisor about obtaining approval to become a liaison or technical advisor to FITYES in her official capacity. Leadership positions – official capacity 8 Q: Let’s assume that Darlene’s supervisor approves of her official involvement as a liaison with the FITYES as part of a partnership between Region One and the organization to promote private involvement in physical fitness research. The organization is still considering seeking a grant from another Federal agency. Q: Can she meet with her Supervisor to discuss the grant proposal because he knows the other agency head involved?

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See http://www.usda-ethics.net/training/index.htm “Participation in Outside Organizations.” See http://www.usda-ethics.net/training/index.htm “Participation in Outside Organizations.”

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A1: Yes, she is assigned to participate officially and it would be within her official duties to keep her supervisor informed as well as to influence other Federal officials in order accomplish agency goals. Q: Can she be paid by the organization to write the grant application? A: No, she cannot be paid because it is part of her official duties to work with the organization. She already is paid by the Federal Government for her work. Under 18 U.S.C. 209, she may not accept dual compensation from a non-Federal source for that work. Q: The organization wants to push legislation currently before Congress. Darlene supports the legislation, but her agency does not. She writes her senator, advocating the passage of the bill. The letter does not refer to her official position and avoids references that would undercut her agency’s position. Is this okay? A: Yes, it’s okay. Despite her official position, Darlene still retains her right to communicate with her representatives in Congress. Leadership positions – Friends Groups/Partners Q: Janice, a public affairs specialist with a Ranger District within the Zebra National Forest, has been asked to serve on the Board of Directors for the Friends of the Zebra National Forest. Her expertise as a public affairs specialist and understanding of Forest Service needs would really help the Board. She would like to accept this position in her personal capacity. May she do so? A: No, because we a dealing with a friends group, there is a conflict of interest with the Forest Service as her participation may cause an appearance of the loss of impartiality for the Forest Service. Q: Janice she would still like to participate on the Board in her personal capacity but, in an effort to avoid ethical issues, she told the organization she could not be a voting member of the Board. Is this okay now? A: No, same rational for above. Q: Janice asked her supervisor to allow her to participate in her official capacity with the Friends group as a liaison/advisor where she would provide technical or professional advice only. She would serve as a fiduciary (managerial/administrative roles) or as an active participant (spokesperson, chair, etc.) Now is this okay? A: So long as Janice’s supervisor approves her participation as liaison/advisor, then she may participate in her official capacity with the friends group. She would still have to be cautious not to cause an appearance of the loss of impartiality for the Forest Service. Attending Conferences – personal capacity 9 Q: Bill is an Interpretative Specialist with the Regional Office. In his personal capacity, he serves as Committee Chair for the American Society of Interpreters (ASI). ASI is paying to send him to the annual 3-day ASI conference for training. During the conference, ASV will convene committee meetings. May Bill participate in these meetings committee chair if he takes leave? A: Yes, he may take annual or administrative leave, or excused absence to participate. He must be sure to keep his outside activities separate & distinct from his official duties. He must not misrepresent himself in either capacity.

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See http://www.usda-ethics.net/training/index.htm “Participation in Outside Organizations.”

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Q: Bill is elected Treasurer and his first task is to conduct a fundraising campaign. Bill knows that his agency supports the goals of the organization. Can he meet with agency senior personnel at work to solicit their monetary support? A: No!! This would be a representation prohibited under 18 U.S.C. 205. Moreover, under 5 CFR Part 950, fundraising at the workplace generally is limited to the Combined Federal Campaign. Q: At an ASI internal meeting, Bill’s committee drafts a position critical of an APHIS policy. Returning to work, Bill’s boss asks for his advice on revising the policy. Can he give his advice? A: No! Since Bill is both an ASI officer and "active" member, giving this advice may violate 18 U.S.C. 208 and result in a loss of impartiality. Attending a conference – official capacity 10 Q: Christopher, a forester working in a Ranger District, attended the annual meeting of a Forestry lobbying organization. The event was a private conference, which was not open to the public. Forest Service paid for the entrance fee and Christopher attended on official time. As part of the event, there was a door prize drawing from the names of all paid attendees. Christopher, with a stroke of luck, won the prize! Woo hoo! Wait, can he keep the $1,500 Bonsai tree? A: Sorry Christopher, you cannot keep the tree. Since the drawing was automatic for each attendee, the employee was required to be a participant in the drawing as part of his official duties. Unless participation is optional, the employee may not accept the prize. Also, the drawing must be open to the public, and this drawing was not open to the public. Only the persons in attendance who had paid the fees for attending were eligible for the prize. Q: Christopher is assigned to participate on a panel at the American Forestry Association (AFA) Conference. AFA is a prohibited source. The fee to attend in $200, but AFA offers to waive the fee and also offers Christopher a nominal ($15), non-monetary plaque for participating. May Christopher attend and accept the waiver and plaque? A: Yes, since his supervisor directed/approved of him participating as a panelist, Christopher is serving on behalf of the Forest Service. He may accept the free attendance from the AFA for the day of his participation as this is a customary part of performing duties, not a gift. He may also accept the plaque because it is a gift worth less than $20. Giving a speech 11 Q: Harry, a GS-12, Forest Service botanist, has been an out-spoken critic of agency policy on logging. He has been invited by the Mountain Club, an environmental interest group, to speak on matters related to the effect of logging road development on the forest environment (part of his official duties). The Club offers to pay his travel costs and pay him a $200 honorarium for his speech. His managers don't want him to do it. He seeks your advice on whether he can accept the travel costs and the honorarium. Your answer is: A: He can accept the travel expenses, but not the honorarium. Since the subject of the talk is related directly to Harry's official duties, he could not accept the honorarium. To do so would violate 18 U.S.C. 209, as well as the TSW rules. However, under the ruling in the Sanjour case, he could accept payment of travel costs from the Club for making the speech.

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See http://www.usda-ethics.net/training/index.htm “New Employee Introduction.” See http://www.usda-ethics.net/training/index.htm “Teaching, Speaking, Writing.”

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Invitations 12 Q: Steve, an engineer in a Ranger District, reviews computer systems for the coordination of management services over the Internet. He just received an invitation from the CEO of a major corporation to attend an intimate dinner at the nicest restaurant in town to informally share thoughts about the company’s customer service applications. Spouses/guests are invited. A: No, Steve and his spouse should not attend. If the event had been attended by (1) a large group of individuals with a diversity of views or; (2) presented in a more conservative setting such as an open house and buffet, then Steve could have attended without violation gift prohibitions. Remember, even though acceptance may be permissible by regulation, it’s never inappropriate and frequently wise to decline a gift offered by a prohibited source or to decline one considered extravagant. Bona fide awards 13 Q: Allison, a leading research soil scientist, received notice that she was selected to receive a $25,000 cash award from a foundation in recognition of her research contributions in soil fertility. The foundation has no interests that may be substantially affected by the performance or nonperformance of Allison’s official duties. The award is to be presented at a gala dinner held in her honor. Her immediate family is invited to attend and airline tickets for Allison and her family are provided. A: Allison may accept full honors including family attendance. Employees may accept gifts of bona fide awards, including cash, when they are given for meritorious public service or achievement by a person/entity that doesn’t have interests that may be substantially affected by the employee’s performance or non-performance of official duties. Awards of cash, investment interests and other gifts with an aggregate market value in excess of $200 may be accepted after receiving a written determination from an ethics official that the award is made as part of an established program of recognition. Further, as Allison may accept an award under this regulation, she may also accept meals, entertainment, and transportation to the award site for both her and her family. Tokens of appreciation 14 Q: Ashlyn, a partnership coordinator on a National Forest, coordinates multiple projects with an array of individuals and organizations in the community. After months of working on a single partnership project, she successfully organized an “Artists in the Woods” weekend. Ashlyn receives a thank you note from a local artist and a $100 gift certificate to a local department store. What should Ashlyn do? A: Ashlyn must return the gift certificate with a note explaining that she was just doing her job. This unsolicited gift is governed by three prohibitions: • it exceeds the $20 limit • it gives the appearance of a loss of impartiality or perception of favoritism because it is tied to a specific act • it is an illegal supplement to her salary (she can’t be paid both by the Forest Service and by an outside source for performance of her duties) Q: Janet works as a recreation specialist. She will spend an entire day in meetings with an OHV organization that is intending to use a campground for a weekend. They will iron out problems in a special recreation use permit. At 5 p.m., the entire group is scheduled to move their discussion to a local restaurant. One of the OHV organization’s reps intends to pay their dinner bill. What should Janet do?

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See http://www.usda-ethics.net/training/index.htm “Invitation from Outside Entities.” See http://www.usda-ethics.net/training/index.htm “Invitation from Outside Entities.” 14 See http://www.usda-ethics.net/training/index.htm “Gifts from Outside Sources.”

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A: Janet should pay for her own meal. Even if her portion of the meal is below the $20 limit, she should not accept it because it gives the appearance of favoritism or loss o impartiality. If her attempt to pay for her portion is refused and/or creates an embarrassing situation at the dinner table, she could wait until the next day. At that time, she should just send a check with a note explaining that it is against regulations to accept such gifts when they create conflicts of interest or an environment of favoritism or loss of impartiality. Important here is the fact that she is negotiating at the time of the meal. If this were a lunch meeting to discuss project performance, the $20 rule would probably apply. There would not be the same appearance problem. Q: Rhonda is an interpretative specialist at the Regional Office. She was a guest speaker at the National Interpretation & Education Association’s annual conference. As a token of appreciation, Rhonda is given a book valued at $15 and a pen valued at $20. What should she do? A: Rhonda may accept one gift, but not both because the total value of the gifts may not exceed $20. If she wants to keep the second gift, she may do so by personally paying its fair market value.

Outside Compensation Can I even hold a job outside of the government? 15 Q: Since you are working for the Federal Government, can I even seek work for any company outside the Government. A: Yes, you may hold a second job with another company while working for the Federal Government. However, it must not put you in a conflict of interest situation or create the appearance of a loss of impartiality or favoritism with your Federal job. Professor or Forest Service employee or both Q: Florence is a Forest Service research scientist collocated at State University (SU) under a Master Agreement with SU to conduct research science. SU pays her to teach a course not related to her official duties in her personal time. Is this okay? A: Since compensation from SU is unrelated to Florence’s official duties, there is no dual compensation issue. She may teach a course off-duty for SU. Q: Florence’s Forest Service supervisor asks her to serve on a university doctoral review panel in her official capacity. Three of her students are up for PhDs. Can she serve? A: No, she may not serve. Florence is a paid SU employee. Her service on the panel would require her to take official action on matters involving the interests of SU—her outside employer. This is a conflicting financial interest. Q: Florence’s supervisor asked her to review a few research grant proposals from State University (SU) and University of State (US) to conduct research on forestry techniques. Should Florence review the grant proposals? A: No, she should not review the grant proposals. Florence is a paid SU employee. Her review of the grant proposals is a conflict of interest. Plus, her review may cause an actual or apparent loss of impartiality. Teaching gigs 16
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See http://www.usda-ethics.net/training/index.htm “Seeking Non-Federal Employment.” See http://www.usda-ethics.net/training/index.htm “Teaching, Speaking, Writing.”

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Q: Zakiya is an Interpretative/Conservation Education specialist with a Ranger District. The National Society for Interpretation (NSI) invited Zakiya to provide a 4-hour presentation on tips for successful interpretative programs that will take place during their annual conference. They will pay her travel expenses to the conference. They will waive the attendance fee for the conference. They will compensate her $1,000 for her teaching services. If Zakiya takes annual leave to attend and speak at the conference, will she be in violation of any ethical rules or regulations? A: Yes. Even if Zakiya is operating in her personal capacity, she can not receive compensation for activities “closely related” to her official duty. Receiving $1,000 for a presentation related to her official duty is not acceptable per 5 CFR 2635.807. Payment to whom – official travel 17 Q: You have received an offer from a non-Federal source to pay your travel expenses to a meeting. You will participate in your official capacity as you have diligently contacted your Forest Supervisor who found no conflict-of-interest. Now, the non-Federal source tells you that it is unwilling to write a check to the Forest Service. Instead, it will simply provide you a cash payment when you arrive at the place of meeting. Is this okay? A: Nope! The regulation does not authorize you to accept cash from the non-Federal source. Payment from a non-Federal source for official travel, other than payment in kind, must be by check or similar instrument. Conflict of Interest Analysis for COI questions… always ask yourself the: 1. Identity of the non-Federal source; 2. Purpose of the meeting or similar function; 3. Identity of other expected participants; 4. Nature and sensitivity of any matter pending at the Department affecting the interests of the non-Federal source; 5. Significance of the employee’s role in any such matter; and 6. Monetary value and character of the travel benefits offered by the non-Federal source. Awarding contracts Q: Bridget works in the procurement office within the Regional Office. Three companies submitted bids on a significant contract for facility maintenance work in one of the National Forests. While reviewing the contracts, Bridget noticed that she owns a significant amount of stock in one of the companies. Should she continue to review the contracts? A: No, because Bridget clearly has a financial interest in one of the companies. Her financial interest created a conflict of interest such that she should not participate personally or substantially on matters that could directly and predictably affect that company. Violation of this statute could result in criminal charges under 18 U.S.C. § 208(a). Yikes! Q: What if Bridget’s father owned the stock in one of the companies, and not Bridget? Would she be able to review the bids? A: No again, because a sibling relationship qualifies as a ‘close’ family relationship. There would be an actual or apparent loss of impartiality if Bridget reviewed the bids.

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See http://www.usda-ethics.net/training/index.htm “Acceptance of Payments.” GSA published the rules at 41 C.F.R. Part 304-1.

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Using your position/title Q: An OGC attorney tries to get his superiors to drop a case brought by the Government against his fiancé. A: Assuming the fiancé does not live in the same house, this would be an actual misuse of position or title (favoritism). If his fiancé lived in the same house, then this would be an actual loss of impartiality. Either way, the OGC attorney is not within ethical parameters! Office equipment for personal use Q: Horace and Susan fell in love while drafting air quality regulations for the Forest Service. They are super excited about their upcoming wedding. As you may know, weddings are quite costly. One cost they could avoid is wedding invitation if they buy only one invitation and fax a copy to each of the 50 people in the local area whom they plan on inviting. Horace and Susan ask you, line-officer, for permission to fax the invitation from the fax machine in accordance with the new policy on acceptable use of office equipment. What should you say? A: It’s tough to be the wedding Grinch, but you should say no. Sending 50 separate faxes or even one fax to 50 recipients is excessive. The rule is that personal use should be “limited.”

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