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					                     Ethics for Supervisors
           (Outline of Training Course for Supervisors)

I. INTRODUCTION
    A. Course Goal: To assist Federal supervisors to understand their responsibilities to foster
an ethical workplace. There are two elements of this training that parallel the dual roles of
supervisors:

       1.       Personal Compliance: To understand the requirements, duties, and
responsibilities that apply to them as Government employees and as supervisors in personally
implementing and adhering to Federal ethics rules and policies.

       2.      Setting the Ethical Tone: To understand the special leadership role that they have
as supervisors and leaders to model ethical behavior and to set the ethical tone in the workplace.
This includes:

           a. Setting the right example by taking the appropriate action;

           b. Keeping promises and commitments; and

           c. Responding appropriately to subordinates’ ethics concerns.

    B. Premise: By deed and word, the supervisor establishes the ethical tone for the workplace,
as employees frequently adjust their own standards to reflect those of their supervisor. If a
supervisor understands and complies with ethics laws and regulations so too will most of the
subordinates. In addition, the actions (or inactions) of the supervisor substantially affect the
willingness of employees to ask questions about possible ethics concerns or to report apparent
ethics violations.

       1. It is vital that managers recognize that the ethics program is “their” program. The
primary responsibility for this critical program does not “belong to the lawyers.” Absent a firm
management commitment to its success, an agency’s ethics program is likely to ultimately fail –
and absent a strong ethics program a manager’s career is likely to do the same!

        2. Survey data (from National Business Ethics Survey, Office of Government Ethics,
Department of Defense (DoD), and others) indicate that the supervisor plays a singular role in
establishing an ethical workplace. Employees “read” their supervisors to determine if the
supervisors:

           a. tolerate misuse of their positions;



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           b. accord some individuals preferential treatment over others;

           c. abuse authority;

           d. permit the waste or misuse of Government assets;

           e. practice or tolerate dishonesty in the workplace; or

           f. tolerate shady or unethical business practices.

        3. In addition to the general role that supervisors have in setting the overall ethical
environment for their workplace, supervisors also have specific ethics-related duties and
responsibilities that are part of their agency ethics program. For example, in the Standards of
Ethical Conduct for Employees of the Executive Branch (5 CFR Part 2635), “agency designees”
(in many agencies these are the supervisors) are responsible for making many decisions
involving their subordinates, including decisions on financial reporting, recusal, and gift
acceptance. The manner in which supervisors meet these specific responsibilities will also
directly affect the ethical tone of the workplace.

    C. Background: When we talk about “ethics” in this context we are referring to those
actions that we as public servants take to promote the confidence of the public in the integrity of
Federal decision-making. The Government’s ethics program contains both a “compliance”
element – written laws and regulations with which we must comply – and a “values” element –
the ethical tone that guides attitudes and behaviors of those in the workplace.

       1. The ethics rules with which the Federal employee is expected to comply include:

            a. The conflict of interest laws (18 U.S.C. 201-209). Criminal statutes that prohibit
bribery, graft and conflicts of interest by public officials. They also contain the primary post-
employment restrictions for former Federal officials;

           b. The Standards of Ethical Conduct for Employees of the Executive Branch (5
C.F.R. Part 2635). Comprehensive, Government-wide ethics regulations promulgated by the
Office of Government Ethics (OGE) for employees of Executive branch and independent
agencies;

          c. Supplemental standards of ethical conduct for employees of certain agencies (5
C.F.R. 3101 – 8701). Agency-specific regulations promulgated in consultation with OGE that
supplement the Government-wide regulations, above;

           e. Miscellaneous related bodies of laws or regulations, including the Hatch Act (5
U.S.C. 7321-7326, as implemented at 5 C.F.R. 733-734), Federal Travel Regulations (41 C.F.R.
300-304), CFC fundraising regulations (5 C.F.R. 950), and the OPM regulations on employee
responsibilities and conduct (5 C.F.R. 735).


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       2. Measures to ensure the integrity of decision-making are not unique to the Federal
Government. Businesses, professional associations, universities, not-for-profit organizations,
and other governments have implemented similar measures. For example:

           a. Defense Industry Initiative: (www.DII.org) DII is a consortium of U.S. defense
industry contractors which subscribes to a set of principles for achieving high standards of
business ethics and conduct.

          b. One example of a corporate ethics program is that of General Electric Company:
http://www.ge.com/en/citizenship/compliance/spirit/conflicts.htm

         3. However, the importance of public sector ethics is heightened by our responsibilities
as civil servants to safeguard the public trust. Scrutiny of agency compliance by Inspectors
General, Congress, media, and public interest groups also increases the focus on the public
sector. Recent examples of ethical issues arising in Federal agencies that were the subject of
intense media coverage include:

           a. U.S. Air Force - Boeing contractual issues involving employment of a former
senior Air Force procurement official, who admitted awarding contracts to Boeing because
Boeing had hired the Air Force official’s daughter. This case resulted in the ultimate
imprisonment of the former senior Air Force official.

             b. Outside employment of NIH personnel by companies that seek NIH approvals.

             c. Improper official travel by a senior HHS official.

             d. Illegal acceptance of gifts from lobbyists by Interior Department and GSA
officials.

        4. Empirical Data: Surveys indicate the powerful role supervisors play in shaping
employee behavior. A 2005 survey of senior officials and procurement personnel in DoD
indicated:

          a. 80% would seek ethics advice from their direct supervisor (interestingly, only 75%
would seek ethics advice from an ethics official).

           b. 69% indicated they would report an ethics violation if they observed one. 14%
said they would not report a violation.

            c. Of those personnel who had reported an ethics violation in the past, only 18%
indicated they were satisfied with the action taken. 40% indicated they were dissatisfied with the
agency’s action.

            d. 46% believed that senior personnel in DoD are held accountable if they are caught
for an ethics violation. 21% disagreed.

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         e. 67% indicated that they thought that their coworkers consider ethical issues when
making work-related decisions. Only 6% disagreed.

            f. 4% believed that their supervisors reward personnel who get good results, even if
they violate the Standards of Conduct. 69% disagreed.

II. PERSONAL COMPLIANCE
   A. Individual behavior as a Federal employee.

       1. Know the ethics rules that apply to you personally

       2. Walk the Walk – Don’t just Talk the Talk

   [Optional materials: – Substantive overview of the Conflict of Interest laws, Standards of
Ethical Conduct, Hatch Act, OPM Employee Responsibility and Conduct rules, Agency
Supplemental Standards]

   B. Individual behavior as a Supervisor.

       1. Serving as an Agency Designee. The Standards of Ethical Conduct, at 5 C.F.R,
2635.102(b), permit Federal agencies to delegate authority to take certain actions to implement
the agency’s ethics program to “agency designees.” In many agencies supervisors fill this role.
Among their duties are:

             a. “Widely Attended Gathering” (WAG) determinations. (5 C.F.R. 2635.204(g)) “If
the person who has extended the invitation has interests that may be substantially affected by the
performance or nonperformance of an employee’s official duties or is an association or
organization the majority of whose members have such interests, the employee’s participation
may be determined to be in the interest of the agency only where there is a written finding by the
agency designee that the agency’s interest in the employee’s participation in the event outweighs
the concerns that the acceptance of the gift of free attendance may or may appear to improperly
influence the employee in the performance of his official duties. Relevant factors that should be
considered by the agency designee include the importance of the event to the agency, the nature
and sensitivity of any pending matter affecting the interests of the person who has extended the
invitation, the significance of the employee’s role in such matter, the purpose of the event, the
identity of other expected participants, and the market value of the gift of free attendance.”

               (1) In most instances the invited employee’s supervisor is best positioned to
assess both the nature of the agency’s interest in the employee’s attendance and the “appearance”
concerns that will result from such appearance.

             (2) Even where the supervisor is not an “agency designee” his or her input into
the WAG determination is of significant value.

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            b. Disposal of perishable gifts. (5 CFR 2635.205(a)(2)) When not practicable to
return a tangible item because it is perishable, the item may, at the discretion of the employee’s
supervisor or an agency ethics official, be given to an appropriate charity, shared within the
recipient’s office, or destroyed.

            c. Authorization of an employee to participate in a matter in which he has a covered
relationship. (5 CFR 2635.502) “Where he has information concerning a potential appearance
problem arising from the financial interest of a member of the employee’s household in a
particular matter involving specific parties, or from the role in such matter of a person with
whom the employee has a covered relationship, the agency designee may make an independent
determination as to whether a reasonable person with knowledge of the relevant facts would be
likely to question the employee’s impartiality in the matter …. If the agency designee
determines that the employee’s impartiality is likely to be questioned, he shall then determine, in
accordance with paragraph (d) of this section, whether the employee should be authorized to
participate in the matter.”

    Test: Does the interest of the Government in the employee’s participation outweigh the
concern that a reasonable person may question the integrity of the agency’s programs and
operations? As with WAG determinations discussed above, the affected-employee’s supervisor
is often best able to assess the “appearance” concerns that would result from participation by the
employee. The supervisor’s input is therefore of significant value even if the supervisor is not
formally an “agency designee.”

             d. Disqualification while job seeking. (5 C.F.R. 2635.604(c)) The agency ethics
official or the person responsible for any employee’s assignment (generally, the employee’s
supervisor) may require written disqualification when employee is seeking private employment.

            A written disqualification helps ensure the employee remembers that they are
disqualified. It also alerts the employee’s supervisor to the potential conflicting interest.

           e. Prior approval of outside employment. Some agencies require prior approval by
“agency designee” before employees undertake some or all categories of outside employment.
(5 C.F.R. 2635.803) Supervisors, being aware of their subordinates’ official duties and
responsibilities, are uniquely positioned to judge whether a proposed outside position will
present a conflict or the appearance of a conflict.

            For example: An agency IT specialist who reviews the work of an IT contractor as
part of his Federal job, may not moonlight as an employee of the contractor.

        2. Conducting Financial Disclosure Program. Supervisors must be able to
understanding and articulate the purpose for and the value of this program. The financial
disclosure program assists the employee, supervisor, and ethics counselor to identify conflicting
interests and to remind them to take steps such as recusal, to prevent violation of 18 U.S.C. 208.
In the minds of some, financial disclosure is not an easy or pleasant evolution. While having to

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complete and submit a financial disclosure report may be viewed as “intrusive,” it is extremely
important that it is done properly and in a timely fashion.

           a. Supervisors play a critical role in determining which employees must file, as 5
C.F.R. 2634.904 gives agencies great discretion regarding confidential filers. Filers include GS-
15 and below employees with important roles in contracting, auditing, regulating, grant
administration or other activities having substantial economic affect on non-Federal entities.
Neither over-reporting nor under-reporting serves the public, the Government, your agency or
your subordinates.

5 C.F.R. 2634.904 Confidential filer defined.

  The term confidential filer includes:

   (a) Each officer or employee in the executive branch or at an independent agency whose
position is classified at GS-15 or below of the General Schedule prescribed by 5 U.S.C. 5332, or
the rate of basic pay for which is fixed, other than under the General Schedule, at a rate which is
less than 120% of the minimum rate of basic pay for GS15 of the General Schedule; each officer
or employee of the United States Postal Service or Postal Rate Commission whose basic rate of
pay is less than 120% of the minimum rate of basic pay for GS-15 of the General Schedule; each
member of a uniformed service whose pay grade is less than O-7 under 37 U.S.C. 201; and each
officer or employee in any other position determined by the designated agency ethics official to
be of equal classification; if:

   (1) The agency concludes that the duties and responsibilities of the employee's position
require that employee to participate personally and substantially (as defined in Sec.
2635.402(b)(4) of this chapter) through decision or the exercise of significant judgment, in
taking a Government action regarding:
   (i) Contracting or procurement;
   (ii) Administering or monitoring grants, subsidies, licenses, or other federally conferred
financial or operational benefits;
   (iii) Regulating or auditing any non-Federal entity; or
   (iv) Other activities in which the final decision or action will have a direct and substantial
economic effect on the interests of any non-Federal entity; or

   (2) The agency concludes that the duties and responsibilities of the employee's position
require the employee to file such a report to avoid involvement in a real or apparent conflict of
interest, and to carry out the purposes behind any statute, Executive order, rule, or regulation
applicable to or administered by that employee. Positions which might be subject to a reporting
requirement under this subparagraph include those with duties which involve investigating or
prosecuting violations of criminal or civil law.

5 C.F.R. 2634.905 Exclusions from filing requirements.




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   Any individual or class of individuals described in Sec. 2634.904 of this subpart, including
special Government employees unless otherwise noted, may be excluded from all or a portion of
the confidential reporting requirements of this subpart, when the agency head or designee
determines that:
   (a) The duties of a position make remote the possibility that the incumbent will be involved in
a real or apparent conflict of interest;
   (b) The duties of a position involve such a low level of responsibility that the submission of a
confidential financial disclosure report is unnecessary because of:
   (1) The substantial degree of supervision and review over the position; or
   (2) The inconsequential effect of any potential conflict on the integrity of the Government;

            b. Reviewing reports for conflicts of interest. Generally the supervisor rather than
the ethics counsel reviewer is best positioned to recognize conflicts or potential conflicts. 18
U.S.C. 208 prohibits Federal officers and employees from participating in any official capacity in
particular matters in which, to his knowledge, he has an personal financial interest, if the
particular matter will have a direct and predictable effect on that interest. Protect your
subordinates as well as the public – remember that 18 U.S.C. 208 is a criminal statute and a well-
reviewed financial disclosure report is the best way to avoid inadvertent violations.

            c. Forwarding reports to ethics counselor. Make sure that your review and conflicts
analysis is thorough so that the ethics counselor who will review the report will have the benefit
of your unique insights and expertise.

          d. Eliminating potential conflicts of interest by recusal, reassignment, divestiture, or
waiver. Consult with your ethics counselor on which measures are most appropriate under the
circumstances present.

           e. Protect privacy and confidentiality of employees’ financial disclosure reports by:

           f. Limiting access to the reports while they are in your custody during your review.

          g. Not revealing any information contained in financial disclosure reports except as
may be required for official purposes.

III. SETTING THE ETHICAL TONE
     A. Leading by Example: Supervisors’ actions more than their words demonstrate their
attitudes, values, and expectations. Employees often look to their supervisor as a role model in
order to determine their own level of compliance with ethics requirements. They know that if
the supervisor personally complies with regulations, he or she is unlikely to tolerate subordinates
who do not.

       1. Concept: “Everyday we leave a footprint. Is it one we are proud of, or otherwise?”



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       2. A 2006 study by the Ethics Resource Center identified three actions by supervisors,
managers, and coworkers that have an especially large impact on the ethics and compliance
program:

             a. Setting a good example.

             b. Keeping promises and commitments.

             c. Supporting others in adhering to ethics standards.

       3. Practice the Five Principles of Public Service Ethics (From Defense Acquisition
University and Josephson Institute of Ethics)

       #1: Public Interest: Public office is a trust to be used only to advance public interests, not
personal gain.

       #2: Objective Judgment: Decisions are to be made on the merits, free of partiality or
prejudice and unimpeded by conflicts of interest.

      #3 Accountability: Government is to be conducted openly, efficiently, equitably and
honorably so the public can make informed judgments and hold public officials accountable.

          #4 Democracy: Honor and respect democratic principles; observe the letter and spirit of
laws.

       #5 Respectability: Safeguard public confidence in the integrity of government by
avoiding appearances of impropriety and conduct unbefitting a public official.

   B. Compliance of subordinates: The following are some concrete steps, beyond the example
you set, that you can take to promote subordinate compliance with the requirements of the
Federal ethics program.

        1. Encouragement, discussion of issues. Encourage employees to communicate their
ethics concerns with you or someone else in authority and to ask questions before they take
actions.

             a. Regulations will generally protect employees who seek ethics advice before taking
action:

     “Employees who have questions about the applications of this part or any supplemental
agency regulations to particular situations should seek advice from an agency ethics official.
Disciplinary action for violating this part or any supplemental agency regulations will not be
taken against any employee who has engaged in conduct in good faith reliance upon the advice
of an agency ethics official, provided that the employee, in seeking such advice, has made full
disclosure of all relevant circumstances. Where the employee’s conduct violates a criminal

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statute, reliance on the advice of an agency ethics official cannot ensure that the employee will
not be prosecuted under that statute. However, good faith reliance on the advice of an agency
ethics official is a factor that may be taken into account by the Department of Justice in the
selection of cases for prosecution” (5 CFR 2635.107(b))

            b. On the other hand, Federal employees are required by law, at 28 U.S.C. 535, to
report any information they receive relating to a violation of the Federal criminal code (Title 18).

            c. Whistleblower protections may be available to employees raising certain ethics
concerns.

       2. Acknowledge and reward ethical behavior. Do not reward unethical, shady, or
questionable behavior, even if it yields favorable results.

        3. Keeping the Big Picture. Take the time to understand (and be able to explain to
others – particularly those in your workplace) how the ethics regulations and statutes are
designed to contribute to promoting the integrity of decision-making:

            a. Conflicts of interest statutes: (18 U.S.C. 201, 203, 205, 207-209) These criminal
statutes ensure Federal personnel do not have, or act based on, conflicting financial interests
when they are performing their official duties. Because they have no conflicting interests, we
can assume their decisions were made only in the interests of the Government.

                (1) Leaders must know not only what the laws expressly prohibit, but also what
latitude they give you and your subordinates. Waivers of the disqualification requirement are
often an option. An effective supervisor must be able to explain why their enforcement is
important.

                (2) The adoption of these laws was not meant to imply that Federal employees
are less than ethical – these laws set an extremely high standard of “appearances” because of the
rights and responsibilities that we, as public servants have been given.

           b. Impartiality regulation: (5 CFR 2635.502) – Again know your latitude. Be able to
guide your subordinates. These rules are not necessarily intuitive.

            c. Prohibition on acceptance of gifts: (5 CFR 2635 Subpart B) It may be difficult for
a member of the general public to have confidence that a Federal employee is going to act
strictly impartially toward a particular party, if the employee has received a gift from that party.

             d. Prohibition on gifts to superiors: (5 CFR 2635 Subpart C) Again, it may be
difficult for all employees in the work space to feel certain that a supervisor will behave
impartially toward all of his or her subordinates if the supervisor has accepted gifts from one or
more of them.




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            e. Regulation of political activities: (5 U.S.C. 7321-26 “Hatch Act”) Like financial
interests, political interests may compromise the impartiality of official decisions. Know the
rules that apply to you and to your employees – yours may well be more restrictive than theirs.
Behave strictly in accord with the dictates of this crucial and sensitive set of requirements.
Remember that the spoils system is dead and needs to be seen as such!

            f. Prohibition on solicitation of subordinates and prohibited sources. (5 CFR
2635.808) Nothing can more quickly undermine your authority and prematurely terminate your
career than the perception that you are abusing your position or obtaining personal gain from
your official position.

   C. Analyzing Risk for your Work Center.

        1. What are your work center vulnerabilities? Where is your compliance the weakest?
What aspects of your job keep you up at night? Identify these vulnerabilities and take positive
action to remedy them.

        2. Reporting of apparent violations. (Surveys indicate that employees tend not to report
violations they witness if they think their supervisor won’t support them or won’t take effective
action.)

          a. Establish a favorable ethical climate for violation reporting. (Don’t shoot the
messenger.)

           b. Handle reports of possible ethics violations properly:

               (1) Take reports seriously.

               (2) Allow the employee time to explain his concerns.

               (3) Provide the employee the privacy to complain.

               (4) Be prepared to protect employee’s anonymity.

               (5) Get the complaint to the proper authority.

            c. Know whom to contact in your agency for ethics and ethics-like problems – Office
of Inspector General, HOTLINE, Office of General Counsel, Security Office, Human Resources
Office, ethics counselor. Keep the phone numbers of these offices close at hand and make sure
that your employees have access to them as well.

            d. Follow-up and give feedback to the employee who registered the complaint on
how the ethics issues were resolved – demonstrate that you and the agency care about reports of
violations. Privacy considerations may prevent you from releasing all of the details of the
resolution, but at least get back to the employee confirming that something was done. Lack of

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feedback after registering a complaint was one of the most consistent complaints in both the
OGE and the DoD employee ethics surveys. Deterring future ethics violations and promoting
prompt reporting of suspected violations are best served by ensuring that all employees
recognize that the agency cares about and will address such violations.

   D. Get the word out: Include ethics issues in your periodic meetings and communications,
both verbal and written, with your employees. If you have an existing employee bulletin or
newsletter, consider adding ethics content to it. Your ethics counselor is available – and
probably eager – to assist you in doing so.

       1. Introduce ethical considerations into your decision-making. For example, ask, “Are
we doing the right thing for our customer? Is this action the appropriate action for public
servants such as us? Am I proud that I’m part of this effort?”

   E. Support Ethics Training.

         1. Suggest topics to the ethics trainers that will be of interest or importance to your work
force.

        2. Request training for specific groups or business units, including those for whom ethics
training is not mandatory under the regulations.

        3. Attend ethics training with your work unit and actively demonstrate your interest in
the topic.

        4. Ask your ethics counselor to help integrate ethics and compliance issues into other
training conducted in your office.

   F. Hold employees (and yourself) accountable!

   G. Integrate ethical considerations into your decision-making.

        1. Make ethics like safety; it is part of every decision. Usually it is a background factor
because safety issues are considered and resolved from the very beginning. If, however, the
issue involves procedures that are unsafe, then safety receives focus and discussion.

IV. COMMON ETHICS PROBLEM AREAS
   A. Use of Government credit cards. This area has been the focus of significant
Congressional and media interest, and, as a result, it has also been the subject of much Inspector
General scrutiny. Supervisors should expect that it will continue to be so for the near term.
Make sure that your subordinates are aware of the rules governing the use of the various
Government-issued credit cards and that you have effective measures to ensure compliance.



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    B. Misuse of Government equipment, resources, and official time – yours and that of your
subordinates. Be sensitive to this concern and make sure that your subordinates – from top to
bottom – are aware of it as well. This is one ethics rule that is subject to abuse – and detection –
at all levels of the workplace.

    C. Working with contractors. They may look like Federal employers these days, but they’re
not! Know where you may include contractors in “employee” activities and where you may not.
Excellent guidance on “contractors in the workplace” can be found at:
http://www.dod.mil/dodgc/defense_ethics/resource_library/guidance.htm

   D. Recusals. Ethics rules require that employees recuse themselves from participating in
matters in which they have an actual conflict of interests or the appearance of one. This basic
requirement is critical to ensuring that the public has confidence in the employees’ agency’s
programs and operations.

       1. Know when recusals are appropriate or required – consult with your ethics counselor
in making recusal decisions.

       2. Establish “gate-keepers” for recused officials in order to ensure that both the officials
and the operations of the agency are protected.

       3. Ensure that the appropriate officials, such as the recused official’s assistants and
supervisor, have been notified of an individual’s recusal from participating in a particular matter
or matters.

    E. Violations of post-employment restrictions. Again, consult with your ethics counselor on
this complex – and criminal – topic. Make sure that you and your employees are aware of your
and their own restrictions, and that they know how to react if they are contacted by a former
Federal official.

   F. Fundraising and solicitation.

      1. In the workplace: Fundraising and solicitation in the Federal workplace are governed
by OPM regulations that are found at 5 C.F.R. 950. Be aware of the rules that apply during the
CFC period and in the case of natural disasters.

         2. Outside of the workplace: Fundraising outside the Federal workplace (other than
political fundraising, which is governed by the Hatch Act. See above.) is governed by the
Standards of Ethical Conduct for Employees of the Executive Branch, at 5 C.F.R. 2635.808.
One of the most critical points is that employees may not solicit in a personal capacity from
prohibited sources or from subordinates. The potential for coercion that arises, particularly in
the latter situation, clearly mandates against such solicitation.




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    G Travel – Frequent Ethics Violations. Supervisors should be aware of these and similar
concerns, both for their own official travel and for subordinate official travel that may be subject
to their approval.

        1. Scheduling official travel for personal reasons. This includes making travel plans in
order to travel at a specific time, by a particular route or using a specific airline primarily for
one’s personal convenience rather than in the interest of the Government.

         2. Inappropriate Use of Government Travel Card. Ensure that subordinates understand
that the Government travel card is available only for use while on official travel and for purposes
tied to such official travel. The fact that an
employee pays promptly a credit card bill upon receipt does not justify its use for other than
authorized purposes, nor does it absolve the employee from adverse administrative action

       3. Misuse of Government vehicles. Be aware, in particular, of home-to-work restrictions
and the requirement that official vehicles may be used only for authorized, official purposes.

         4. Misuse of Government aircraft. In addition to any general restrictions on the use of
such aircraft that an agency may have instituted, supervisors must also be aware of specific
restrictions on travel by family members of Government officials on Government aircraft.

        5. Inappropriate reimbursement of travel expenses. Authority exists, at 31 U.S.C. 1353,
as implemented at 41 C.F.R. 304, for agencies to accept certain offers from non-Federal entities
to reimburse agency travel expenses, provided that the acceptance will not result in a conflict of
interest or the appearance of a conflict. Although in many agencies, such determinations are
made by ethics counselors, the supervisor is generally most familiar with the duties of the
traveler and whether the source of the offer would be unduly affected by the performance of such
duties. Accordingly, supervisors should ensure that the agency decision-maker has the benefit of
their input in determining whether the agency should accept such offers.

V. WRAP-UP & CONCLUSION
   A. Hypothetical ethics case studies

   B. Final Thought:    Take the High Road
   C. Feedback:

       1. What will you take back from this course?

       2. What actions will you take next week at work that result from this course?

       3. What can we do to improve this course?



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