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Avoid ethical pitfalls during holiday season

By | Dec. 3, 2010

LACKLAND AIR FORCE BASE, Texas — 'Tis the season for giving, right? But in the midst of this holiday season full of gifts, parties, and fundraisers, don't let the federal ethics rules slip your mind. Here are some important things to remember as you plan for a happy, and ethical, holiday season.

Gifts
A federal employee may not directly or indirectly solicit or accept gifts offered because of his official position, from someone with business before his agency, or from someone whose interests may be substantially affected by the employee's performance of duty.

Although holiday gifts between friends and family are fine, a federal employee may not accept a gift worth more than $10 from a subordinate or person in a lower pay grade, or a gift worth more than $20 (or gifts totaling more than $50 in a year) from a contractor or contract employee, unless there is a bona fide personal relationship underlying the gift.

You should never accept gifts of cash from a contractor or subordinate. Different rules may apply for the 737th Training Group and Airmen assigned to that group may call Capt. Lindsay Jenschke, 802nd Mission Support Group Legal Office at 671-3362 for more information.

Parties
It's fine to attend parties hosted by your peers and superiors, ones that are open to the general public or to all government or military personnel, and ones to which you were invited based on a relationship outside the workplace. You may attend a party hosted by a subordinate if the hospitality provided is customary for the occasion.

Similarly, if you are hosting a party as a supervisor, you may accept a hospitality gift from a subordinate at your party if the gift is of the type and value customarily given on such an occasion. If an open house or reception is hosted by a contractor, you may attend and accept any refreshments if it is a widely-attended gathering and your supervisor determines it is in your agency's interest that you attend. If you're having an office or squadron party, you may not use appropriated funds to pay for it.

Fundraisers and Solicitations
Since you can't use taxpayer money for your party, how do you cover expenses? A private organization, such as a unit booster club, can hold fundraisers such as a bake sale or fun run, or simply ask people to contribute. Private organizations wanting to conduct a fundraiser must submit the Lackland AFB Fundraising Request Form, located online at www.lacklandfss.com/private_org.html, and any advertising materials to Scott Wooley, 802nd Force Support Squadron, in advance of the event.

You may not conduct raffles or other gambling activities to raise funds. You may not solicit outside sources, e.g., businesses on- or off-base, for contributions of any sort for your party in your official capacity (i.e., in uniform, on-duty, using official letterhead, and invoking your unit or the Air Force).

However, private organizations may solicit funds for your unit party off duty, out of uniform, using booster club letterhead, and not using your rank or official position.

Follow the advice above, and you'll be well prepared. If you have any questions, call the 802nd MSG Legal Office at 671-3362 and ask to speak with an ethics counselor. And have a happy - and ethical - holiday season!