The Office of Government Ethics has issued guidance to agencies regarding how ethics policies apply to student interns, explaining that policies vary depending on the hiring authority used to bring them on board.

Interns who are formally hired into the civil service are considered regular employees and are “fully subject” to ethics laws, conflict of interest laws and the standards of conduct, says legal advisory 17-09.

Volunteer interns “are not generally considered executive branch employees for purposes other than certain laws relating to travel subsidies, injury compensation, and the Federal Tort Claims Act,” it says. That means they are not covered by conflict of interest laws or the standards of conduct, for example. However, “OGE urges agencies to consider whether permitting volunteer interns to engage in activities that would otherwise be prohibited by the ethics laws would be inappropriate.”

In between are those serving as “special government employees” who may serve with or without compensation either on a full-time or intermittent basis for up to 130 days in any 365-day period; most restrictions apply to them.

The guidance spells out details of those distinctions as they apply to financial disclosure requirements, work on matters affecting their educational institutions, seeking outside employment, restrictions after the internship ends, and more.