The Office of Government Ethics has issued guidance on exceptions to gift acceptance restrictions for federal employees involving free attendance at events.

Employees may accept free attendance from an event’s sponsor on a day when the employee is making a presentation as part of official duties, or from any source if the event is deemed a “widely attended gathering”–in the latter case, additional restrictions apply if the source is not a sponsor.

Legal Advisory 17-04 states that in deciding who is a “sponsor” for purposes of those exceptions, agencies should consider who determined the topics to be covered, the intended audience, the agenda, the speakers, the date or the location for the event, and who is the primary point of contact.

In contrast, it said, merely providing financial support for an event does not make an individual or organization a sponsor for those purposes.