The Army has issued general ethics guidance for those who want to work for a non-federal entity while furloughed, reminding them they would remain subject to “normal” ethics rules if they do so.
The guidance includes the following common rules and principles to be aware of:
Once an employee starts to seek outside employment, the employee is disqualified from personally and substantially participating in a particular matter that will have a direct and predictable effect on the financial interests of a current or prospective employer – and where an actual conflict arises, DoD regulations require the employee to provide a written disqualification statement to his supervisor.
Employees required to file a public financial disclosure report must notify the appropriate ethics office within three-days of starting negotiations for outside employment.
A contractor cannot hire an Army employee to perform the employee’s official duties, even while on furlough.
DoD requires prior supervisory approval for outside employment with a prohibited source (such as a DoD contractor) for all financial disclosure filers.
Any outside employment may not entail representation back to the federal government on particular matters where the government is a party or has an interest.
If DoD personnel are considering an opportunity to serve in an outside position in their personal capacities, whether the position is compensated or uncompensated, they should immediately disqualify themselves from participating in DoD matters that could affect their prospective employer in order to avoid a conflict of interest.
