The Office of Government Ethics issued guidance to agencies on assessing and addressing the ethics risks in their workforces.
To assess risks, agency ethics officials “encouraged to: review advice logs for common issues; discuss upcoming work and agency priorities with senior staff; talk to program managers about risks inherent in their work; conduct surveys to identify common and emerging ethics risks; and talk to employees about the ethics concerns they encounter in the workplace,” the guidance says.
They should then “develop different ethics education messages and products for different groups of employees based on risk” and consider the risks “most relevant to the day-to-day work of their specific audiences when deciding which ethics concepts to cover and how much time to dedicate to each. For example, employees involved in procurement may require a greater emphasis on financial conflicts of interest. Similarly, employees involved in science and research may require greater emphasis on outside teaching, speaking, and writing.”
“Just as the content of ethics education should be relevant to the intended audience, the format of any ethics communications should be appropriate to the needs of the target audiences. Employees in positions with elevated ethics risks may benefit from in-person briefings and communications. Employees with ongoing ethics risks may benefit from a series of written or oral reminders. For employees who face minimal risks in their day-to-day work, basic, web-based training may be sufficient,” it says.
Another consideration is timing, it says, since executives “may require frequent, short interactions addressing real-time issues” while employees whose work poses ethics risks only occasionally “may require targeted communications that coincide with the beginning of sensitive work.”
Agencies further should continually evaluate the effectiveness of that training, it adds, through steps such as gathering feedback from employees and agency leaders and comparing inquiries to the agency ethics office from before and after the training.