Federal Manager's Daily Report

DoD: Special care must be taken regarding attendance at events where fundraising occurs, especially if the attendance of DoD personnel is a "draw" for the event.

DoD’s central ethics office, the Standards of Conduct Office, has summarized policies on accepting gifts of free attendance at outside events, saying that “there are differing views” on that subject among the department’s components.

It said that one common exception is for attendance at an event where agency personnel are presenting information on behalf of the department; in such cases, “the value of such attendance is considered necessary to the presentation and not a gift to either the official or the agency.” Another applies to attendance at a “widely attended gathering,” although that exception “may not be available to personnel traveling on government orders where the widely attended gathering is the primary purpose of the trip.”

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Further, special care must be taken regarding attendance at events where fundraising occurs, especially if there may be an “appearance that DoD personnel attending in an official capacity are the ‘draw’” for the event.

It also cautions about “circumstance that would create the appearance of accepting a gift on behalf of the agency primarily to permit use of a government vehicle to attend an event, particularly where members of Congress and other government leaders attending may not have similar access to official transportation.”

“Where personnel from multiple services or commands have been invited to an event, the respective ethics counselors are encouraged to coordinate with one another to mitigate the potential for inconsistent or conflicting ethics advice,” it adds.