Restrictions on the Promotion of Outside Personal Interests

Restrictions on the Promotion of Outside Personal Interests in Federal Workplaces Sean Croston Deputy Ethics Official Federal Reserve Board & Jeremy Suttenberg Deputy Ethics Official U. S. Nuclear Regulatory Commission

DISCLAIMER • The views that we express are our own and do not necessarily represent those of the Federal Reserve Board or the Nuclear Regulatory Commission. 2

Agency ethics officials occasionally face staff questions about the permissibility of promoting various outside personal interests at work, like: • Soliciting donations for favored charities • Supporting political ideas/groups/candidates • Endorsing professional organizations • Advertising for personal business, nearby commercial vendors or entertainment sites • Selling items in federal buildings 3

4 Child Care An agency employee who is affiliated with the Board of the agency’s on-site child care center (usually a private nonprofit) asks if the center can solicit funds for its tuition assistance program within the federal building, outside of the center itself.

Retirement A secretary is on terminal leave in anticipation of retiring after many years of service at the agency. In the office-wide email announcement for her retirement party, she wants to request donations to a 501(c)(3) Federal Secretaries Fund in lieu of flowers or other personal gifts. When you look up this Fund, you also notice that its website lists this secretary as a Board Member for the Fund. 5

Obituary What about an office-wide email forwarding an obituary for a distinguished former employee, which requests donations to the American Cancer Society? Or donations to the former staffer’s favorite politicians in lieu of flowers? 6

Solicitation of Co-Workers An agency employee wants to solicit his co-workers for donations to cover the expenses of his daughter’s trip to a regional beauty pageant 7

Professional Organization An agency attorney who is an active member of the American Attorneys Association wants to distribute an announcement for the Association’s next section meeting, which will feature a “year in review” discussion of the agency’s recent activities. The attorney also wants to send recruiting emails to new agency employees, asking them to join the Association. 8

Affinity Group A group of agency employees wants to put an ad in the agency newsletter regarding their efforts to start a new affinity group (Antarctican Agency Employees) The employees want to include an announcement for an AAE organizing event at a “great” restaurant across from HQ. Can the announcement also include a $5 -off coupon for agency employees on behalf of the restaurant? 9

Housing Ad An agency employee wants to post a personal ad on agency bulletin board for her apartment, which notes that she prefers “quiet, single, nonsmoking, professional, Orthodox female” tenants 10