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  • 8/14/2019 FEDERAL EMERGENCY MANAGEMENT AGENCY - INSTRUCTION

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    FORmat FOR PAGE ONE OF FEMA INSTRUCTION

    FEDERAL EMERGENCYMANAGEMENT AGENCYDate NumberINSTRUCTION April 27 , 1993 1100. 1 GC

    Standards of Conductsubject)

    1. Purpose. This instruction adopts the Office of GovernmentEthics (OGE) regulations at Title 5 Code of Federal Regula-tions (CFR) relating to standards of conduct for FederalEmergency Management Agency (FEMA) employees, and assignsresponsibilities for its implementation.2. Applicability and Scope. The provisions of this instructionare applicable to all FEMA employees in headquarters, regions,and field establishments.3. Supersession. This instruction supersedes FEMA,Instruction 1100.1, Standards of Conduct, dated June 15, 1983.4. Authorities.

    a. Title 5 United States Code Appendix 4, Sections 201-212,Executive Financial Disclosure,.

    b. Executive Order 12674 pf April 12, 1989, PrescribingStandards of Ethical Conduct for Government Officers andEmployees.

    c. United States Office of Government Ethics regulations,Standards of Ethical Conduct for Employees of the ExecutiveBranch, 5 CFR Part 2635.

    d. The Inspector General Act of 1978, 92 Statute 1101, asamended by Public Law 100-504, 102 Statute 2515.5. Responsibilities.

    a. The General Counsel in accordance with the provisions ofthe attachment is designated the Agency Ethics Officer andresponsible for the following:

    (1) Reviewing positions annually to determine if the.persons occupying the position; are required to file a StandardForm (SF) 278, Public Financial Disclosure Report, or an SF 450,Confidential Financial Disclosure Report;(Do NOT type text below this line)

    Distribution: H(AllPersHqFld)

    FEMA Form 51-2a, JUL81 (Supersedes Previous Edition) USE.FOR FIRST PAGE OF INSTRUCTION ONLY

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    April 27, 1993 FEMA Instruction 1100.1within 30 days of termination in accordance with Office ofGovernment Ethics published regulations.

    c. FEMA employees are responsible for fully familiarizingthemselves with all the requirements of the standards of conductregulations issued by the OGE. The OGE regulations aresynopsized in the attachment. FEMA employees are required toconduct themselves in accordance with these regulations. Failureto comply may subject the employee to appropriate disciplinaryaction.

    d. The Inspector General pursuant to the Inspector GeneralAct is the appropriate authority within FEMA for the following:(1) Investigating reports of waste, fraud, abuse, andcorruption;(2) Investigating, if appropriate, any suspectedviolations of the Federal Statutes at 18 United States CodeSections 201-209; and(3) Referring cases to the United States Department ofJustice.

    6. Forms Prescribed. This instruction prescribes the use of thefollowing forms which may be obtained from the Office of GeneralCounsel.a. SF 278, Public Financial Disclosure Report.b. SF 450, Confidential Financial Disclosure Report.

    james L. Wittirector

    AttachmentOffice of Government Ethics Standards of Conduct

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    april 27, 1993 fema instruction 1100.1

    OFFICE OF GOVERNMENT ETHICSSUMMARYof New Standards of Ethical Conduct

    THE STANDARDS OF ETHICAL CONDUCTEffective February 3, 1993, the Standards of Ethical Conduct for Employees of theExecutive Branch at 5 CF R Part 2635 replace the many individual agency standards ofconduct regulations with a uniform set of standards applicable to all employees of theExecutive branch. Where necessary, individual agencies have authority to issue supple-mental regulations.Because they are intended to answer questions about the ethical conduct of more than amillion individuals employed by more than 100 different Federal agencies, the newStandards of Ethical Conduct are detailed. They contain many examples and will readilyanswer most ethical questions employees will have. The attached synopsis has beenprepared bythe Officeof Government Ethicsto give employees enoughfamiliaritywith thecontents of the regulations to recognize ethical issues when they arise and to assist inlooking up relevant provisions in the regulations. Because the synopsis provides only ashorthand reference to lengthier provisions in the regulations, an employee must refer tothe regulations themselves in resolving ethical issues that actually arise or may seek theadvice of an agency ethics official.

    Copies of complete text ofStandards are available in theOffice of General Counsel

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    FEMA Instruction 1100.1Dril 27 . 1993

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    FEMAnstruction100.1 April 27,1993

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    FEMA Instruction 1100.1

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    april 27, 1993 fema instruction 1100.1

    SYNOPSIS OF SUBPART A - GENERAL PROVISIONSTHE PRINCIPLES OF ETHICAL CONDUCT. Thefollowing principles of ethical conduct apply to allofficers and employees of the executive branch andmanyform the basis for specific standards set forth inthe regulation.* Public service isapublic trust, requiring employeesto place loyalty to the Constitution, the laws andethical principles above private gain.* Employees shall not hold financial interests thatconflictwith the conscientious performance of duty.* Employees shall not engage in financial transac-

    tions using nonpublic Government information orallow the improper use of such information to fur-ther any private interest.* An employee shall not, except pursuant to theexceptions in subpart B, solicit or accept any gift orother item of monetary value from any person orentity seeking official action from, doing businesswith, or conducting activities regulated by theemployee's agency, or whose interests may besubstantially affected by the performance or non-performance of the employee's duties.* Employees shall putforth honesteffortintheperfor-mance of their duties.* Employees shall make no unauthorized commit-ments orpromises of any kind purportingto bind theGovernment.* Employees shall not use public office for privategain.* Employees shall act impartially and not give prefer-ential treatment to any private organization or

    individual.* Employees shall protect and conserve Federalproperty and shall not use it for other than autho-rized activities.* Employees shall not engage in outside employ-ment or activities, including seeking or negotiatingfor employment, that conflict with official Govern-ment duties and responsibilities.

    * Employees shall disclose waste, fraud, abuse, andcorruption to the Office of Inspector General.

    * Employees shall satisfy in good faith their obliga-tions as citizens, including all just financial obliga-tions, especiallythose such as Federal, State andlocal taxes-that are imposed by law.* Employees shall adhere to all laws and regulationsthat provide equal opportunity for all Americansregardless of race, color, religion, sex, nationalorigin, age, or handicap.* Employees shall endeavor to avoid any actions

    creating the appearance that they are violating thelaw or these Standards of Ethical Conduct.BASIC CONCEPTS.* Employees shall apply the principles stated abovein weighing the propriety of conduct not otherwiseaddressed in the regulations.* Employees shall judge whether circumstances willviolate the appearance principle, the last principleset forth above, from the perspective of a reason-able person with knowledge of the relevant facts.* There are special rules for determining which stan-dards apply to employees detailed to other agen-cies, to other branches of the Federal government,to State or local governments or to internationalorganizations.* A violation of the regulatory standards may because for corrective action orfor disciplinary actionagainst an employee. There are criminal penaltiesfor violations of criminal statutes referred to in theregulations.* Employees are encouraged to seek the advice ofagencyethics officials. Disciplinary action forviola-tion of regulatorystandardswill not be taken againstan employee who relies on such advice.DEFINITIONS. Terms used throughout the Stan-dards of Ethical Conduct, such as "agency designee"and "Special Government Employee," are defined insubpart A. Terms of more limited applicability are

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    FEMA Instruction 1100.1nril 97 1993

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    April 27, 1993FEMA Instruction 1100.1defined in the subparts or sections to which theyapply.

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    April 27 , 1993 FEMA Instruction 1100.1SYNOPSIS OF SUBPART B - GIFTS FROM OUTSIDE SOURCES

    BASIC PROHIBITION ON GIFTS FROM OUTSIDESOURCES. An employee shall notsolicitoracceptagift given because of his official position or from aprohibited source. A prohibited source is defined asany person, including anyorganization morethan halfof whose members are persons:

    Seeking official action by his agency;Doing or seeking to do business with his agency;Regulated by his agency; orSubstantially affected by the performance of hisduties.

    DEFINITION OF A GIFT. Th e term "gift" includesalmost anything of monetary value. However, it doesno t include:Coffee, donuts an d similar modest items of foodan d refreshments when offered other than as partof a meal;Greeting cards and most plaques, certificates andtrophies;Prizes in contests open to the public;Commercial discounts availabletothe general pub-lic or to all Government or military personnel;Commercial loans, and pensions an d similar ben-efits;Anything paid for by the Government, secured bythe Government under Government contract oraccepted by theGovernment in accordance with astatute;Anythingforwhich the employeepays marketvalue.

    EXCEPTIONS. Subject to the limitations noted be-low, there are exceptions which will permit an em-ployee to accept:

    Unsolicited gifts with a market value of $20 or lessper occasion, aggregating no more than $50 in acalendar yearfrom any one source (this exception

    does not permit gifts of cash or investment inter-ests);Gifts when clearly motivated by a family relation-ship or personal friendship;Commercial discountsand similar benefits offeredto groups in which membership is not related toGovernment employment or, if membership is re-lated to Government employment, where the sameoffer is broadly available to the public throughsimilar groups, and certain benefits offered bypro-fessional associations or by persons who are notprohibited sources;Certain awards and honorary degrees;Gifts resulting from the outside business activitiesof employees an d their spouses;Travel and entertainment in connection with em-ployment discussions;Certain gifts from political organizations;Free attendance provided by the sponsor of anevent for the dayon which an employee is speakingor presenting information at the event;Free attendance provided by the sponsor of awidely-attended gathering of mutual interest to anumber of parties where the necessary determina-tion of agency interest has been made;Invitations to certain social events extended bypersons who are not prohibited sources, providedno one is charged a fee to attend the event;Certain gifts of food an d entertainment in foreignareas;Gifts accepted by the employee under a specificstatute, such as 5 U.S.C. 4111 and 7342, or pursu-an t to a supplemental agency regulation.

    LIMITATIONS ON USE OF EXCEPTIONS. An em-ployee may not use any of the exceptions notedabove to solicit or coerce the offering of a gift or toaccept gifts:

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    April27 , 1993 FEMA Instruction 1100.1

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    FEMA Instruction 1100.1 April 27,1993For being influenced in the performance of officialduties;In violation of any statute;So frequently as to appearto be using public officefor private gain; or

    DISPOSITION OF GIFTS. When an employee can-no t accept a gift, the employee should pay the donorits market value. If the gift is a tangible item, theemployee may instead return the gift. Subject toapproval, however, perishable items may be donatedto a charity, destroyed or shared with the office.

    In violation of applicable procurement policies re -garding participation in vendor promotional train-ing.

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    April 27 , 1993FMA Instruction 1 100.1

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    April 27 . 1993 FEMA Instruction 1100.1SYNOPSIS OF SUBPART C - GIFTS BETWEEN EMPLOYEES

    BASIC PROHIBITION ON GIFTS BETWEEN EM-PLOYEES. An employee shall not:

    Give or solicit for a gift to an official superior; orAccept a gift from a lower-paid employee, unlessthe donor and recipient are personal friends whoare not in a superior-subordinate relationship.

    DEFINITION OFA GIFT. Theterm "gift" has the samemeaning as in subpart B. However, carpooling andsimilar arrangements are excluded where there is aproportionate sharing of the cost and effort involved.DEFINITION OF AN OFFICIAL SUPERIOR. Theterm "official superior" includes anyone whose officialresponsibilities involve directing or evaluating theperformance of the employee's official duties orthoseof any other official superior of the employee. Theterm is not limited to immediate supervisors butapplies to officials up the supervisory chain.EXCEPTIONS. Subject to a limitation on using anyexception to coerce a gift from a subordinate, thereare exceptions that:

    On an occasional basis, including birthdays andother occasions when gifts are traditionally ex-changed, permit giving and accepting:

    Items otherthan cash aggregating $10 or less peroccasion;Food and refreshments shared in the office;Personal hospitality at a residence;Appropriate hostess gifts; andLeave sharing under OPM regulations.

    Infrequent occasions ofpersonal significance, suchas marriage, and occasions that terminate thesuperior-subordinate relationship, such as retire-ment, permit giving and accepting gifts appropriateto the occasion; andPermit voluntary contributions of nominal amountsto be made or solicited for gifts of food an d refresh-ments to be shared in the office orfor group g ifts onoccasions such as marriage or retirement describedin the preceding paragraph.

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    April 27, 1993 FEMA Instruction 1100.1

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    FEMA Instruction 1100.1 Apr11 27,1993

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    April 27, 1993EM A Instruction 1100.1

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    April27 1993 fema instruction 1100.1SYNOPSIS OF SUBPART D - CONFLICTING FINANCIAL INTERESTS

    DISQUALIFYING FINANCIAL INTERESTS. Underthe criminal conflict of interest statute, 18 U.S.C. 208,an employee is prohibited from participating in anofficial capacity in any particular matter in which, tohis knowledge, he or certain other persons have afinancial interest, if the particular matter will have adirect and predictable effect on his own orthat person'sfinancial interests.

    APPLICABILITY. Inaddition to matters that affecthis own financial interests, this prohibition appliesto particular matters that affect the financial inter-ests of:The employee's spouse, minor child or generalpartner; orAny person the employee serves as officer, di rec-tor, trustee, general partner or employee.

    The prohibition also applies to particular mattersthat affect the financial interests of a person withwhom the employee is negotiating for or has anarrangement concerning future employment. How-ever, this aspect of the statute is addressed morespecifically in subpart F.DISQUALIFICATION. Disqualification can be ac-complished simply by not participating in the mat-ter. Although an employee should notify the person

    responsible for his assignment of the need to dis-qualify, a written disqualification statement is nec-essary only if required by an ethics agreement orrequested by an agency ethics official orthe personresponsible for the employee's assignment.SOLUTIONS OTHER THAN DISQUALIFICATION.Disqualification is not required if the financial inter-est is the subject of one of the statutory waiversdescribed insubpart Dor if the employee has soldor otherwise divested the conflicting interest.

    PROHIBITED FINANCIAL INTERESTS. In general,employees may acquire and hold financial interestssubject only to the disqualification requirement im-posed by 18 U.S.C. 208. However, some agencieshave statutes that prohibit employees from acquiringor holding particular interests. In addition, subpart Dgives agencies the authority, by supplemental regu-lation, to prohibit employeesfrom acquiring orholdingcertain financial interests. Agencies also may prohibitan individual employee from holding financial inter-ests where disqualification would impair theemployee's abilityto perform the duties of his positionor adversely affect the agency's mission. An em-ployee directed to divest a financial interest may beeligible for special tax treatment of the transaction.

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    FEMA Instruction 1100.1pril 7, 1993

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    FEMA Instruction 1100.1 april 27, 1993

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    April 27, 1993EMA Instruction 1100.1

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    April 27 , 1993 FEMA Instruction 1100.1SYNOPSIS OF SUBPART E - IMPARTIALITY IN PERFORMING OFFICIAL DUTIES

    CONSIDERATION OF CERTAIN PERSONAL ANDBUSINESS RELATIONSHIPS. Even though his dis-qualification may not be required undersubpart D, anemployee should not participate in an official capacityin certain matters without first obtaining specific au-thorization if, in his judgment, persons with knowl-edge of the relevant facts would question his impar-tiality in those matters.

    MATTERS COVERED. The matters covered in-clude a particular matter involving specific parties ifthe employee knows that it is likely to affect thefinancial interests of a member of his household orthat one of the following persons is a party orrepresents a party in the matter:

    A person with whom the employee has or seeksa business or other financial relationship;A member of the employee's household or rela-tive with whom the employee has a close per-sonal relationship;A person the employee's spouse, parent or childserves or seeks to serve as officer, director,trustee, general partner, agent, attorney, consult-ant, contractor or employee;A person the employee has, in the past year,served as officer, director, trustee, general part-ner, agent, attorney, consultant, contractor oremployee; orAn organization, other than a political party, inwhich the employee is an active participant.

    DISQUALIFICATION. Disqualification can be ac-complished in the same manner as when requiredunder subpart D or disqualifying financial interests.AUTHORIZATION TO PARTICIPATE. Notwith-standing the employee's determination that hisimpartialitywould be questioned, the agency desig-neecan authorizetheemployeeto participate inthematter based on a determination that theGovernment's interest in he employee's participa-tion outweighs the concern that a reasonable per-son would question the integrity of agency pro-grams and operations. The authorization permittedby subpart E cannot be given, however, if theemployee's disqualification is also required bysubpart D.OTHER APPLICATION OF THE PROCESS. Em-ployees are urged to use the process set forth insubpart E to decide whether they should or shouldnot participate inother matters inwhich their impar-tiality is likely to be questioned.

    EXTRAORDINARY PAYMENTS FROM FORMEREMPLOYERS. An employee is disqualified for 2years from participating in any particular matter inwhich his former employer is a party or represents aparty if, prior to entering Federal service, that em-ployer gave him an extraordinary payment in excessof $10,000.* A routine severance and other payment madeunderan established employee benefits plan wouldnot be an extraordinary payment.* There is authorityto waive all orpart of this disquali-fication requirement.

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    FEMA Instruction 1100.1pril 27, 1993

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    fema instruction 1100.1 april 27 , 1993

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    April 27 , 1993em a Intrinetinn I 1Of) 1

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    April 27 . 1993 FEMA Instruction 1100.1SYNOPSIS OF SUBPART F - SEEKING OTHER EMPLOYMENT

    DISQUALIFICATION WHILE SEEKING EMPLOY-MENT. An employee is prohibited from participatingin an official capacity in any particular matter that, tohis knowledge, has a direct and predictable effect onthe financial interests of a person with whom he isseeking employment. For this purpose, "employ-ment" means anyform of non-Federal employment orbusiness relationship involving the provision of per-sonal services.

    DEFINITION OF SEEKING EMPLOYMENT. Theterm "seeking employment" includes b ilateral ne-gotiations with another, mutually conducted with aview to reaching an agreement regarding possibleemployment. Italso includes conductshort of nego-tiations, such as sending an unsolicited resume orother employment proposal. It can include employ-ment contacts byorth rough an agent or intermedi-ary. However, it does not include simply:* Rejecting an unsolicited employment overture;* Requesting a job application; or* Sending an unsolicited resume or other employ-ment proposal to a person affected by perfor-

    mance of the employees duties only as a memberof an industry or other discrete class.Having once begun, an employee generallycontin-ues to be seeking employment until he or theprospective employer rejects the possibility of em-

    ployment and al l discussions end. However, anemployee is no longer seeking employment withthe recipient of his unsolicited resume or otheremployment proposal aftertwo months have passedwith no indication of interest in employment discus-sions from the prospective employer.DISQUALIFICATION. Disqualification can be ac-complished in the same manner as when requiredunder subpart Dfordisqualifying financial interests.SOLUTIONS OTHER THAN DISQUALIFICATION.If the employee's conduct in seeking employmentamounts to negotiations, the employee can partici-pate in the matteraffecting his prospective employeronly if granted an individual waiver described insubpart D. If his conduct falls short of negotiations,the employee may be authorized to participate usingthe procedures set forth in subpart E.

    DISQUALIFICATION BASED ON AN EMPLOYMENTARRANGEMENT. An employee may no t participatein a particular matter that, to his knowledge, has adirect and predictable effecton the financial interestsof anyone with whom he has an arrangement con-cerning future employment. In this case, an employeemay be able to participate in a particular matteraffecting a prospective employer only if he has re-ceived an individual waiver described in subpart D.

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    FEMA Instruction 1100.1nril 27, 1993

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    April 27 . 1993

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    . Sylv.. I.- IJ .V |VV.Eema instrucion 11001.1

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    april 27,1993emanstruction 1100.1

    SYNOPSIS OF SUBPART G - MISUSE OF POSITIONUSE OF PUBLIC OFFICE FOR PRIVATE GAIN. Anemployee shall not use his public office for his ownprivate gain orfor the private gain of friends, relativesor persons with whom he is affiliated ina non-govern-mental capacity, or for the endorsement of any prod-uct, service or enterprise. Inparticular, an employeeshall not use his Government position, title or author-ity:

    Ina manner intended to induce another to provideany benefit to himself or to friends, relatives oraffiliated persons;Ina mannerthatcould be construed to implythat hisagency or the Government sanctions or ensorseshis personal activities or those of another; orTo endorse any product, service or enterprise ex-cept in urtherance of statutory authorityto do so, inaccordance with agency programs to give recogni-tion for achievement or to document compliancewith agency standards or requirements.

    USE OF NONPUBLIC INFORMATION. An em-ployee shall not engage in a financial transactionusing nonpublic information, or allow the improperuse of nonpublic information to further his own privateinterests or those of another. Information that is"nonpublic" includes information the employee knows

    or reasonably should know:Is routinelyexemptfrom disclosure underthe Free-dom of Information Actor protected from disclosureby statute;Is designated as confidential by an agency; orHas not actually been disseminated to the generalpublic and is not authorized to be made available tothe public on request.

    USE OF GOVERNMENT PROPERTY. An employeehas a duty to protect and conserve Governmentproperty and to use Government property only forauthorized purposes. Authorized purposes are thosefor which Government property is made available tothe public or those purposes authorized in accor-dance with law or regulation.USE OF OFFICIAL TIME. Unless authorized in ac-cordance with law or regulation to use such time forother purposes, an employee shall use official time inan honest effort to perform official duties. And, anemployee shall not encourage, direct, coerce or re-quest a subordinate to use official time to performactivities other than those required in the perfor-mance of official duties or those authorized in accor-dance with law or regulation.

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    FEMA nstruction 1100.1nril97 1 Rq

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    April 27, 1993FMA Instrucition I I100. 1

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    april 27, 1993 fema instruction 11001.

    SYNOPSIS OF SUBPART H - OUTSIDE ACTIVITIESGENERALLY. In addition to the standards set forth insubpart H, an employee's outside employment andother activities must comply with all ethical require-ments set forth in the subparts A through G of theregulation, including the requirement to avoid eventhe appearance of using public office for private gain.For example, the prohibition against use of Govern-ment property for unauthorized purposes would pro-hibit an employee from using the agency photocopierto reproduce documents for his outside organization.RESTRICTIONS IMPOSED BY OTHER LAWS. Anemployee's outside employment and other activitiesmust comply with applicable laws other than theStandards of Ethical Conduct. Several are listed insubparts H and 1.Outside activities frequently raisequestions about the following:

    The restrictions in 18 U.S.C. 203 and 20 5 onemployees engaging in representational activitiesbefore the United States;The cons titutional prohibition against accepting anyoffice, title or compensation from a foreign govern-ment; andThe Hatch Act, which prohibits most employees'participation in certain partisan political activities.

    PRIOR APPROVAL FOR OUTSIDE ACTIVITIES.When required by supplemental agency regulation,an employee shall obtain approval before engaging inoutside employment or a ctivities.CONFLICTING OUTSIDE ACTIVITIES. An employeeshall no t engage in outside employment or activitiesprohibited by statute or by supplemental agencyregulation, or that which would materially impair theability to perform his official duties by requiring hisdisqualification under subpart D or E.RESTRICTIONS ON RECEIPT OF COMPENSA-TION. With certain exceptions, Presidential appoin-tees to full-time noncareer positions shall no t receiveany outside earned income for outside employmentor other outside activities performed during that ap-pointment. Higher-level noncareer employees maynot, in any calendar year, receive outside earnedincome which exceeds 15 percent of the rate of pay

    for Level II of the Executive Schedule. These nonca-reer employees also are prohibited from receivingan y compensation forteachingwithout prior approval,serving as officers or board members of outsideentities, practicing certain professions or being affili-ated with firms or other entities that practice thoseprofessions.SERVICE AS AN EXPERT WITNESS. In the ab-senceof specific authorization, an em ployee shall no trepresent anyone other than the United States as anexpert witness in any proceeding before a court oragency of the United States if the United States is aparty or has a direct and substantial interest. Therestriction applies even though no compensation isreceived. A less restrictive standard applies to specialGovernment employees.TEACHING, SPEAKING AND WRITING. An em-ployee shall no t receive compensation for teaching,speaking or writing that is related to his official duties.

    DEFINITION OF RELATED TO DUTIES. Teach-ing, speaking orwriting is "related to an employee'sofficial duties: if:Th e activity is undertaken as part of his officialduties;Th e invitation to engage in the activity was ex-tended primarily because of his official position;Th e invitation or the offer of compensation wa sextended by a person whose interests may beaffected by the employee's official duties;The information draws substantially on nonpublicinformation; or

    For most employees, the subjectof the teaching,speaking or writing deals in significant part withan y matter presently assigned to the employee,any matter to which the employee had beenassigned in the previous one-year period, or toany ongoing or announced policy, program oroperation of his agency. Certain noncareer em-ployees are subject to less restrictive standards.EXCEPTION FO R TEACHING. An employee may

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    FEMA Instruction 11 00 .1nril 9>7 1QQg.q

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    receive compensation forteaching certain courses, personally solicit funds or other supportfrom subordi-notwithstanding that the subject matter is related to nates or from anyone known to him to be a prohibitedhis official duties and notwithstanding that he may source for purposes of the gift restrictions in subparthave been offered the opportunity because of his B. A special Government employee, however, mayofficial position. solicitcharitablecontributionsfrom aprohibited sourceas long as that person does not have interests af-FUNDRAISING. Providedthathedoesnototherwise fected by the performance of his official duties.violate the Standards of Ethical Conduct, an em-ployee may engage in charitable fundraising activi- JUST FINANCIAL OBLIGATIONS. Employees shallties in a personal capacity if he does not use his satisfy in good faith all just financial obligations.official title, position or authority to furtherthat effort or

    April 27 , 1993FM A Instrucition I1100.1