2012 Combined Federal Campaign Training Conference Ethics and Legal Awareness Linda Siegle, Chesapeake Bay Area CFC Nita Yates, Hawaii CFC 2012 Combined Federal Campaign Training Conference

Myths and Legends All Campaigns are the Same It is Better to Beg for Forgiveness Than to Ask for Permission Most Federal Agencies Interpret Things in a Similar Fashion If You Did It, Then I Can Do it Too! Black and White Solutions The Legal/Ethics ‘Silver Bullet’ 2012 Combined Federal Campaign Training Conference

Reality Legal/Ethics Responsibilities Permeate Your Entire Campiagn No two General Counsel and/or Ethics Officers ever interpret a regulation the same way Ethics/Legal Issues are Frustrating – Inconsistencies – Affects Morale and Creativity – No Hard and Fast Guidance – Often Time Consuming

2012 Combined Federal Campaign Training Conference So, What’s a Campaign to Do? Be Aware Be Flexible Be Creative Plan Ahead to Allow Legal/Ethics Research Don’t Avoid/Ignore Legal/Ethics Remember the Purpose of the Campaign

2012 Combined Federal Campaign Training Conference Levels of Concerns Campaign Level – Governance LFCC Membership / Oversight Campaign Committees – Campaign Staff – Campaign-Wide Events and Activities Federal Agency Level – Campaign Committee / Oversight – Agency Events and Activities

2012 Combined Federal Campaign Training Conference Regulations 5 CFR 950 CFC Memoranda DoD Directive Army Regulations (AR600-29) Guidance from Specific Agencies – Ethics Officer – General Counsel

2012 Combined Federal Campaign Training Conference Campaign Level Governance and Oversight – Conflict of Interest – Avoid Coercion Campaign Budget and Expenses – Legitimate and Necessary Expenses – Return on Investment – How Would Donors View Use of Funds? Campaign Volunteers and Staff – Conflict of Interest – Solicitation of Businesses

2012 Combined Federal Campaign Training Conference Application Review Federal Employees Must Perform Review – PCFO May Support Process Conflict of Interest Fair, Consistent Treatment of ALL Applications – Standardize the Process – Train Review Committee Members

2012 Combined Federal Campaign Training Conference Charity Speakers Be Consistent Be Fair to All Ensure Equal Opportunities Provide Guidelines/Training to Speakers Some Agencies Will Not Support – Concerned that it will appear as ‘endorsement’ – Only allow if ALL charities are notified

2012 Combined Federal Campaign Training Conference Sponsorships / In Kind Donations Federal Employees May Not Solicit Use Standard Process for Request Determine How You Will Acknowledge – Be Consistent – No Posting of Logos or Web Links Use of Funds / Items – Campaign Wide? – Equal Opportunity for Federal Agencies to Access

2012 Combined Federal Campaign Training Conference Events / Activities Events and Activities Raise Awareness Vary widely from Agency to Agency – Different cultures – Ensure appropriateness of event Equal Ability to Participate “Raffles” versus “Drawings” Approvals Well Ahead Help Avoid Stress / Issues Some Agencies Authorize ‘Standard’ Events

2012 Combined Federal Campaign Training Conference Giveaways/Recognition Gifts Should Be of ‘Nominal’ Value – What is nominal value? – Be aware of rules regarding the ability of federal employees to accept gifts or meals Look at Return on Investment (ROI) Always Safe to Use ‘Internal’ Prizes – Executive Parking Space – Lunch with Boss

2012 Combined Federal Campaign Training Conference Employees / Volunteers On the Clock? – During work hours? – On leave? On federal property? – Agency rules/policies apply – Safety, injury Off federal property? – What liability is there?

2012 Combined Federal Campaign Training Conference The Bottom Line LEGAL – Know the rules, be informed ETHICS – “Would you be comfortable if this appeared on the front page of your local newspaper?” Ensure your staff and volunteers are aware of legal and ethics concerns Plan ahead and/or standardize Be CONSISTENT Common sense!