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* Vermont National Guard hosts international military ski
* Reserve soldiers volunteer for Operation Restore Hope
* Medics in Somalia face hardships, by Pfc. Alberto Betancourt
* Military barter system alive and well, by Air Force Sgt. Dave
* 555th medical detachment deploys to Somalia, by Spc.
* Keeping duties free of conflict of interest, by Alfred H.

============================================================

Vermont National Guard hosts international military ski
championships

    WASHINGTON (ARNEWS) -- Military athletes from around the
world will gather in Stowe and Jericho, Vt., when the Vermont
National Guard hosts the Conseil International du Sport
Militaire Ski Championships in March.
    More than 400 competitors from 20 countries will vie in
cross-country, biathlon, triathlon and giant slalom events
during the five-day championships that begin March 2.
    The Vermont National Guard hosted the championships in
1989, the first time the competition was held outside of Europe.
    CISM was founded in 1948 in France to promote peace and
friendship among military members from different parts of the
world through sports. Since its founding, CISM has grown to
more than 82 nations, including countries of the former Soviet
Union.
    All events are free and open to the public. For more
information, call DSN 636-3246 or commercial [phone].


Reserve soldiers volunteer for Operation Restore Hope

    WASHINGTON (ARNEWS) -- The 711th Adjutant General Company
(Postal), made up of U.S. Army Reserve volunteers, deployed to
Somalia, Jan. 13, in support of Operation Restore Hope.
    "The 711th AG is a provisional unit created solely to house
the volunteers," said Steve Stromvall, spokesman for the U.S.
Army Reserve Command.
    "The reservists are from six different Army Reserve
Commands," he explained. "No Army Reserve units were mobilized
for Restore Hope. The 711th soldiers left Fort Bragg, N.C., for
Somalia; once there, they'll support a postal unit that's
already deployed.
    "The soldiers are on temporary tour for active duty while
in Somalia," Stromvall said. "The tour can be for up to 179
days. If they're needed for longer than that, they may be asked
to re-volunteer, or we may look for new volunteers to serve."
    He said the operation has no deadline for completion. The
soldiers will try to keep supporting the mission as long as
they're needed.
    "USARC and Forces Command worked together to identify
reservists with skills critical to Restore Hope. Units with
those soldiers were polled, and individuals were asked to
volunteer," Stromvall said.
    The reservists' home units are the 81st ARCOM, East Point,
Ga.; the 86th ARCOM, Fort Sheridan, Ill.; the 77th ARCOM, Fort
Totten, N.Y.; the 83rd ARCOM, Columbus, Ohio; the 94th ARCOM,
Hanscom Air Force Base, Mass.; and the 122nd ARCOM, Little
Rock, Ark.


Medics in Somalia face hardships, by Pfc. Alberto Betancourt

    KISMAYO, Somalia -- The medic stood outside a hangar on a
cold and windy afternoon, Dec. 21, at Griffis Air Force Base in
Rome, N.Y., fearing what lay ahead.
    He was bundled up in long johns, desert uniform, flak vest,
load carrying equipment, gloves and desert overcoat, and toted
his rifle while waiting to board a C-141 -- destination:
Kismayo, Somalia.
    Pfc. Shawn Davis, a native of Erie, Pa., is a member of
Headquarters and Headquarters Company, 3rd Battalion, 14th
Infantry, 10th Mountain Division (Light Infantry). The medic
knew very little about Somalia, other than that rebels were
fighting each other; but he did know one thing for sure. "I
knew we were landing on a regular airport," he said.
    One hour before the 23-hour flight ended, ammunition was
issued to the six soldiers on the plane. Davis was flung into
reality.
    "I thought to myself, 'Oh no, the rebels have taken over
the airport. Are they going to be shooting at us?' It suddenly
hit me we were not on a training exercise. This was the real
thing."
    Upon arrival, Dec. 23, he and his fellow medics were
greeted not by rebels firing guns, but by physician assistant
2nd Lt. Tom Catalina and an 89-degree Kismayo morning. Their
first battle was with the thick layer of dirt, and human and
animal waste that covered the room at the airport terminal that
was to be turned into an aid station.
    The soldiers spent two days of hard work to get the aid
station running. Soon it was decorated with IV water bags,
camouflage netting and a four-cabinet medical chest. The floor
is now clean, and "Old Glory" proudly drapes in a corner.
    Since arriving in Somalia, Catalina and his crew have been
busy overseeing field sanitation and hygiene. "This is one of
the biggest tasks we have here," he said.
    "In Fort Drum we don't get malaria in our backyard or any
of the other diseases this country has. Our job is to prevent
them from happening."
    Besides field sanitation, Catalina and his 18-man team
provide medical support for all 700 troops at Kismayo.
    "We have 600 troops at the airfield and 100 at the port,"
he said. "These include Air Force, Navy and Marines."
    According to Catalina, the 97 patients they've seen have
had minor injuries and illnesses, such as sprained ankles and
dehydration.
    "So far we haven't encountered any of the tropical diseases
we were worried about," he said. "Malaria is a scare, but we
are all taking our medication."
    On Jan. 4, the medics took part in a surprise mass casualty
exercise -- a simulated ammunition point explosion. The medics'
mission was to save life and limb in the shortest amount of
time.
    Spc. Charles Rose was enjoying a casual game of volleyball
when the call came into the aid station. Within minutes, he was
in his ambulance speeding across the airfield toward the ammo
point.
    "I didn't know it was a drill," he said. "When I got to the
point and found out it was, I still reacted as if it were the
real thing.
    "That drill helped me reflect on how I can prepare myself
mentally for what to see and what to expect in mass casualty,"
Rose said.
    Traveling has become second nature for the members of the
aid station in the last few months. November was spent training
in the California desert at the National Training Center at
Fort Irwin. One week later, they were notified that they were
deploying to Somalia. Spc. Jude Carpenter summed up the unit's
attitude: "Have boots, will travel."
    (Betancourt is in Somalia with the 19th Public Affairs Team
from Fort Riley, Kan.)


Military barter system alive and well, by Air Force Sgt. Dave
Rogers

    BAIDOA, Somalia (ARNEWS) -- The places might change; the
people might change; armies may come and go. But one thing
remains the same -- the unofficial military barter system, and
it's in full swing in Baidoa, Somalia -- French style.
    Jaime P. Bouzar, Luc Jacquemin and Cycille Talson are all
drivers for the French marines from Djibouti -- they're also
avid barterers of the highest order.
    Hats, badges, pins, knives, watches and Meals Ready-to Eat
-- it's all considered open season.
    "We've worked with American soldiers in the Gulf and
elsewhere," said Bouzar, a native of LeMans, France.
    "It's the same always -- a soldier speaks to another
soldier, 'What do you have for what I'll give?' and an
arrangement is made."
    The typical barter begins with a pleasant walk through the
Somali countryside, during which you may happen to come upon
two enterprising young men in a jeep.
    You might need a change in cuisine -- a French MRE perhaps.
And maybe these two soldiers have a need as well -- for your
hat.
    You may be willing to part with your hat; and if you are,
you'll be dining in the only French restaurant in Somalia --
first class, no jacket required.
    If not, it may be time to talk about those boots. It's an
exchange service limited only by your imagination, and how many
articles of clothing you are wearing.
    In fact, according to the French marines, in just three
days, dozens of such arrangements have been made.
    "We have not finished yet," said Bouzar. "We've only just
started to bargain. When we go back to Djibouti, we may only
have the uniforms we are wearing."
    The French marines are just part of a growing crowd of
international military converging on Somalia. Bouzar's group is
stationed in Djibouti, Africa, as part of an international
agreement.
    According to him and his friends, their stay in Somalia is
not unlike their regular station.
    "We have come from Djibouti," said Bouzar. "We know Africa;
we are French marines. Sure, maybe the culture is different,
but people are still the same. For us, nothing changes."
    (Rogers is in Somalia with the Joint Infromation Bureau in
Mogadishu.)

 555th medical detachment deploys to Somalia, by Spc.
Kim Rich

    MOGADISHU, Somalia (ARNEWS) -- One of the latest units to
deploy in support of Operation Restore Hope is hoping its
skills won't be needed by U.S. troops.
    The nine members of the 555th Medical Detachment from Fort
Hood, Texas, are a forward surgical team assigned to support
the 210th Forward Support Battalion, 10th Mountain Division
(Light Infantry) from Fort Drum, N.Y.
    "Our mission here is to support the troops," said Lt. Col.
Lawrence Runke, commander of the 555th. "We are capable of
standing alone without support for up to 48 hours and up to 40
major surgeries.
    "I think what we'll see -- if we see any type of injuries
at all -- will be injuries from sniper fire to troops. We could
see AK-47 injuries or mine injuries, and accidental injuries.
    "Since we're a surgical squad, we can't do anything if
nobody gets hurt, but it's good to have us here," said Staff
Sgt. Robert Simmons, the detachment's NCOIC. "We're not looking
forward to seeing people hurt, but we want to be here if it
happens."
    The 210th, Runke said, will have a 40-room hospital
facility, which will handle most non-emergency situations.
    "They will have the capability to handle non-surgical
problems," he said. "We have a two-bed capacity in our
operating room. We can do two surgeries at any one time."
    The team includes a general surgeon and an orthopedic
surgeon, as well as licensed practical nurses, registered
nurses, anesthetists, and operating room technicians. The
team's equipment, though, is fairly basic, which helps make the
team more mobile, Runke said.
    "From the time we hit the ground," he said, "we can be
operational within one hour. We can set up our tent and
equipment in an hour.
    "It takes about two hours to break it down to move. So we
truly are a rapidly deployable surgical unit."
    Despite its ability to move quickly, the 555th's mission
will be slightly different from what it would be in wartime.
    "We expect that we'll have less to do here than we would in
a real military conflict," Runke said. "If there was a true
advancing front line, we would follow that front line, and a
medical company would support us from the rear.
    "Anyone we operated on would be evacuated via aircraft or
ground ambulance to the (medical) company or to the evac
hospital."
    For Operation Restore Hope, however, the unit will be
fairly stationary.
    "We expect to stay wherever we go, because we'll be
attached to a medical company," Runke said. "But we're going to
set up as if we're going to have casualties immediately."
    If the team doesn't see many military casualties, it may
try to help out elsewhere.
    "I would hope that wherever we are, that if we don't have
military casualties, they will let us assist local hospital
facilities," said Runke. "They do have a shortage of personnel,
and I think we could offer something to them. But that's not
our mission -- we just hope it will become part of the mission."
     The unit is tentatively scheduled to move to Baledogle or
Kismayo.
    (Rich is in Somalia with the Joint Information Bureau in
Mogadishu.)


Keeping duties free of conflict of interest, by Alfred H.
Novotne

    WASHINGTON (ARNEWS) -- (EDITOR'S NOTE: New rules governing
ethics of federal personnel go into effect Feb. 3. Published
last August by the U.S. Office of Government Ethics in
Washington, the new rules apply to servicemembers as well as to
federal employees. In a series of update articles, Novotne
explores how the new rules will affect the federal workforce.
The first article, below, deals with "conflict-free performance
of duty." Novotne serves as an ethics attorney with the Army
judge advocate general's Standards of Conduct Office.)

    Federal personnel may not use their power as federal
officials to benefit any of their private interests. Such
conflict of interest constitutes criminal offense, as spelled
out in the U.S. Code.
    The law prohibits you, as a federal employee, from taking
any official action in a matter where you, your spouse or minor
child have a financial interest. Prohibited behavior stops not
at approval or disapproval of an action; it also includes
recommendations, advice, investigations or other actions that
could affect the outcome of an official activity.
    Obviously, the law's coverage is quite broad. So avoid such
traps as thinking that your non-involvement with government
contracts frees you from worry about conflicts of interest.
Many federal personnel have some responsibility to provide
input to official actions.
    Any time you take part in official matters that could
affect the finances or operations of a non-government entity,
you must be aware of the possibility of a conflict with your
personal interests. Congress intended the law to cover the
activities of all government workers to ensure that official
actions are always in the government's best interest and that
there is no private gain at the public's expense.
    Conflicts of interest can arise in a number of ways. The
three most common occur in connection with outside employment,
negotiation for employment, and investments.

Outside employment
    Generally, federal personnel need not get prior approval
for outside employment, although agencies do have the power to
require approval for those who work in sensitive positions.
    Of course, if your outside job interferes with the
performance of official duty, you can be required to terminate
the outside employment. Such interference could create a
conflict of interest.
    For example, if your part-time employer has an interest in
the activities of your office, then there's a real potential
for conflict of interest. When this occurs, the situation must
be resolved immediately, either by changing your duties or by
giving up your outside employment.
    If you're unsure whether a part-time job will create a
conflict, or if you believe a conflict has developed that must
be resolved, you should discuss the matter with your supervisor
and the ethics counselor assigned to your organization.
    Be aware, too, that a separate law imposes additional
limitations on outside employment. Aside from avoiding
conflicts of interest, federal personnel may not accept
positions where they would be representing private parties in
matters against or involving the federal government.

Conflicts when seeking employment
    Searching for a new job? Negotiation for employment creates
a special risk for conflicts of interest. The problem is that
when you discuss potential employment with a company, you have,
for all practical purposes, bought stock in that company. So,
if you could not own stock in that company while continuing to
perform your current duties without a conflict, then you may
not discuss future employment with them without causing a
conflict.
    This conflict arises from the very first contact, even if
you did not initiate it. Thus, when a company that could be
affected by the performance of your duties gives you an
unsolicited call about what you plan to do after leaving the
federal government, you must terminate the conversation, or
take immediate steps to have matters affecting that company
removed from your control.
    In addition to the above restriction, found in the criminal
code, the Office of Government Ethics has restricted "seeking
employment" that would conflict with your official duties. The
difference between "seeking employment" and "negotiating for
employment" is that when you're seeking employment, the
potential employer has not entered into discussions or shown
any interest in hiring you.
    That is, if you send one or more resumes to potential
employers, you're "seeking employment," but you are not
"negotiating for employment." Under the new rules from the OGE,
you would be considered to be seeking employment for up to two
months after you send the resume. During that time, you could
not perform any duties that would possibly favor the company
that you solicited. Thus, when you want to seek employment with
a company that could be affected by your duties, you should
always discuss these plans with your supervisor before taking
any action.
    On the other hand, if you've sent resumes to all potential
employers in a particular industry, you have triggered neither
the statutory nor the OGE restriction. In this case, you're
neither "seeking employment" nor "negotiating for employment,"
because you have not focused on particular employers. However,
that all changes when one of those employers responds to your
resume. You then have acquired an interest that can be the
basis for a conflict.
    Procurement officials also have additional restrictions on
whom they may contact about future employment, to protect the
integrity of government acquisitions. Federal personnel
involved in procurement may not contact competing contractors
about future employment during the procurement process without
getting prior written approval from the head of the contracting
activity.

Investments
    Sometimes investments can cause difficulty. If you're among
those who invest in stocks, be aware that you may not skirt
conflicts of interest by giving a broker power to make stock
purchases and trades on your behalf without seeking your
approval.
    Even if you have no knowledge of what stocks are in your
brokerage account, you're legally responsible for any conflicts
those stocks might create. As a federal person, you'll find it
much simpler to invest in mutual funds, certificates of deposit
or annuities.
    Legally, none of these investments has any potential to
create a conflict with your official duties. Although nothing
prohibits you from investing in individual stocks, you are
responsible for keeping close track of what stocks you possess,
and ensuring that those investments create no conflict.
    There's no such thing as a "minor conflict." You're
prohibited from owning even one share of stock, if your duties
could potentially impact that company. It matters not that the
company may be enormous, or that your input to an official
action is relatively small. A conflict is a conflict, whatever
the size. When a conflict arises, it must be resolved.
    Remember that avoiding conflicts of interest applies not
just to procurement officials or to those who work in
contracting offices. The rules apply to everyone who works for
the government.

Resolving a conflict of interest
    We have three ways to resolve a conflict of interest. The
first goes by the term "disqualification."
    To disqualify yourself from taking official action on a
matter, you first must notify your supervisor. Your supervisor
has the discretion to decide whether you can be released from
that aspect of your duties.
    If the request is approved by your supervisor, it would be
prudent to put the disqualification in writing. A written
disqualification statement should be circulated to any peers or
subordinates who might route prohibited matters to you.
    The second means of resolution consists of selling or
liquidating the outside financial interest that has led to the
conflict. When an employee's duties cannot be adjusted to avoid
a conflict, an agency may require this sort of divestiture.
When divestiture is required, taxes on capital gains resulting
from the sale of the asset may be deferred by OGE.
    Finally, in some cases, a waiver of the conflict may be
granted. The waiver must be granted in writing with a complete
explanation.
    Where practicable, the request for waiver first must be
coordinated with OGE officials. Not only must you get prior
coordination of the request; your supervisor has to be
satisfied that the conflict poses no substantial harm to the
integrity of your performance as a federal employee.
    In all such cases, you should contact your local ethics
counselor if you have any questions.


Gratuities and the public trust, by Alfred H. Novotne

    WASHINGTON (ARNEWS) -- (EDITOR'S NOTE: As the second in a
series of articles about the new federal ethics rules taking
effect in February, this piece focuses on how federal personnel
can avoid the pitfalls in accepting gifts from "outside
donors." Novotne serves as an ethics attorney with the Army's
judge advocate general's Standards of Conduct Office.)

Basic rules
    Under rules that go into effect Feb. 3, two prohibitions
apply to gifts from outside sources. First, federal personnel
may not solicit or accept gifts from a "prohibited source" --
that is, someone who has an interest in the employee's or
agency's work. Second, employees may not accept gifts that are
given because of their official positions.
    These prohibitions seem simple enough. However, the U.S.
Office of Government Ethics in Washington has created
exceptions to accommodate some common-sense situations.
    To determine if an exception applies, ask the following
questions: Does the item in question actually constitute a
"gift"? If it does, and if it's prohibited for either of the
two reasons cited above, does one of the listed exceptions
apply? And, even if an exception applies, would using an
exception undermine the integrity of the government?

Is the item actually a gift?
    OGE officials have excluded certain items from the
definition of "gift." These include --
    -- Modest food and refreshment that are separate from a
meal (the "coffee and donut" rule).
    -- Loans from financial institutions on normal commercial
terms.
    -- Commercial discounts or promotions available to the
general public, or to all government or military personnel.
    -- Prizes won in contests open to the general public,
unless the employee enters as part of his official duties.
    -- Greeting cards, plaques, certificates and trophies
having little intrinsic value.
    -- Travel expenses and gifts accepted by the Army, and
which belong to the Army.
    If the item being offered to you falls within one of these
categories, then it's not a "gift," and you may accept it --
except that in the last case above, you'll be accepting on
behalf of the Army.

Does an exception apply?
    The new rules do allow acceptance of what otherwise would
be prohibited gratuities, acknowledging that such circumstances
are unlikely to erode public confidence or affect a federal
employee's official judgment. Remember, however, that even if a
gift would be acceptable under one of these exceptions, it is
often more prudent -- and never inappropriate -- to decline a
gift offered by a prohibited source. The exceptions include the
following:
    -- Any unsolicited items, other than cash or its equivalent
(such as bonds or stock certificates), received on a single
occasion and having a total value of $20 or less, so long as
the total value of all gifts received from a single source
during a calendar year amounts to no more than $50.
    -- Gifts based on a family or personal relationship where
it is clear that the relationship, not the employee's official
position, is motivating the gift. Where the relationship is
based on official business contacts, even if amicable, or the
gift is charged to the giver's business account, then the gift
is presumed not to be based on a personal relationship.
    -- Gifts based on the employee's or spouse's outside
employment (such as travel expenses for a job interview), if
the gift is not given or increased because of the employee's
federal employment.
    -- Discounts or gifts offered to all government or military
personnel by a professional organization for its activities
when membership is solely based on professional qualifications.
    -- Discounts or gifts offered to a group or class whose
membership is unrelated to government service (e.g., the local
PTA gets discounts for an industry air show for all its
members).
    -- Discounts or gifts offered by employee associations
related to government employment (e.g., a federal credit union)
that are available to other members of the public through
similar associations.
    -- Discounts or gifts offered by non-prohibited sources
(organizations having no business ties with the Department of
Defense or no interest in DoD activity), so long as the gift
does not discriminate on the basis of higher rank or favor a
special class of select employees (e.g., a restaurant chain
offering a free steak dinner to all soldiers who assisted in
hurricane-relief efforts).
    -- Food, refreshments and entertainment at a social event
where the host is not a prohibited source and no fee is charged
to any person attending (this exception permits an employee to
attend social events even though the invitation is based on his
or her official position).
    Other OGE exceptions apply only with the approval of an
agency ethics official. These include the following:
    -- Legitimate awards that are part of a regular and
established program of recognition for meritorious public
service from a non-prohibited source when the value is more
than $200 (e.g., the Nobel Peace Prize given to a federal
employee for efforts supporting world peace).
    -- Free attendance at widely attended gatherings, where
attendance is determined to be in the agency's interest.
    -- Free attendance at training events sponsored by
tax-exempt organizations.
    Do not assume that you may use these last three exceptions
until after you've consulted with the ethics official assigned
to your organization and with your supervisor.

Would using the exception undermine government integrity?
    Even if a prohibited gift falls under one of the
exceptions, you may not use an exception if it will undermine
government integrity. OGE officials have identified four
situations where using an exception would undermine government
integrity. The first three situations are obvious:
    First, federal personnel may not solicit or coerce a gift.
    Second, any gift is improper if it is in exchange for an
official action. Solicitation of a gift in exchange for
official action constitutes illegal graft or bribery. Under
these circumstances, the item could be of small value, such as
a pen or coffee cup, and it would still be a criminal offense.
    Third, acceptance of gifts is prohibited if it would
violate some other provision of law (e.g., payment as a
supplement or addition to an employee's salary is prohibited
under a separate criminal statute).
    The fourth situation is less clear than the first three.
OGE officials have determined that use of a gift exception is
improper if the frequency of gifts from a particular source
would cause a reasonable person to believe the employee is
using public office for private gain.
    For example, it would be improper for a federal employee
who runs the concessions in a federal building to accept a free
sandwich from a concessionaire on a weekly basis. This creates
the appearance of impropriety. A reasonable person would
question whether this employee is using public office for
private gain.
    This also illustrates that "frequency" cannot be defined
precisely. If the concessionaire treats the employee to a
sandwich only occasionally during the year, it may be allowed
under the OGE $20 gift exception. The point at which the gift
becomes too frequent requires judgment; look at the
circumstances, the relationships of the people involved, and
the need for appearance of absolute impartiality.
    Unfortunately, this is not the only rule where some
subjective judgment must be exercised. To be safe, you should
consult with your supervisor. You'll find times when both you
and your supervisor will have to rely upon your organization's
ethics counselor for guidance.

Handling improper gifts
    If you've been offered or have accepted an improper gift,
you have several ways to resolve the situation.
    First and foremost, you can refuse the offer.
Diplomatically inform the donor that federal employees may not
accept certain gifts.
    If you cannot diplomatically refuse the gift, or have
accepted a gift and found out later that acceptance was
improper, you can correct the error by either returning the
gift or paying market value to the donor. "Market value" is
what the gift or a similar item would have cost you if you had
bought it.
    When it's impractical to return a gift because of its
perishability (e.g., a floral arrangement or perishable food),
it may, at your supervisor's discretion, be donated to charity,
shared in your office, or destroyed.
    If you act promptly to resolve an improper gift, no action
will be taken against you for violation of the gift rules. The
rules protect employees who act on their own initiative to
resolve an improper gift, or who promptly seek advice from an
ethics counselor on how to resolve the problem.
    However, if someone else discovers the problem first, and
complains that you've received an improper gift, you'll be
subject to punishment for violation of the gift prohibitions.
    If you have any questions about gift restrictions, contact
your local ethics counselor.


Ethics in the workplace: a navigation guide, by Alfred H.
Novotne

    WASHINGTON (ARNEWS) -- (EDITOR'S NOTE: This is the third of
a series of articles exploring the implications of newly
published ethics rules. Developed by the U.S. Office of
Government Ethics in Washington, the rules take effect Feb. 3.
Novotne serves as an ethics attorney with the Army judge
advocate general's Standards of Conduct Office.)

    Generally, any misconduct in the federal workplace violates
standards of ethical conduct. However, many types of behavior
-- such as sexual harassment, racial discrimination, nepotism,
alcoholism on the job, tardiness or insubordination -- are
covered by specific laws or regulations.
    U.S. Office of Government Ethics rules deal only with those
matters not covered by these other regulations. The OGE rules
treat two general areas: gifts among employees and misuse of
official position.

Gifts among employees
    The general rule on gifts among employees prohibits an
employee from giving a gift or making a donation toward a gift
for an official superior, and prohibits superiors from
accepting gifts from subordinates.
    An "official superior" is someone whose duties include
directing or evaluating the employee, or any superior in that
employee's chain of review. What's more, an employee may not
accept a gift from any other employee receiving less pay, even
if not in an official-superior relationship, unless there is a
personal relationship between the two people.
    OGE officials have created two exceptions to the gift
prohibition. Under the first, a subordinate may give or donate
toward a gift to an official superior on a special, infrequent
occasion. Such occasions generally are one-time or unusual
events, such as marriage or illness. A special occasion also
could arise from a transfer or retirement that terminates the
supervisory relationship.
    Gifts for special occasions must also be appropriate to the
occasion. However, the new rules do not define "appropriate."
This is another situation in which you'll have to seek guidance
from the ethics counselor assigned to your organization.
    Even though the gift might be permissible, the new rules
require that the solicitation for contributions to gifts to a
superior must be completely voluntary. If an amount of
contribution is suggested, it must be made clear that employees
may contribute a lesser amount or nothing at all.
    The new rules set no total-dollar limit on the size of a
gift to a superior. The Department of Defense may, in
supplemental regulations, set a firm dollar limit on
contributions.
    The second exception permits gifts on an occasional basis,
including traditional gift-giving occasions. This exception
allows such nominal gifts as contributions for food that will
be consumed at the office, meals at an employee's home (of a
type and value customarily provided to personal friends), and
customary gifts like a bottle of wine, brought when invited to
another's home.
    How about infrequent gifts having a value of no more than
$10 on appropriate occasions, such as Christmas or birthdays?
Yes, they're still allowed; but if such gifts should become
"routine," the exception will not apply. In a sense, this
affirms the policy that gifts must be voluntary. No federal
employee may be required to give gifts to the boss on each
holiday and birthday.
    Finally, this second exception provides that the donation
of annual leave by employees under applicable regulations is
not an improper gift, even if given to a superior. However, the
superior may not be the employee's immediate supervisor.

Misuse of position
    The OGE regulations on misuse of official position address
five areas:
    -- Use of public office for private gain.
    -- Improperly creating the appearance of government
sanction.
    -- Use of non-public information.
    -- Use of government property.
    -- Use of official time.
    For each area of possible pitfall, here's a rundown on what
applies:
    -- Using public office for private gain. The rules prohibit
employees from using their titles, positions or authority of
their positions for the private gain of themselves, their
families or friends, or organizations with which they're
affiliated. Thus, an employee would be prohibited from using
his position to provide special handling of a friend's travel
claim, even if the friend's claim was fully warranted.
    -- Improper appearance of government sanction. Federal
personnel shall not permit their official position, title, or
authority to be used to imply that the government sanctions or
endorses a private activity.
    Some commercial and charitable organizations are eager to
secure government endorsement for their products or activities.
Even when a private organization has rendered great service to
the government, employees must guard against giving an
endorsement that could be misused.
    Some charitable organizations do have special status
because of their support of military personnel or goals.
However, endorsement or sanction of any such organization is
carefully regulated.
    Official endorsement of a charitable activity must be
approved at Army and DoD headquarters. Federal employees may
privately endorse and support charities and civic groups, but
must be careful not to allow their status as a federal employee
to be included in the endorsement.
    Federal employees may use their official titles in
connection with some limited private activities, when the title
is used as an ordinary term of address -- such as "Justice
O'Connor," or "Major Smith." Once again, personnel must be
careful that such use does not imply government sanction for
the activity.
    -- Use of non-public information. The rules prohibit an
employee from using non-public information for his own or
another's benefit.
    "Use" includes not only releasing non-public information
but also giving advice or taking action based on such
information. "Non-public information" is simply any information
that has yet to be released to the public, even though it may
be released sometime in the future.
    Non-public information also includes classified and
sensitive information. Employees should use special care in
protecting this type of information.
    An example of "sensitive" information would be the content
of proposals submitted by government contractors. Although this
information is not classified, it is highly sensitive; and
unauthorized release or use of procurement-sensitive
information could result in criminal penalties.
    -- Use of public property. A federal employee has a duty to
protect and conserve government property, and not allow its use
for other than authorized purposes.
    Thus, it would not be proper for a supervisor to ask an
employee to type a personal letter during duty hours, or to
personally use a government computer and printer for the
letter. Similarly, photo-copy machines may not be used for any
personal activities, such as a civic group or church in which
you're a member.
    In certain limited circumstances, telephones may be used
for local personal calls, so long as they do not interfere with
official activities. For example, you may call your child's
school to explain why she was late that day, but you may not
have an extended conversation with her teacher about the
math-study program. Personal long-distance calls may be made if
charged to the employee's calling card or home phone number.
    Finally, gambling is prohibited on government property.
This includes office sports pools.
    -- Use of official time. Federal personnel must make an
honest effort to devote official time to official duties.
Employees may not actively pursue personal activities while at
work and on the job.
    For example, you may not run a part-time landscaping
business and receive customer calls at work. In a similar
fashion, you may not solicit co-workers to patronize your
outside activity. This includes soliciting, during duty hours
in the office, the purchase of life insurance, kitchen
products, personal-care items, and candy or cookies to support
a civic or youth group.
    If you have any questions about the new ethics rules as
applied to the workplace, you should contact your local ethics
counselor.


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