DAJA-SC, Information Paper, Subject: Private Organizations (13 August 1998)

Article excerpt


13 August 1998

SUBJECT : Private Organizations

1. PURPOSE: To provide information on relationships with non-Federal entities (NFE)


a. Personal Participation - Permitted Activities

(1) DoD employees, acting in their personal capacity, may join and participate in NFE activities.

(2) DoD employees may become officers and directors of private organizations provided that the positions are not offered solely because of their Federal position and that they act exclusively outside of their official position. If the employee files an SF 278 or an OGE 450 financial disclosure report, the position as a NFE officer must be reported.

(3) DoD employees may engage in fundraising on behalf of NFEs provided that no DoD endorsement is implied, and as long as they do not personally solicit prohibited sources or their subordinates.

(4) DoD employees may make presentations and publish papers as part of NFE activities. If the presentation or paper deals with DoD operations or policies, there must be a disclaimer that the views presented are personal and do not represent DoD.

(5) Subject to supervisory approval, DoD employees may use official time and material to prepare presentations and papers for non-profit associations and learned societies.

(6) DoD employees may represent a NFE which is composed of DoD employees and their dependents in discussions with the Government except when the matter involves an administrative or judicial proceeding or the disbursement of funds.

b. Personal Participation - Prohibited Activities

(1) Subordinates may not be coerced to join or participate in NFE activities.

(2) An employee's official position may not be used to state or imply official endorsement of a NFE, its activities or fundraising efforts.

(3) DoD employees who are officers or directors of NFEs in their personal capacity may not participate in official Federal actions which affect the interests of the NFE.

(4) DoD employees may not represent ordinary NFEs (as opposed to NFEs composed of DoD members) in discussions with the Government.

(5) As a matter of personnel policy, the Deputy Secretary of Defense has directed that General Officers may not receive compensation for serving as NFE officers or directors.

c. Official Relationships - Permitted Activities

(1) Attendance. Consistent with sound fiscal principles governing training expenses, DoD employees may attend meetings, conferences, seminars and similar events sponsored by NFEs, and may participate as panelists and speakers. DoD employees may not attend such events at government expense solely to acquire or maintain professional credentials that are minimum requirements to hold a DoD position.

(2) Liaison. DoD employees may serve as liaisons to NFEs when appointed by the appropriate commander. Liaisons may represent DoD in discussions, but cannot bind their DoD organization to any action. …