Contractor-Sponsored Events: Navigating through the Rules

By Moorhouse, Dick; Hickey, Dave | National Defense, August 2005 | Go to article overview

Contractor-Sponsored Events: Navigating through the Rules


Moorhouse, Dick, Hickey, Dave, National Defense


The ethics culture in Washington, D.C., during recent decades has become encrusted in a bewildering array of statutes, regulations, guidelines, policies, procedures, assorted memoranda, brochures and bulletins. Federal contractors and their government customers must navigate these ethics rules daily. Contractor-sponsored events that involve federal employees require special planning considerations. Published guidance often relies on broad objective standards of conduct, such as avoiding the "appearance of impropriety" or "apparent conflicts of interest." Or it simply recites complex regulatory language.

Event sponsorship triggers federal rules that generally bar contractor gifts to Defense Department personnel. Government employees in fact may accept something of value from outside sources if it is not a "gift" or if it falls within the widely attended gathering or event exception (or something similar).

When invoking the widely-attended gathering exemption, the following considerations should be examined: the nature of the event, the role and capacity of the government employees attending the event and the specific, sponsored activities and "takeaways" that comprise the event. Company-sponsored social events commemorating a historic military milestone, for example, differ from seminar speaking invitations to a Defense Department official. Government attendees also should understand the difference between attendance in an official capacity, or in a personal status. Finally, a breakdown of all logistical elements is necessary, such as any food, refreshments, entertainment, materials, plaques, travel, lodging and other items of value that will be furnished.

Defense Department employees are permitted to attend events where it is in the interest of the agency or its operations. In approving an event, ethics officials will focus on certain key factors, such as the number of attendees (100 is the benchmark), market value of free attendance, nature and diversity of attendees (all from one contractor or broader community), and whether there is a legitimate government purpose for attending.

For example, many events sponsored by trade associations can be approved under a "community relations" rationale if it does not interfere with government duties or favor one entity over others, and does not support a profit-making function. In many cases, a supervisor must make a written determination permitting attendance. Contractors can and should assist an employee in obtaining approval by providing pertinent information. Ultimately the government employee bears responsibility for accepting free attendance in consultation with the employee's ethics office.

Defense Department personnel can properly deliver a speech in an official capacity, but they may not participate in fundraising in an official capacity and should not officially endorse non-federal organizations. Employees also may be barred from making an official speech that affects the financial interests of the sponsoring organization. …

The rest of this article is only available to active members of Questia

Already a member? Log in now.

Notes for this article

Add a new note
If you are trying to select text to create highlights or citations, remember that you must now click or tap on the first word, and then click or tap on the last word.
One moment ...
Default project is now your active project.
Project items

Items saved from this article

This article has been saved
Highlights (0)
Some of your highlights are legacy items.

Highlights saved before July 30, 2012 will not be displayed on their respective source pages.

You can easily re-create the highlights by opening the book page or article, selecting the text, and clicking “Highlight.”

Citations (0)
Some of your citations are legacy items.

Any citation created before July 30, 2012 will labeled as a “Cited page.” New citations will be saved as cited passages, pages or articles.

We also added the ability to view new citations from your projects or the book or article where you created them.

Notes (0)
Bookmarks (0)

You have no saved items from this article

Project items include:
  • Saved book/article
  • Highlights
  • Quotes/citations
  • Notes
  • Bookmarks
Notes
Cite this article

Cited article

Style
Citations are available only to our active members.
Buy instant access to cite pages or passages in MLA, APA and Chicago citation styles.

(Einhorn, 1992, p. 25)

(Einhorn 25)

1. Lois J. Einhorn, Abraham Lincoln, the Orator: Penetrating the Lincoln Legend (Westport, CT: Greenwood Press, 1992), 25, http://www.questia.com/read/27419298.

Cited article

Contractor-Sponsored Events: Navigating through the Rules
Settings

Settings

Typeface
Text size Smaller Larger Reset View mode
Search within

Search within this article

Look up

Look up a word

  • Dictionary
  • Thesaurus
Please submit a word or phrase above.
Print this page

Print this page

Why can't I print more than one page at a time?

Help
Full screen

matching results for page

    Questia reader help

    How to highlight and cite specific passages

    1. Click or tap the first word you want to select.
    2. Click or tap the last word you want to select, and you’ll see everything in between get selected.
    3. You’ll then get a menu of options like creating a highlight or a citation from that passage of text.

    OK, got it!

    Cited passage

    Style
    Citations are available only to our active members.
    Buy instant access to cite pages or passages in MLA, APA and Chicago citation styles.

    "Portraying himself as an honest, ordinary person helped Lincoln identify with his audiences." (Einhorn, 1992, p. 25).

    "Portraying himself as an honest, ordinary person helped Lincoln identify with his audiences." (Einhorn 25)

    "Portraying himself as an honest, ordinary person helped Lincoln identify with his audiences."1

    1. Lois J. Einhorn, Abraham Lincoln, the Orator: Penetrating the Lincoln Legend (Westport, CT: Greenwood Press, 1992), 25, http://www.questia.com/read/27419298.

    Cited passage

    Thanks for trying Questia!

    Please continue trying out our research tools, but please note, full functionality is available only to our active members.

    Your work will be lost once you leave this Web page.

    Buy instant access to save your work.

    Already a member? Log in now.

    Author Advanced search

    Oops!

    An unknown error has occurred. Please click the button below to reload the page. If the problem persists, please try again in a little while.