Education through Training & Advice

Ethics education is an essential tool in helping agencies and employees manage and minimize the risk of ethical failure. An agency’s ethics education program increases employees’ awareness of their ethical obligations, helps them identify ethics issues that may arise in the work they perform, and provides employees guidance and support for making ethical decisions. Through education, ethics officials assist employees in fulfilling their responsibility to act at all times in the public’s interest and avoid losing impartiality or appearing to lose impartiality in carrying out their official duties.

Responsibilities of the Designated Agency Ethics Official (DAEO)

The DAEO, acting directly or through other officials, is responsible for carrying out an effective government ethics education program for the employees of the agency. An agency educates its employees through a combination of targeted notices, training, personalized ethics advice, and ongoing agency communications. To be effective, the DAEO assesses ethics risks, identifies employees most at risk, and delivers training and counseling that is directly responsive to the risk those employees face.

Among the specific responsibilities, the DAEO:

• Issues ethics notices to prospective employees and new supervisors
• Conducts initial ethics training for new employees
• Provides additional ethics briefings for certain agency leaders
• Provides annual ethics training for certain employees
• Advises prospective and current employees regarding government ethics laws and regulations
• Provides former employees with advice and counseling regarding post-employment restrictions

The DAEO may establish additional requirements for the agency's ethics education program to help employees with increased or acute risks of facing ethics challenges to better manage those risks. In agencies with 1,000 or more employees, the DAEO coordinates with any other offices that have responsibility for issuing ethics notices or conducting training.

Key Legal Authorities

• 5 C.F.R. § 2635.107 - Ethics advice to employees
• 5 C.F.R. § 2638.104(c) - Responsibilities of the DAEO
• 5 C.F.R. part 2638, subpart C - Government ethics education requirements

Key Advisories

LA-16-09: Job Aid: Overview of Education Requirements under the Revised 5 C.F.R. Part 2638, Subpart C (PDF)

This legal advisory provides a job aid to help ethics officials familiarize themselves with the government ethics education requirements under the revised 5 C.F.R. part 2638.

PA-19-05: Ethics Education: Using the Regulation to Maximize Effectiveness (PDF)

This program advisory advises ethics officials of ways that they can use the ethics education regulations to maximize the effectiveness of their agency’s ethics education programs.

PA-16-11: Requirement: Ethics Notices for Prospective New Employees and New Supervisors (PDF)

This program advisory describes two notification requirements for prospective new employees and new supervisors.

For additional advisories, search the Legal Research Collection

Resources

Agency Practices

As the supervising ethics office, OGE has insight into the methods, procedures, and practices of over 140 agency ethics programs and seeks to highlight these practices as a resource for improving ethics programs across the executive branch. The following practices are gathered from OGE program reviews, agency responses to Annual Agency Ethics Program Questionnaires and data calls, and OGE summits and conferences. While no single approach is one-size-fits-all, ethics officials may find other agencies’ practices useful to the effective and efficient administration of their own ethics program.

• Incorporate the Oath of Office into initial ethics training for new employees as a way of introducing expectations for ethical service.
• Preload ethics webpages and/or ethics program applications on agency desktops and agency mobile smart devices to provide information about financial disclosure forms, required ethics approvals, prohibited holdings, and agency ethics staff contact information. Alert new employees about the page/app during onboarding and initial ethics training.
• Use and adapt OGE's library of training scenarios to help ensure training is relevant and engaging. See above under "Strategic Communications”.
• Incorporate ethics training into the agency’s e-learning management system.
• Use financial disclosure filing as a training vehicle by building training modules around the filing process.
• Assess ethics risks across the agency and develop appropriate ethics education tools to mitigate the risks identified. To assess risk, ethics officials can review advice logs for common issues, discuss upcoming work and agency priorities with senior staff, talk to program managers about risks inherent in their work, conduct surveys to identify common and emerging ethics risks, and talk to employees about the ethics concerns they encounter in the workplace.
• Provide specialized training to groups that may face unique ethics situations: supervisors, grant reviewers, public affairs specialists, scientists, procurement officials, IT personnel, etc. Also provide specialized training for non-employees, such as contractors, foreign nationals, partner organizations, etc.
• Mandate annual ethics training for all employees, not just for those required by regulation.
• Include an evaluation after each training for employees to provide feedback on the instructors and the training’s relevance and clarity (example of a short evaluation (Word Doc), example of a long evaluation (Word Doc)).
• Alert supervisors to the availability of tailored ethics training, upon request, to any agency division or branch.
• Develop training for employees with the assistance of seasoned ethics officials from other agencies.
• Schedule recurring lunchtime and teleconferencing events to provide information on seeking employment, post-employment, and other common counseling topics.
• Place ethics posters in rooms where employees congregate and where decisions are made, for example, lunchrooms, conference rooms, and kitchens. OGE has created posters which agencies can customize with agency contact information and a URL for the agency ethics page. See above under "Strategic Communications".
• Include the ethics office in the agency’s official public organization chart to ensure employees are aware of the importance of the ethics office.
• Maintain regular engagement with agency employees using newsletters, targeted emails, advisory memos, webcasts, electronic bulletin boards in common areas, lunchtime trainings, and teleconferencing events. Rotate ethics messages to appear upon signing into the workplace computer, with common counseling topics, such as seeking employment, post-employment, gifts between employees, and conflicting financial interests.
• Incorporate ethics topics into regularly scheduled staff or division meetings, for example by providing the ethics program a standing 5-minute slot on the agenda.