January 8, 2024
Shelley Finlayson, Acting Director and Program Counsel
As we usher in a new year, it is a busy period for the government ethics program. The annual communication and training cycle restarts. Both the annual confidential and public financial disclosure cycles begin. And, this year, preparations accelerate for the Presidential election cycle.
The new year also highlights another cycle: the career lifecycle of federal employees. Even before a federal employee’s very first day on the job, the ethics program is already at work protecting that employee and the government from possible ethical lapses. Agencies are required to notify prospective employees that they will be subject to the ethics rules and regulations, and to the applicable financial disclosure requirements. Once an employee comes on board, the ethics program is one of the first touchpoints for that new employee. Within a few days, the employee should receive a new employee ethics orientation, introducing the employee to the ethics rules and procedures, and ensuring the employee knows where to go for help with ethics questions throughout their career.
As an employee’s responsibilities grow, the ethics program continues to help them avoid ethics pitfalls. If, an employee is promoted or assigned to duties that would create a possibility for financial conflicts of interest, the employee will be asked to begin filing financial disclosure reports. Some employees will complete confidential financial disclosure reports upon entering a filing position and then file annually in February thereafter. While other, more senior employees, will complete public financial disclosure reports. They file upon entering the position, then file annually on May 15th, and upon termination of the position. They also file anytime they have a qualifying financial transaction. These reports are used to identify potential conflicts of interest with the employee’s duties and ensure that employees take necessary steps to avoid them.
All of these financial disclosure filers are also obligated to receive annual ethics training from their agency ethics offices. This intervention helps prepare employees to manage ethics risks they are likely to encounter in their day-to-day work.
The ethics program is available to support employees, not just once or twice a year, but every single day, by providing advice and counseling as ethics challenges emerge. Every employee, regardless of rank or position, has access to ethics officials who can help them navigate ethics challenges, big and small. Whether it is a question about accepting lunch from a colleague or a possible conflict of interest resulting from the issuance of a multimillion-dollar contract, ethics officials are ever ready to assist and support. This as-needed support can be especially helpful as an employee winds down a federal career. The ethics office is ready and able to help employees navigate the process of finding post-government employment without violating any ethics standards.
This support continues even after executive branch employees leave federal service. Former employees who need help understanding the obligations of the post-government-employment restrictions are entitled to advice from their former agencies to help them comply with applicable restrictions.
For their entire career lifecycles, the ethics program helps and supports federal employees. Without these interventions we could not protect the public trust. I’m grateful to the employees who honorably carry out their duties and comply with and seek out ethics support throughout their careers and to all of the ethics officials who are hard at work helping prospective, current, and former government officials serve our country honorably and in compliance with ethics laws and regulations.