In this Issue: Rules of Engagement
Welcome to your monthly newsletter. Our goal is to
enhance the agency's ethics education by bringing you helpful
information, insights, and updates. We are here to support you
and hope this format is an enjoyable way for you to stay informed
and ethical!  We Do Our Best Work When We're at Our Best
The Biden Administration has asked EXIM and its
interagency partners to expand their presence in the U.S. and
abroad. Our expansion may take us into new and different areas,
but we will still follow the same credo: we do our best work when
we abide by our shared values. In this issue, we will discuss the
rules of engagement for EXIM employees as we conduct business and
build relationships with a wide variety of individuals, groups,
and companies this year.
Our Value System
Time and again, EXIM employees have agreed to a core
set of values as drivers for our agency's success.
• Integrity
• Accountability
• Stewardship
• Commitment to Excellence
• Customer-Focused
• Innovation
• Equity
• Leadership
The EXIM Code of Business Conduct and Ethics, which
all employees acknowledge and agree to uphold, explains how we
adopted these values and what they mean to us as an agency
community. EXIM's Strategic Plan also embodies these values.
Part of our value system is a commitment to the
various federal employee ethics rules and regulations, many of
which are included in the Standards
of Ethical Conduct for the Employees of the Executive Branch. Below are a few examples of how they apply to
expanding our presence in the U.S. and abroad.
Rules of Engagement.
Let's
Make It Official
Developing business contacts takes many forms. Some
conversations build your personal network while others relate to
your official duties. If these conversations are taking place
using personal means, like a social media account or personal
phone number or email address, you'll want to know when it's time
to "make it official."
Conversations in personal channels that turn to
official business must be moved into EXIM platforms. Examples of
EXIM accounts include an exim.gov email address, EXIM's newly
updated website, or any of EXIM's official social media accounts.
Making conversations official will remove doubt of whether you
are speaking personally or officially and also help employees
conform to the federal records management policy, available on the intranet (see
especially part 6.6).
Professional networking social media services, such
as LinkedIn or Monster, deserve special mention. Your accounts on
these sites are considered personal even though they are often
used to develop business relationships. You need to make a
judgement call when a conversation within one of these services
qualifies as an official communication and move it into an EXIM
platform. For example, a conversation turns official when it goes
beyond mere pleasantries and get-to-know-you topics and moves
into EXIM business, setting a meeting, or other activity you
perform in your official duties.
Spontaneity Is the Spice of Life…Unless
it's Too Spicy?
Unexpected activities or gifts can boost a
relationship. Government employees must try not to get caught up
in the moment of receiving a gift. The ethics rules allow EXIM
employees to accept gifts only under limited circumstances, if at
all. In no circumstances may an employee solicit, or ask for, a
gift or any other benefit because of their government position.
Free Attendance to Events. You might receive an invitation for free attendance
to an event where business contacts are gathering. An event could
be many things, ranging from a dinner to a professional
conference. Invitations are sent to employees in advance or at
the last minute. In any case, you will need to seek ethics advice
prior to accepting the invitation and attending the event. For
example, if the event qualifies as a Widely Attended Gathering
(WAG), the ethics rules require that an employee receive prior
written approval from an ethics official. For official travel,
the best practice is to submit approval requests prior to leaving
town.
Tangible Gifts. What a treat to receive a gift, and they even
bothered to wrap it! EXIM employees, in most circumstances, may not
accept a gift from a business contact. Agency policy says
employees should attempt to graciously decline any gift when
offered. Sometimes declining a gift is not possible (due to
awkwardness, for example), and it may be accepted but immediately
reported. On the contrary, EXIM employees should always accept
gifts from foreign government officials. Any accepted gift is
reported using the online
gift form.
Resolve Your Conflicts Before Making Big Decisions
Expanding EXIM's presence might create opportunities
to think outside the box or expand the agency's outreach. Two
important ethical guardrails define the limits of an employee's
actions.
The criminal conflict of interest statute protects
government decision-making, keeping an employee's financial
interests out of government matters. The rule states that an
employee is prohibited from participating personally and
substantially in a particular Government matter that will affect
their own financial interests, as well as the financial interests
of certain individuals with whom they have ties outside the
Government.
The impartiality regulations offer a similar
protection, but instead of financial interests, they protect
government decision-making from the influence of strong personal
relationships. These rules ask federal employees to consider
"appearance" issues. The rule says that an employee should
consider appearance concerns before participating in a particular
matter if someone close to the employee is involved in that
matter.
When You Should Seek Counseling
The Office of Ethics is always available to answer
your questions and concerns. Ethicsadvice@exim.gov. We
also have resources on the web. You can find us on EXIM Connect
here: Ethics
ASK ETHICS
What if I want to discuss EXIM services with my
brother-in-law's company?
These discussions would probably be permissible so
long as the company did not receive special treatment or
nonpublic agency information. As noted above, EXIM employees may
not participate in official matters when the employee has a close
relationship with a party to the matter. The outcome may depend
on whether these discussions are the type of matter covered by
the ethics rules, what actions the company intends on taking
based on the shared information, and whether the brother-in-law
has a close relationship to the employee and is a party to the
discussions. The EXIM employee would also want to make sure they
give the company the same opportunity as other similarly situated
companies.
Can I attend an event to boost my professional
network if I was only told about it at the last-minute?
Attending an event for free is likely a gift that
needs prior written approval. It is possible to get ethics advice
in a short turnaround time. We are attentive to the Ethicsadvice@exim.gov email inbox and can potentially help you. However, in case we
cannot, you could always attend the event and pay the sponsor the
fair market value of your attendance.
Upcoming Dates &
Deadlines
In June 2022 -
A
KNOW EXIM session on this month's newsletter topic will be held
later this month
|
About
the
Office
of Ethics
The
Office of Ethics was established by the 2015 EXIM Charter. The
Office of Ethics staff is available at any time to provide advice
and counsel to employees and managers on any ethics questions,
including: personal and financial conflicts of interest; gifts;
seeking and negotiating other employment; engaging in outside
activities; financial disclosure reporting; political activity;
and, post-employment restrictions.
In
accordance with the Charter, the Senior Vice President and Chief
Ethics Officer, Lisa Terry, serves as the Designated Agency Ethics Official
(DAEO). She oversees EXIM's federal ethics program and
administration of EXIM's ethics program.
The DAEO,
along with the Alternate Designated Agency Ethics Official
(ADAEO) Lance Mathews, coordinates with the Office of Government Ethics
and manages the day-to-day activities of the Office of Ethics.
Both the
DAEO and ADAEO, as well as ethics counsel, Stephen Grimes and Debra Zusin, are available at any time to provide advice and
counsel to employees and managers on any ethics questions.
The
Office of Ethic's program specialist, Gabrielle Guy, provides Ethics' program specialist, provides
administrative support, including serving as system administrator
for the Integrity and Financial Disclosure (FD) online systems.
When
contemplating any action that may be covered by the ethics rules,
always seek the advice of the Office of Ethics at EthicsAdvice@exim.gov.
Lisa V. Terry
Senior Vice President &
Chief Ethics Officer
Office of Ethics Staff:
Lisa V. Terry
Senior Vice President &
Chief Ethics Officer (DAEO)
Lance Mathews
Deputy Chief Ethics Officer (ADAEO)
Stephen
Grimes
Attorney-Advisor, Ethics
Debra Zusin
Attorney-Advisor, Ethics
Gabrielle Guy
Program Specialist |
