From: EXIM Announcements

Sent: Wednesday, March 16, 2022 12:12 PM

To: EXIM Feds

Subject: Ethical Insights - a brief to the EXIM workplace: March 16, 2022

EXIM ONLINE

Vol. 5, No. 3, March 16, 2022

In this Issue: Up, Up, and Away

Plane taking off

Dust Off Your Airplane Wing Pins and Slip On Your Travel Shoes

This issue is brought to you by the Office of Ethics and the Travel Office! We anticipate that EXIM employees will start to travel more for official business in 2022. Official travel is a metal bird of a different feather and there are rules you need to know before jetting away on government business.

Before Takeoff

For EXIM official travel, you must want get all the right approvals in advance.

Official Travel Expenses. If an event sponsor has made an offer to pay your official travel expenses, you will need agency approval to accept it before you fly. An employee may not ask for a sponsor to pay travel expenses but may inform a sponsor about the ability for EXIM to accept them.

EXIM may accept sponsor-paid expenses under two authorities: 1) the government-wide travel authority for attending a conference or seminar in one's official capacity; or 2) a specific EXIM authority which allows the agency to accept travel payments for mission-related meetings and similar events. These typically include transaction related meetings such as, site visits, audits, inspections, and more.

No matter who pays for official travel, EXIM employees follow the same travel regulations set by the General Services Administration (GSA) and the ​pdf icon EXIM Travel Policy.

The Fly America Act provides that U.S. government employees must book American air carriers when using federal travel funding. However, if a non-government sponsor pays for a flight, a non-American carrier may be used.

Free Attendance at Widely Attended Gatherings (WAGs). You might receive an invitation to an event separate from the official business of the trip. Free attendance to an ancillary event is likely a gift and could qualify for the WAG exception, but you'll need advance approval. Before flying, submit event invitations and details to the ethics office for review so you can be approved for all activities you'd like to attend while you're on location.

CONCUR. EXIM uses this system as the hub for all travel-related logistics. Before leaving on travel, CONCUR is where you book flights and seek approval for sponsor-offered gifts of travel expenses. Accuracy is important for a successful trip, which makes documentation for each aspect of the trip essential. It is highly recommended that employees who travel on EXIM business take the CONCUR training offered by the Travel office.

During the Trip

Personal Time on Official Travel. Stuck in a hotel conference room in Prague and you can't sample the local sights or food? Sometimes work trips send us places that would be great to explore but we have a full schedule of official duties. However, with some planning, an employee can combine personal travel with official travel. Business matters come first in official travel but there is a way to arrange for you to be "on your own time" in a place you'd like to explore before coming back to the office. You may even be able to extend your trip. Interested employees must consult with the travel office to make appropriate arrangements. Any such personal travel cannot increase the cost to EXIM.

Fly Coach. The general rule is to fly coach class. Government travel policy provides that non-coach seating (e.g. business class) is permitted only under limited circumstances. For flights of more than 14 hours—wheels up/wheels down— or with a documented medical need, an employee may be approved to fly something other than coach.

Gifts Given In-Person. Gifts are frequently given to EXIM staff on travel. They can come in the form of meals, gift bags, souvenirs, and more. For gifts from foreign governments, employees should graciously accept and report the gift upon returning to their duty station for processing. Gifts from prohibited sources may only be accepted if valued at $20 or less.

Some gifts could be approved during your trip if they are in the agency's interest and other factors are met. For example, what if a fellow conference attendee invites you to a networking event outside the scope of the conference you are approved to attend? You should reach out to the ethics office to advise whether you could attend for free under the WAG rule. Absent an approval, paying fair market value for admission to the event is permitted.

Per Diem. While on government-paid travel, employees are given a "per diem" amount of funding to cover expenditures such as lodging, meals, and other incidental expenses. Employees may not exceed the per diem amount. If you are traveling on sponsor-paid travel, you may not submit a voucher for reimbursement of your travel expense. This "double-dipping" is illegal.

Care for Your Government Equipment. Government-issued equipment and resources are for official business only. Be sure to take personal equipment like electronics or other travel gear for your personal needs. Travelers to foreign countries must get clearance from IT well before taking their government equipment overseas.

Back Home

Report Gifts. Tangible items will often fall under the restrictions against accepting gifts and should be reported using our online gift form within 3 days of returning to the office from travel.

CONCUR. Employees complete their travel when the final entries and expenditures are recorded in CONCUR. One important task is to file vouchers and receipts from the trip within 5 days of returning from travel. Sponsor-paid expenses, especially in-kind items are sometimes difficult to value and should be documented with receipts. Documentation is essential.

EXIM Connect: Ethics | Travel

ASK ETHICS

What does agency approval for sponsor-paid travel cover?

EXIM can only approve sponsor-paid expenses in advance. This means any "surprise" costs that might arise while on travel (e.g., an upgraded hotel suite) are not covered by the original approval. An appropriate response to an offer to cover a new or different travel expense is for the employee to politely advise that they are only authorized to accept the original approved offer of in-kind travel expenses.

What if I want to conduct unrelated official business while on sponsored travel?

It is possible to combine a sponsor-paid trip with other official EXIM business. Sometimes, a trip may consist of a conference or other sponsored meeting as well as an official EXIM function like business development or a site visit that is unrelated to the sponsor's reasons for paying for your trip. Work with the travel office to delineate how the costs will be paid.

Upcoming Dates & Deadlines

In March 2022 -

  • A KNOW EXIM session on this month's newsletter topic will be held on the 24th.

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EXIM Office of Ethics | Room 857 | 202.565.3195
EthicsAdvice@exim.gov


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 Terry

Lisa V. Terry
Senior Vice President &
Chief Ethics Officer

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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