Ethics: Sponsorships Use, Events/Fundraisers 2014 MDRT Conference Atlanta, GA Facilitators: Renaye Waller & Diane Sharp

Always Safe to Use ‘Internal’ Prizes Executive Parking Space Lunch with Boss ETHICS – “Would you be comfortable if this appeared on the front page of your local newspaper?” Ensure your staff and volunteers are aware of legal and ethics concerns Plan ahead and/or standardize Be CONSISTENT Know the rules, be informed No two General Counsel and/or Ethics Officers ever interpret a regulation the same way Get approval ahead of time to avoid stress and/or issues Ethics: Sponsorships Use, Events/Fundraisers

The Directive dated March 28, 2012, prohibited campaigns from spending CFC CFC funds on food, beverages and entertainment. Campaigns are prohibited from incurring expenses or seeking reimbursement using CFC funds for food and/or entertainment from that date forward. The directive prohibiting paying for food and entertainment from CFC funds does not prohibit reimbursement for travel costs incurred by an individual needed in order to conduct CFC business or attend a training event. No expenses for entertainment during the travel may be charged to or reimbursed by the CFC. As always, expenses must be preapproved by the LFCC. If you and/or the LFCC are concerned about whether the cost of planned travel is reasonable and reimbursable, please seek guidance from OCFC. Ethics: Sponsorships Use, Events/Fundraisers

The reasonable costs of items such as room rental, balloons, programs, etc, are permitted if approved by the LFCC. In its review of these expenditures, the LFCC should consider whether the expenses are reasonable and whether they promote the goal of securing the most funds possible for the charities designated by CFC donors. When in doubt, the OCFC is available to offer guidance. Can the CFC charge donors to attend an event? The fee would cover the cost of food and/or entertainment. Yes. However, the expenses and the revenues cannot be accounted for as CFC funds. The PCFO or the Federal agency where the event is held must provide the financial support in advance and be the point of reimbursement from employees. The CFC cannot incur the expenses in advance, even if it will be fully reimbursed from attendance fees at a later date. Attendees must be informed that the fee is not a CFC contribution and is not tax-deductible. Ethics: Sponsorships Use, Events/Fundraisers

Are food/entertainment expenses permissible if they are provided by a business or another source and not charged to the campaign? Food and/or entertainment may be provided at campaign events if the costs are not borne at any time by the CFC. CFC Memorandum provides additional information on the accounting for such expenses. The phrase “campaign events” for these purposes means events that are open to all potential donors with the purpose of encouraging them to make a contribution or to thank them for their participation. Campaign events also include award ceremonies. Campaign events do not include LFCC meetings, LE or keyworker or other campaign personnel trainings or other events that are not open to all potential donors in a Federal agency or the campaign region. As always, campaigns must clear all sponsorships with the Designated Agency Ethics Officers of the Federal agencies that will participate in the event. Can the CFC accept in-kind contributions, such as food, from businesses or other sponsors? The campaign may accept non-monetary items for usage in the CFC if the Designated Agency Ethics Officer of every Federal agency with staff attending the event has approved the source of the contributions and the value per employee. Ethics: Sponsorships Use, Events/Fundraisers

The out-of-pocket burden on CFC staff, LE’s, LFCCs, keyworkers… The Workarounds: ◦ Federal Sponsorship ◦ PCFOs ◦ FEB / FEA’s ◦ Other Creative Options Ethics: Sponsorships Use, Events/Fundraisers

Sponsorships  Who are they?  What are you getting?  How are you using it?  How do we make it a win / win? Ethics: Sponsorships Use, Events/Fundraisers

Is it a drawing, is it a raffle, is there anyway to have an affective fundraiser? The Rules as we know them: OPM Regulations regarding fundraising events and CFC: § Solicitation methods. (a) Employee solicitations shall be conducted during duty hours using methods that permit true voluntary giving and shall reserve to the individual the option of disclosing any gift or keeping it confidential. Campaign kick-offs, victory events, awards, and other non-solicitation events to build support for the CFC are encouraged. (b) Special CFC fundraising events, such as raffles, lotteries, auctions, bake sales, carnivals, athletic events, or other activities not specifically provided for in these regulations are permitted during the campaign period if approved by the appropriate agency head or government official, consistent with agency ethics regulations. CFC special fundraising events should be undertaken in the spirit of generating interest in the CFC and be open to all individuals without regard to whether an individual participates in the CFC. Chances to win must be disassociated from amount of contributions, if any. Raffle prizes should be modest in nature and value. Examples of appropriate raffle prizes may include opportunities for lunch with Agency Officials, agency parking spaces for a specific time period, and gifts of minimal financial value. Any special CFC fundraising event and prize or gift should be approved in advance by the Agency's ethics official. (c) In all approved special fundraising events the donor must have the option of designating to a specific participating organization or federation or be advised that the donation will be counted as an undesignated contribution and distributed according to these regulations. Ethics: Sponsorships Use, Events/Fundraisers

Open to all employees – “ALL” – REALLY? ◦ The phrase “campaign events” for these purposes means events that are open to all potential donors with the purpose of encouraging them to make a contribution or to thank them for their participation. Campaign events also include award ceremonies. Campaign events do not include LFCC meetings, LE or keyworker or other campaign personnel trainings or other events that are not open to all potential donors in a Federal agency or the campaign region. Reasonable Gifts?  Is it $20, Or if it is going to tens of thousands of federal employees is it a Harley? Reasonable Costs?  OPM: The room charge is reimbursable as long as it is reasonable.  Room fees, “All-Inclusive” Room fees Ethics: Sponsorships Use, Events/Fundraisers

Wrap Up Final Questions? Final Comments? THANK YOU!