1. Government Ethics Rules: Impact on Government Employees and Non-Employees Arthur Warren Senior Counsel for Ethics U.S. Department of Commerce MBDA 2015 NATIONAL TRAINING CONFERENCE

2. AN MBDA EMPLOYEE MAY NOT WORK ON A GRANT, CONTRACT, OR ANY OTHER OFFICIAL MATTER THAT WILL AFFECT THE EMPLOYEE’S FINANCIAL INTERESTS

3. MBDA 2015 NATIONAL TRAINING CONFERENCE AN MBDA EMPLOYEE MAY NOT WORK ON A GRANT, CONTRACT, OR ANY OFFICIAL MATTER TO WHICH AN ORGANIZATION IN WHICH THE EMPLOYEE IS ACTIVE OR HOLDS A POSITION OR BY WHICH SHE/HE WAS RECENTLY EMPLOYED

4. MBDA 2015 NATIONAL TRAINING CONFERENCE PERSONAL GIFTS AVOID UNDUE INFLUENCE AN MBDA EMPLOYEE MAY NOT ACCEPT A GIFT OR INVITATION FROM A “PROHIBITED SOURCE”, UNLESS AN EXCEPTION APPLIES

5. MBDA 2015 NATIONAL TRAINING CONFERENCE PERSONAL GIFTS AVOID UNDUE INFLUENCE WHO IS A PROHIBITED SOURCE OF GIFTS TO MBDA EMPLOYEES? - ANY PERSON OR ORGANIZATION SEEKING OR DOING BUSINESS WITH MBDA, INCLUDING GRANTEES, CONTRACTORS, AND BUSINESS CENTER OPERATORS

6. MBDA 2015 NATIONAL TRAINING CONFERENCE PERSONAL GIFTS AVOID UNDUE INFLUENCE WHO IS A PROHIBITED SOURCE OF GIFTS TO MBDA EMPLOYEES? (Cont’d) -ANY PERSON OR ORGANIZATION OFFERING A GIFT OR INVITATION BECAUSE OF YOUR GOVERNMENT POSITION

7. MBDA 2015 NATIONAL TRAINING CONFERENCE PERSONAL GIFTS AVOID UNDUE INFLUENCE WHO IS A PROHIBITED SOURCE OF GIFTS TO MBDA EMPLOYEES? (Cont’d) -ANY PERSON OR ORGANIZATION SEEKING OR DOING BUSINESS WITH ANY OTHER AGENCY IN THE DEPARTMENT OF COMMERCE

8. MBDA 2015 NATIONAL TRAINING CONFERENCE PERSONAL GIFTS AVOID UNDUE INFLUENCE WHO IS A PROHIBITED SOURCE OF GIFTS TO MBDA EMPLOYEES? (Cont’d) IN EFFECT, JUST ABOUT EVERYONE AND EVERY ORGANIZATION

9. MBDA 2015 NATIONAL TRAINING CONFERENCE EXCEPTIONS TO THE PERSONAL GIFT PROHIBITION ALLOW AN MBDA EMPLOYEE TO ACCEPT: -A GIFT VALUED AT $20 OR LESS (No Cash) - AN INVITATION TO A “WIDELY-ATTENDED GATHERING” PERSONAL GIFTS AVOID UNDUE INFLUENCE

10. MBDA 2015 NATIONAL TRAINING CONFERENCE PERSONAL GIFTS AVOID UNDUE INFLUENCE EXCEPTIONS (Cont’d)TO THE PERSONAL GIFT PROHIBITION ALLOW AN MBDA EMPLOYEE TO ACCEPT: - WHEN SPEAKING IN AN OFFICIAL CAPACITY: FREE ATTENDANCE ON THE DAY OF SPEECH AND MEALS FROM THE EVENT SPONSOR PROVIDED TO ALL ATTENDEES ON THE DAY OF THE SPEECH

11. MBDA 2015 NATIONAL TRAINING CONFERENCE OFFICIAL GIFTS AVOID UNDUE INFLUENCE AN MBDA EMPLOYEE MAY NOT ACCEPT A GIFT ON BEHALF OF MBDA, SUCH AS A TRAVEL GIFT, FROM A GRANTEE, CONTRACTOR, OR SOMEONE WITH AN INTEREST IN A CONTROVERSIAL MATTER PENDING BEFORE MBDA

12. MBDA 2015 NATIONAL TRAINING CONFERENCE OUTSIDE ACTIVITIES AVOID DIVIDED LOYALTIES AN MBDA EMPLOYEE MAY NOT ACCEPT EMPLOYMENT WITH, OR PROVIDE VOLUNTARY SERVICES TO, AN ORGANIZATION, INCLUDING A GRANTEE OR CONTRACTOR, WITH MATTERS BEFORE THE EMPLOYEE’S OFFICE

13. MBDA 2015 NATIONAL TRAINING CONFERENCE USE OF GOVERNMENT RESOURCES AVOID MISUSE OF RESOURCES NEITHER AN MBDA EMPLOYEE NOR A GRANTEE MAY USE GOVERNMENT RESOURCES FOR ANYTHING OTHER THAN AUTHORIZED PURPOSES

14. MBDA 2015 NATIONAL TRAINING CONFERENCE SEEKING EMPLOYMENT WITH A GRANTEE AVOID DIVIDED LOYALTIES AN MBDA EMPLOYEE MAY EXPLORE EMPLOYMENT WITH A GRANTEE OR CONTRACTOR, BUT MUST STOP ALL WORK ON MATTERS AFFECTING THE GRANTEE OR CONTRACTOR WHILE EMPLOYMENT DISCUSSIONS ARE ONGOING

15. MBDA 2015 NATIONAL TRAINING CONFERENCE RESTRICTIONS AFTER LEAVING GOVERNMENT SERVICE AVOID MISUSE OF POSITION AN MBDA EMPLOYEE MAY WORK FOR A GRANTEE OR CONTRACTOR AFTER LEAVING FEDERAL SERVICE, BUT: -MAY NOT CONTACT MBDA OR OTHER FEDERAL AGENCIES ABOUT GRANTS THE EMPLOYEE WORKED ON - MAY NOT DISCLOSE NON-PUBLIC INFORMATION

16. MBDA 2015 NATIONAL TRAINING CONFERENCE RESTRICTIONS ON A FORMER GRANTEE WORKING FOR THE GOVERNMENT A GRANTEE OR CONTRACTOR MAY WORK FOR THE GOVERNMENT AFTER LEAVING THE GRANTEE ORGANIZATION, BUT CANNOT WORK ON ANY MATTERS IN WHICH THE GRANTEE OR CONTRACOR ORGANIZATION IS A PARTY FOR ONE YEAR, UNLESS SPECIAL AUTHORIZATION IS GIVEN

17. HAVE QUESTIONS? NEED ADVICE? CONTACT: THE ETHICS LAW AND PROGRAMS DIVISION U.S. DEPARTMENT OF COMMERCE 202-482-5384 ethicsdivision@doc.gov www.commerce.gov/ethics MBDA 2015 NATIONAL TRAINING CONFERENCE