IX. Conduct and Ethics
Working with Partners who are Fundraising
The implementation of many partnership projects depends upon monetary support, and fundraising is an important strategy for obtaining the necessary funds. Non-federal organizations support partnership projects by providing in-kind services, gifts, donations, and participating in fundraising campaigns. These kinds of support are important and appreciated but often approached by the Forest Service with hesitancy due to the uncertainty that arises from ethical issues that can be involved. This section discusses the difference between fundraising and negotiating with partners in the context of a partnership agreement, Forest Service involvement in fundraising events, and a note on co-applying for grants.
It is important to understand that negotiating and documenting a partnership arrangement, where the Forest Service and a cooperator are coming together and contributing resources towards a mutually beneficial outcome, is not considered fundraising. In addition, the partner contributions to a partnership arrangement are not considered “gifts” subject to Departmental Regulations on Acceptance of Gifts (see next section). Forest Service employees can negotiate with partners in the context of a partnership agreement and partners can then fundraise to generate their contribution to the partnership arrangement.
Partners can fundraise – by direct mail, conducting events, or other means – and use those funds to contribute towards a mutual benefit arrangement or other type of agreement. The manner is which the partner raises funds from outside sources is not governed by the Forest Service or Department of Agriculture Regulations. However, government ethics policy and regulations regarding conflict of interest and avoiding the appearance of impartiality make it important for the Forest Service to consider the source of partner contributions when considering whether to enter into a partnership arrangement. In addition, if Forest Service employees are involved in partner fundraising events, then conduct and ethic guidelines for federal employees apply, and are detailed below.
Forest Service involvement in fundraising events of partners or other non-federal organizations is subject to the same conduct and ethic guidelines for Forest Service employees in any fundraising event. In other words, it is extremely limited! Outside of making an official speech, fundraising in an official capacity is limited to the, 1) Combined Federal Campaign, 2) Special solicitations approved by the Director of the Office of Personnel Management, (e.g., Tsunami Relief in 2005).
Forest Service Involvement in Partner Fundraising Events
What a Forest Service Employee Needs to Know
- Attending fundraising events in an official capacity is permitted – though restricted to approved and official remarks. Participation may not appear to endorse the fundraising effort or the organization.
- Employees can be named on invitations as speakers (without title) but neither the employee nor the agency can be shown as sponsors.
- Employees can wear their uniforms when attending meetings and fundraising events as representatives of the agency. Again, their remarks must be limited to programs, projects, or subjects related to the agency’s mission.
- Agency employees cannot ask for money or support, or receive donations on behalf of the non-federal organization. They can provide information about how contributions benefit Forest Service programs.
- Raising funds in a personal capacity for a charitable non-federal organization that is completely separate from a person’s federal government job is allowed other than prohibited sources or subordinates.
- Federal employees may not use or permit the use of their position, title, or authority to support the fundraising effort occurring in his or her personal capacity.