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Other Ethical Considerations

Surreptitious Tape Recordings in the Workplace

Recording conversations in the workplace or while conducting business on behalf of the OCFO with a recording or electronic transmission device, without the knowledge and consent of all parties who are part of the conversation, is prohibited. This prohibition is intended to eliminate a chilling effect on the expression of views that may exist when one person is concerned that his or her conversation with another is being secretly recorded. This concern can inhibit spontaneous and honest dialogue, especially when sensitive or confidential matters are being discussed. Any employee who records or electronically transmits a conversation in violation of this policy shall be subject to termination.

Duty to be Honest

It is vital to the OCFO that the public is able to rely on the honesty of all of our employees. Therefore, employees shall perform their duties with honesty and integrity. An employee shall not make any false or misleading verbal or written statements in matters relating to his/her official duties, submit false claims or make false allegations, or engage in any dishonest or illegal activity.

Duty to File Returns and Pay Taxes

OCFO employees must set the highest example for tax compliance with all applicable local, state, and federal tax laws and display the highest level of ethical conduct in the resolution of disputed personal tax issues. This includes the accurate reporting of all income, deductions and credits, assuring that tax withholding is sufficient to meet legal requirements, and that property tax information is accurate. Each OCFO employee is required to file timely all applicable local, state, and federal tax returns, and make payment in full when due. Employees are responsible for their personal tax compliance and should be knowledgeable of their tax affairs even if they are handled by a professional, spouse, or others.

Duty to Satisfy Just Financial Obligations

Employees shall pay each just financial obligation in a proper and timely manner. For the purpose of the Code of Conduct, a "just financial obligation" means one acknowledged by the employee or reduced to judgment by a court or one imposed by law; "in a proper and timely manner" means in a manner which the OCFO determines does not, under the circumstances, reflect adversely on the OCFO as an employer. In the event of a dispute between an employee and an alleged creditor, this section does not require the OCFO to determine the validity or amount of the disputed debt.

Requirement for Annual Integrity and Ethics Training

Every OCFO employee shall attend an annual integrity and ethics training presentation sponsored by the OCFO. An employee must attend an entire session and certify his or her attendance.

DC Office of Campaign Finance Disclosure Statement

Each year employees whose official position has been so designated by management must complete and file the District of Columbia Office of Campaign Finance Financial Disclosure Statement. A letter is mailed to the home address of covered employees. Covered employees are also required to file a final Financial Disclosure Statement with the Office of Campaign Finance within 90 days of separation from government service.

OCFO Confidential Financial Disclosure Report (OCFO Form 450)

OCFO employees, DS 13 or above, or those employees whose official positions have been so designated by management, must annually complete the OCFO Confidential Financial Disclosure Report (Form 450). The OCFO Form 450 is sent electronically to covered employees at the end of the reporting calendar year.

Gifts

The term "gift" includes any gratuity, favor, discount, entertainment, hospitality, loan, forbearance, or other item having monetary value. It includes services, as well as gifts of training, transportation, local travel, lodgings and meals, whether provided in-kind, by purchase of a ticket, payment in advance, or reimbursement after the expense has been incurred.

Gifts from Outside Sources

OCFO employees shall not solicit or accept, either directly or through the intercession of others, any gift from a taxpayer involved in any tax administration matter or a person or business that:

  • Has, or is seeking to obtain, contractual or other business or financial relations with the DC Government
  • Conducts operations or activities that are subject to regulation by the DC Government
  • Has an interest that may be favorably affected by the performance or non-performance of the employee's official responsibilities
  • Is an organization, most of whose members are described above
  • Gives the gift because of your official position.

This rule does not apply to

  •  An insignificant item, such as a soft drink, coffee, donuts and other modest items of food and refreshments when not offered as part of a meal
  •  Unsolicited advertising or promotional material such as pens, pencils, note pads, calendars, and like items of nominal value
  •  Items of little inherent value that are intended solely for presentation, such as plaques, certificates and trophies
  •  Anything for which you pay market value
  • Obvious personal relationships such as those that exist between an employee and his or her parents, children or spouse, when the circumstances make it clear that the motivating factor in these relationships is the individual's close family ties, rather than the business of the persons concerned.

There are other exceptions to the "gift rule," such as discounts available for Government employees as a group, and free attendance at widely attended meetings and events where the employee's attendance is determined to be in the best interest of the agency. These and other possible exceptions have limitations based on the circumstances. Therefore, if an employee has any question about whether a gift can be accepted, the employee should contact the OCFO Ethics Officer for a determination.

Employees should not attend holiday celebrations sponsored or hosted by contractors, entities seeking to obtain contracts with the District, or entities regulated by the District, nor allow those entities to supply food, refreshments, or other items of value to employee-hosted events.

Since employees may not accept any gift or thing of value, the acceptance of gifts like travel expenses, lodging, meals, invitations or tickets to spectator and other events (e.g., a basketball game, the ballet, private club, sports tournaments, museum admission fees, tours, celebrations, galas), and services (e.g. car washing, investment counseling) is prohibited.

The offer of something of value may constitute a crime. Except for those areas in which the gift prohibition rule does not apply, as described above, employees must promptly report to the Internal Security Division of the Office of Integrity and Oversight (OIO) the offer of any gift or gratuity.

If an employee receives a prohibited gift, including perishable items, which he or she was unable to decline, e.g. it was delivered to the office, or where circumstances, such as a presentation at a public event or where sensitivities indicate it would cause embarrassment to a well-intentioned citizen, the employee should promptly contact the Internal Security Division of the Office of Integrity and Oversight. Internal Security will address the matter and arrange for the return, disposition or retention of the item, as appropriate.

Any gift offered or received from a foreign government must be reported to the OCFO Ethics Officer, who will coordinate with Internal Security concerning retention or disposition of the item.

Gifts Between OCFO Employees

The definition of gift is the same as described in the above section.

Gifts to Superiors

Employees should not solicit contributions from other employees for gifts to persons in superior positions, or make a donation as a gift to a superior, or accept a gift from a subordinate employee. This does not preclude the presentation or acceptance of a voluntary gift of nominal value, or of a cash donation in a nominal amount, when given on a special, infrequent occasion, such as birthday, a holiday on which gifts are traditionally given or exchanged, marriage, birth or adoption of a child, retirement, resignation, illness or death.

For the purposes of this section, the term "gift to a superior" means an item other than cash, and the terms "nominal value" and "nominal amount" mean, per occasion, a $25 maximum for an employee when making an individual gift or a $10 maximum per employee when collecting for a group gift to a superior.

Solicitors must make clear to all prospective contributors that contributions are voluntary. Supervisors should not solicit a gift, or contributions from an employee under his supervision under any circumstances.

Gifts Between Employees

Gifts from superiors to subordinates, as well as gifts between employees that do not involve a subordinate-superior relationship, are permissible if the gifts:

  •  Are provided on an occasional basis, such as occasions on which gifts are traditionally given or exchanged, and
  •  Are of a value appropriate to the occasion and the relationship of the employees, and
  • Do not create the appearance of impropriety due to the frequency and/or value of the gift(s).

The OCFO Ethics Officer is available to provide guidance on this subject and should be consulted if an employee has any questions on this subject.

Recommending Professional Assistance

Employees may not recommend or suggest, specifically or by implication, to anyone that he/she obtain the services of any particular accountant, attorney, or firm of accountants or attorneys, or any other person or professional or business organization in connection with any official business which involves or may involve the OCFO.

Cooperation with Official Inquiries

Employees shall respond to questions truthfully and under oath when required, whether orally or in writing, and must provide documents and other materials concerning matters of official interest when directed to do so by competent DC government authority, such as the OCFO Office of Integrity and Oversight and the DC Office of the Inspector General, and other such agencies.

Use of Government Property and Official Time

Employees have a duty to protect and conserve Government property and resources and shall not use such property and resources, or allow its use, for other than authorized purposes. Employees shall adhere to District Government policies concerning the use of Government property, which includes, but is not limited to, information technology resources and Government motor vehicles.

OCFO policy on the acceptable and intended use of OCFO computers, the DC government e-mail system, accessing the internet, and other related subjects is available on the CFO Intranet by accessing the Ethics and Integrity link (Documents).

Employees shall use official time in an honest effort to perform official duties.

Soliciting, Selling and Canvassing

Employees shall not, by any means including email, solicit, make collections, canvass for the sale of any article, or distribute literature or advertising in any government-owned or leased property or while on duty without appropriate authority.

Gambling, Betting, and Lotteries

Employees shall not participate, while on government-owned or leased property or while on duty, in any gambling activity, including the operation of a gambling device, in conducting a lottery pool, in a game for money or property, or in selling or purchasing a numbers slip or ticket, except for those lawful activities sponsored by the DC Lottery and Charitable Games Board, or necessitated by an employee's agency-approved law enforcement duties.

Political Activities

OCFO employees are reminded of their obligations under federal law concerning political activities. The provisions of Title 5 of the United States Code, Section 7321 et seq., commonly known as the "Hatch Act," contain prohibitions regarding the political activities of federal and District government employees. Although government employees are permitted to take part in partisan political campaigns, employees are cautioned that there are significant restrictions on employees' political activity. Employees are responsible for familiarizing themselves with these provisions. The U.S. Office of Special Counsel (OSC) is the designated agency for investigating alleged violations of the Hatch Act. A list of permitted and prohibited activities concerning the Hatch Act and other useful information is provided on the OSC website. OCFO employees may contact the OCFO Ethics Officer for guidance and assistance. Employees also may obtain advice and opinions from OSC about which political activities are permitted or prohibited by contacting OSC directly at (202) 254-3650, or by email.