Ask the Scholar
Page 1 of 1
I can add historical knowledge about this page.
Page image
OCR
The original documents are located in Box 40, folder "Transition Reports (1977) - Vice
President (5)" of the John Marsh Files at the Gerald R. Ford Presidential Library.
Copyright Notice
The copyright law of the United States (Title 17, United States Code) governs the making of
photocopies or other reproductions of copyrighted material. Gerald R. Ford donated to the United
States of America his copyrights in all of his unpublished writings in National Archives collections.
Works prepared by U.S. Government employees as part of their official duties are in the public
domain. The copyrights to materials written by other individuals or organizations are presumed to
remain with them. If you think any of the information displayed in the PDF is subject to a valid
copyright claim, please contact the Gerald R. Ford Presidential Library.
Digitized from Box 40 of the John Marsh Files at the Gerald R. Ford Presidential Library
CONTENTS
C - Selected additional current procedural memoranda
1. File Manual (1974)
2. Fire Alarm System (July 3, 1975)
3. Standards of Conduct/Confidential Statement
of Employment and Financial Interests
(July 9, 1975)
4. Restrictions on Political Participation by
Employees of the Vice President's Office
(July 14, 1975)
5. Security Procedures (November 4, 1975)
6. Procedures in case of Riot or Disorder Enroute
(February 11, 1976)
7. Control and Reduction of Official Travel Costs
(March 3, 1976)
8. Federal Travel Allowances and Preparation of
Necessary Travel Forms (March 3, 1976)
9. Absences from the Office of the Vice President
(Annual Leave, Sick Leave and Compensatory Time)
(March 3, 1976)
10. Transportation (March 19, 1976)
11. Guests on the Vice President's Airplane
(March 24, 1976)
12. Use of Burn Bags for Classified Material
(May 18, 1976)
13. Minimum Ground Time Requirements (June 1, 1976)
14. Thank-You Letters (June 22, 1976)
15. Vice Presidential Gifts Received on Trips
(July 23, 1976)
FORD is LIBRARY GERALD
16. Service Academy Nominations by the Vice
President (Vice President's Military Office
Operating Procedure 1-76) (October 12, 1976)
17. Correspondence Analysis, 22 July 1975 -
31 July, 1976) (included as a sample)
is
FORD
SERALD
FILE
OFFICE OF
THE VICE PRESIDENT
FILE MANUAL
1974
BERALD FORD LIBRARY
Section I
FILES OPERATION
The success or failure of the filing system is dependent on properly
carrying out several basic steps. These steps consist of setting un the
system, preparing the filing material, finding papers in the files and
charging them out, keeping the files orderly, breaking the files, and
retiring inactive files.
These steps are explained in detail so that an efficient filing system
can be provided.
A. Setting up the System
1. Selecting Folders, Labels, and Guides
The types of folders, labels, and guides used and their manner
of preparation affect the appearance and efficiency of the files.
The specific arrangement of the folders with the folder labels
and their guides will be discussed in Section II. Supplies
should be standardized as much as possible to obtain the follow-
ing advantages:
- Neater appearance through uniformity.
- Faster supply replenishment.
- Fewer requisitions.
a. File Folders
Extensive tests of various types of file folders have shown
that kraft folders are the best for general use because of
durability, economy, and space occupied in the file drawers.
Kraft folders, 11-point, square-cut, with reinforced top,
are recommended.
Square-cut folders have a tab which covers the full width
of the folder. They provide neatness and uniformity in
appearance.
b. Folder Labels
Labels should be placed on the left side of the folder tab
ending approximately one-half inch from the end of the tab.
Pressure sensitive, color-code labels are recommended, as
they may be typed, peeled off the back and attached to the
folders. They adhere to the folder, and the corners of the
label will not come loose.
i
FORD
2
RALD
c. File Guides
(1) Guide cards, with the first position tabs, should be
used to mark the beginning of each primary subject
in the file.
(2) Guide cards, with second or third position tabs, should
be used to identify sub-subjects, where volume of
files and range of subjects require guiding to ease
files reference.
2. Typing File Copies
All letters to be typed will have in addition to the original, a
set of manifold carbon copies. These manifolds will consist of:
Yellow (Gfficial File Copy)
Filed by Subject.
White (Cross Reference)
Filed by Subject or name.
Green (Alphabetic Name or Control File
Filed alphabetic by name.
Copy)
Pink (Chronologic Copy)
Filed in date order by
preparing office.
Blue (Reading Copy)
Filed in date order and
destroyed when seen by
appropriate officials.
B. Preparing Material for the Files
The real test of any file system is not how quickly material can be
filed but how quickly it can be produced. Therefore, give the utmost
care to the classifying and preparation of material for filing.
1. Inspecting
Inspect material to make certain that all file copies are present.
2. Assembling
Assemble each unit of file material by stapling the yellow file
copy on top of the incoming communication, if any, and place the
green copy on top, unfastened.
3. Classifying
a. Classification and Its Importance
Classification is the process of finding the correct file
group under which a record should be filed and the sub-
ordinate subjects (or file groups) which should be cross-
referenced. This is the most vital of all processes having
to do with getting papers into the files.
3
ERALD FORD
The ability to locate papers promptly after they have been
filed depends largely on the care and skill used to determine
the proper subject of the papers at the time they are placed
in the files.
A paper may cover one subject or several. The subjects may
be either obvious or obscure. The system outlined in this
manual is intended to bring together related subjects.
Papers on related subjects, however, can be logically and
consistently brought together in the files only when classi-
fying techniques are sound.
Successful classification is based upon the following
requirements:
- Knowledge and understanding of the office and its activities;
familiarity with how records are asked for and used; and
knowledge of. the classification or subject outline in this
manual.
- Analytical ability.
- Proper techniques.
b. Classifying Techniques
Read and analyze the correspondence or other material to
select the proper file designation by referring to the
Subject Outline or the Alphabetic Index. Be consistent
in classification. Similar or overlapping subjects may
require cross-referencing.
c. Official File Copy
An Official File Copy consists of the original incoming
documents, plus the yellow outgoing file copy. Sometimes
there will be no outgoing response and therefore an ori-
ginal incoming document is then considered an Official File
copy. Conversely there will also be times when you will
only have a yellow outgoing file copy.
d. Marking for the File
After determining the classification, mark it in the upper
right corner of the Official File copy.
AU, GERALD BIT FORD
4
4. Cross-referencing
Cross-references are needed to facilitate prompt location of
documents. Cross-references are of three types:
- A carbon copy of an outgoing letter.
- A-quick-copy of the letter or other paper (Copy the cover
sheet only if there are several pages).
- A cross-reference form. (EXHIBIT I)
If possible, prepare at typing time sufficient cross-reference
copies. Cross-reference copies for the Subject Files are white.
If there is no outgoing correspondence, or if too few copies
were typed, use a quick-copy.
A common occurence which requires cross-referencing is when
more than one name or subject is connected with a case.
C. Filing Records
1. Sorting and Arranging
When the material has been properly marked and assembled,
separate it into file groups (i.e., Agriculture, Public
Relations, and so forth), and arrange it in alphabetical order
or numerical sequence, as the case may be. Be consistent
when arranging alphabetically. Unless one set of rules is
followed, it will become difficult to find wanted documents.
a. Sort subject file material in alphabetical sequence
according to subject title. Within each subject, arrange
material in numerical sequence.
b. Place each unit of file material in the appropriate
folder with the left side of the material down. Material
within the folder should be arranged with the latest
date in front. If successive folders containing material
on the same subject are necessary, the folders should
be arranged chronologically with the latest in front.
2. Do's and Don'ts of Good Filing
Neatness and orderliness are the essence of filing efficiency.
The following are a few suggestions that will help maintain
the office files in a neat and orderly manner:
is
FORD
GERALD
a. Identify File Drawers
Label file drawers adequately to indicate what files,
subjects, or names are filed in them. Also indicate the
year. Filing can be accomplished much more rapidly if
cabinets are arranged systematically and all file drawers
are properly labeled. The material in file drawers
should be arranged from front to back in strict sequence
of the subject outline.
b. Keep Papers Straight
When placing material in file folders, do not let the
papers extend beyond the edges of the folders.
c. Avoid Overloaded File Folders
The scoring along the bottom of the folders should be
creased, as necessary, to adjust the folder to increased
contents. About three-quarters of an inch is the normal
capacity of the kraft folder. When the capacity of the
folder has been reached, additional material on the same
subject should be placed in another folder bearing identi-
cal identification to the full folder and arranged with
the folder containing the more recent material in front.
The inclusive dates of the material should be marked on
the tab of the earlier folder.
d. Avoid Overcrowed File Drawers
If the file drawer is not too crowded, papers can be
added without removing the contents of the folder.
e. Fastening Papers
Fastening of papers to the folders is only justified when:
(1) Papers need to be divided into temporary and
permanent categories.
(2) Papers need to be divided within a- folder to provide
immediate reference to a particular type of document.
(3) Papers are highly valuable or irreplaccable.
(4) There is not much interfiling of papers.
f. Keep the Filing Current
FORD
Don't let a backlog of unfiled material accumulate. Try
to file material each day on an established schedule.
GERALD
6
D. Finding Records
To find papers desired, use the information available concerning
them and relate this information to the filing system. The fol-
lowing steps illustrate how to do this:
1. When receiving a request for file material, obtain,
if possible, sufficient information to identify the
file, that is, the names of individuals or agencies,
the dates, and the subject of the material.
2. If uncertain of the exact file or subject, consult
the Subject Outline or the Alphabetic Index to help
limit the area of search.
3. If only name references are given, search the Alphabe-
tical Name File which sometimes is known as the Central
Control File.
4. If the material cannot be located in the files and
is of a recent date, a check of the unfiled materials
should be made. If this effort does not prove success-
ful, consider the following possibilities:
a. It may never have been received.
b. It was received but is in the hands of
some other staff member.
c. It has been misfiled or misplaced.
d. It was received but was forwarded to another
staff member without being charged out.
5. When removing material from a file drawer or folder,
prepare a charge-out card. (Exhibit II) Put it into
the folder or file drawer in place of the material
removed. Punch holes in top of requested documents
and ACCO file on a File Backing Sheet with latest date
on top. Backing sheet must be stamped "Return to
VP Central Files." When the material has been re-
turned to the file, the charge-out card should be
removed and the entry indicating the charge can be
cancelled by drawing a line through it.
BERRLD R. FORD
7
E. Breaking the Files
1. Definition
Files are "broken" or "art off" by stopping the filing of
documents in one set of folders as of a predetermined date
and thereafter filing under the same file classification
in another set of folders.
2. Continuity Reference
When files are cut off or broken, material necessary to
current operations should be brought forward into the new
files. When earlier material must be brought forward,
prepare E Continuity Reference Form (Exhibit III) for each
file that is being consolidated with the latest correspon-
dence. The Continuity Reference Form is used to show that
material has been brought forward from one year to another.
Fill in the appropriate information opposite each caption.
F. Retiring and Disposing of Records
A goal of good records management is to avoid keeping files in
operating office space when they are not used frequently. Such
files can be transferred regularly to a less active area.
Systematic records retirement is essential if files needed for
current operations are not to be clogged with obsolete material.
Screening or "weeding" of files on a paper-by-paper basis. should
not be undertaken for retirement of files. This method of
sorting is a cumbersome, time-consuming way to reduce bulk.
G. Filing Classified and/or Sensitive Records
Classified papers are filed under the same guidelines as used
for unclassified material. However, classified papers are
housed in equipment affording necessary security. A cross-
reference form placed in the file folder indicating that the
material is filed in security cabinets will provide a guide
to finding. The cross-reference form will not reveal the con-
tent of the classified material. If an entire folder is kept
in security cabinets, a charge-out card should be used.
H. Location of File Manual
The master File Manual should be located in the front of the
first drawer of the files. Additional refinements of the
file system will be made only after consulting the person
responsible for the files, and at that time, all copies of the
file manual will be amended to reflect the latest change.
FORD
BLD
8
Section II
FILE GROUPS
A. Subject Files
Subject Files are maintained for subject-oriented papers. The
subject material housed in these files includes correspondence,
memoranda, reports, and other documents which are logically
classified and filed under subject categories. They are filed
in a series of folders labeled in accordance with an approved
subject system of coding.
1. Classification
Each piece of material sent to the file must be classified,
and that subject classification actually marked on the paper
in the upper right-hand corner. All material to be refiled
must be placed in the same location it occupied previously.
Marking the classification allows exact replacement of the
material in the file and eliminates the man-hour loss as-
sociated with repeated reclassification of material being
returned to the file. In using the subject classification
scheme, some subjects will be rarely used. In these instances
only a primary folder should be prepared, and all documents
filed in this folder regardless of the secondary or tertiary
classification marked on them. Should this single folder
reach ten or more documents in size, it can then be sub-
divided into possible two or more secondary folders for easy
finding.
2. Arrangement
The file folders are arranged in the file by primary subject
categories, then by secondary and tertiary subjects. These
categories form logical subdivisions of the primary subjects,
which pull together all material on a given subject, Folders
should only be made for those subject titles for which there
is a definite current or anticipated need. If only an occasional
document relates to a secondary subject, the material may be
filed in the primary folder, behind the guide card. A separate
folder is prepared for a secondary subdivision when ten papers
or more have accumulated in the primary folder.
3. Guide Cards
Guide cards, 1/3 cut, are the best choice for subject files,
since the first or left tab card is the principal one used.
The left position is used to show each of the primary subjectso
9
in the classification scheme. Occasionally a secondary topic
in the system becomes so important to the users of the file
that this may justify setting up a guide card in the second or
center position to speed retrieval of material from that seg-
ment of the file. Use of the guide cards with proper primary
labeling will materially reduce the search effort required
to find and use the material contained in the subject file
(EXHIBIT IV).
B. Alrhabetic Name File - Sometime known as the Central Control File
File here, alphabetically by name, all documents pertaining to
a specific person, company, or organization. Do not file material
here that could be filed more appropriately in a subject file.
Do not set up a folder for each name, but file in general alphabetic
folders. When sufficient volume on a specific person or organiza-
tion is accumulated, remove this from the general file, make a
folder, and file it behind the general alphabetic folder.
C. Magnetic Card Produced Letter File
Letters answered by a form or robo letter shall be filed separately
and identified as to the type of letter used as a response.
Incoming letters only will be batch filed by date of response.
D. No Answer File
Drop file here, alphabetic by first letter of last name, all
correspondence which does not require an answer. Prepare only
a folder for each letter of the alphabet. When a folder has
reached its capacity, close out the folder by date, and prepare
another folder which states portion of alphabet covered, date
span, and file in front of the previous lettered folder.
FORD
071,
10
CROSS-
FERENCE
(name, number, or
subject under
which this form
is filed)
DATE
TO
IDENTIF
FROM
CATION
o:
RECORD
BRIEF
SUMMARY
OF
CONTENTS
FILED
(Name, number, or subject
under which the document
itself is filed)
&
FORD
Optional Thrm 21
Fib. 1"
GSA Circular 259
CROSS-REFERENCE
EXHIBIT I
II
OUT
II EXHIBIT
IDENTIFICATION OF RECORD
12
CHARGED TO
3
(NUMBER, TITLE AND/OR SUBJECT, DATE Of FILE OR DOCUMENT)
(PERSON & OFFICE)
RALD
sand
j
OPTIONAL FORM 23
FE3 1962
CHARGEOUT RECORD
* GPO : 1962 OF-512734-
8
GSA Circular No. 259
5023-101
ino
(PERSON & OFFICE)
CHARGED
(NUMSER, TITLE AND/OR SUBJECT, DATE OF FILE OR DOCUMENT)
01 CHARGED
DATE
IDENTIFICATION OF RECORD
OUT
DESCRIPTION OF CORRESPONDENCE OR DOCUMENT BEING BROUGHT FORWARD
SUBJECT
,ider which this form
is filed)
DATE (Under which
this form is filed)
TO
FROM
BRIEF SUMMARY
OF
CONTENTS
BROUGHT FORWARD and filed with the documents described below
SUBJECT
DATE
TO
FROM
FORD
is
LD
Optional Form 22
7.1. 1962
CONTINUITY REFERENCE
CSA r N., 250
EXHIBIT III
13
ARRANGEMENT OF FOLDERS, GUIDES AND LABELS
Labels with
File designation
inclusive dates
Labels
affixed to the folder
CA 4
Jan 1, 1974
Routes-Navigation
thru
CA 4
Routes-Navigatio
CIVIL AVIATION (CA)
CIVIL
AVIATION (CA)
AG 3-1
Jan 1, 1974
Marketing Protection Programs
thru
AG 3
Jan 1, 1974
Marketing
thru
AG 1
Jan 1, 1974
Home Economics
thru
AG 1
Home Economics
Jan L 1974
thru
AGRICULTURE
(AG)
PRIMARY SUBJECTS
SECONDARY SUBJECTS
TERTIARY SUBJECTS
1st Position Guides
2nd Position Guidea
3rd Position Guides
NOTE; In the average drawer, one guide for every 10 to 15
folders should serve.
ALD 1817 ? FORD
14
EXHIBIT IV
FILING CATEGORIES
PRIMARY SUBJECTS
SYMBOLS
AGRICULTURE
AG
ARTS
AR
ATOMIC ENERGY
AT
BUSINESS-ECONOMICS
BE
CIVIL AVIATION
CA
COMMODITIES
CM
COUNTRIES
CO
DISASTERS
DI
EDUCATION
ED
EMPLOYMENT ASSISTANCE
EM
ENDORSEMENTS
EN
FEDERAL AID
FA
FEDERAL GOVERNMENT
FE
FEDERAL GOVERNMENT-ORGANIZATIONS
FG
FINANCE
FI
FOREIGN AFFAIRS
FO
GIFTS
GI
HEALTH
HE
HIGHWAYS-BRIDGES
HI
HOLIDAYS
HO
HOUSING
HS
HUMAN RIGHTS
HU
IMMIGRATION-NATURALIZATION
IM
INDIAN AFFAIRS
IN
INSURANCE
IS
INTERNATIONAL ORGANIZATIONS
IT
INVITATIONS
IV
JUDICIAL-LEGAL MATTERS
JL
LABOR-MANAGEMENT RELATIONS
LA
LEGISLATION
LE
MEDALS-AWARDS
MA
MEETINGS-CONFERENCES
MC
MESSAGES
ME
NATIONAL SECURITY-DEFENSE
ND
NATURAL RESOURCES
NR
OUTER SPACE
OS
PARKS-MONUMENTS
PA
PEACE
PC
PERSONNEL MANAGEMENT
PE
POLITICAL AFFAIRS
PL
POSTAL SERVICE
PO
PRESIDENT
PP
PROCUREMENT-DISPOSAL
PQ
SALD R. FORD
15
PUBLIC RELATIONS
PR
PUBLICATIONS
PU
REAL PROPERTY
RA
RECREATION-SPORTS
RE
RELIGIOUS MATTERS
RM
REPORTS-STATISTICS
RS
SCIENCES
SC
SOCIAL APPAIRS
SO
SPEECHES
SP
STATE AND LOCAL GOVERNMENTS
ST
TRADE
TA
TRANSPORTATION
TN
TRIPS
TR
UTILITIES
UT
VICE PRESIDENT
VP
VICE PRESIDENT'S OFFICE
VS
WELFARE
WE
i
FORD
110
16
2
$
#
5.
#
OFFICE OF THE VICE PRESIDENT
WASHINGTON
July 3 1975
MEMORANDUM FOR:
The Vice Presidential Staff
SUBJECT
Fire Alarm System
The General Services Administration has recently completed the installation
of a new Fire Alarm System for the Old Executive Office Building.
Should the System be activated by a Pull Box, a voice announcement will
automatically be transmitted throughout OEOB via loud speakers.
The voice announcement will indicate the location of the fire and direct
occupants to leave the building. Occupants are directed NOT to use the
elevators.
Occupants should become familiar with the closest exits from their office
location and location of the Fire Alarm Pull Boxes.
Pull Box locations closest to the Vice Presidential Staff offices are
outside of Room 289A, 299, 261 1/2, 597 and the interior of Room 578.
Should there be a false alarm a manual overide feature of the new Fire
Alarm System can be used to inform occupants that there is no fire and
to return to their offices.
The Frank R. Pagnotta
Assistant to the Vice President
for Administration
FORD LIBRARY s GERALD
3
Richard Allison
4
OFFICE OF THE VICE PRESIDENT
WASHINGTON
July
1975
MEMORANDUM FOR THE STAFF OF THE A VICE PRESIDENT
FROM :
Counsel to the Vice Plu President
Peter J. Wallison
SUBJECT:
Standards of Conduct/Confidential State-
ment of Employment and Financial Interests
The Vice President has adopted official Standards
of Conduct for employees of his Office. These Standards
formally supersede similar guidelines which applied to
the conduct of the White House staff in general,
including the Vice President's Executive Office staff.
The Counsel to the Vice President will act as "Counselor"
as that term is used in the Standards.
These Standards apply to employees, consultants,
and special Government employees of the Office of the
Vice President, whether or not their salaries or fees
are paid out of funds appropriated to the President.
or to the Senate. Members of the Vice President's
staff who are paid out of Senate funds must of course
continue to adhere to applicable regulations of conduct
for Senate employees.
I have attached:
(a) a copy of the Standards (Tab A) together
with (as an appendix to the Standards) a copy of the
Code of Ethics for Senate employees;
(b) a copy of the Federal criminal statutes
on conflicts of interest and related matters (P.L. 87-
949) applicable to both Executive and Legislative branch
employees (Tab B) i these and other statutory and
executive requirements are included in the Standards;
GERALD R. LIQUIRY FORD
- 2 -
(c) a summary of the regulations applicable
to the White House staff (Tab C) ; the regulations
which apply to the White House staff are substantially
the same as the Standards, and the attached summary
is included to assist you in quickly reviewing the
Standards.
Please read these materials carefully and retain
them for future reference.
Financial Disclosure
All employees paid at a level equivalent to GS-13
($20,677) and above, and all special Government
employees regardless of grade, are required to submit
to the Counselor a "Confidential Statement of Employ-
ment and Financial Interests." The Vice President
has requested that both Executive and Legislative
branch employees of the Office complete this form.
Even if you have already completed such a form,
Civil Service Commission regulations require that
your statement be updated as of June 30 in each year.
Two copies of the form are attached to this memo
(Tab D).
Please return one completed original copy of the
form to me, Office of the Vice President, Old Executive
Office Building, Room 280, in a sealed envelope marked
"Personal-In-Confidence." One copy should be retained
for your files. All information reported will be kept
confidential, subject to the applicable regulations
governing review and determination as to conflicts of
interest.
Please note, in completing the Statement, that:
1.
You are not required to submit any information
relating to your connection with, or interest in,
any professional society or any charitable,
religious, social, fraternal, recreational,
public service, civic, or political organization
or any similar organization not conducted as a
business enterprise. Educational and other
institutions doing research and development or
related work involving grants of money from the
United States are deemed to be "business enter-
prises" for purposes of this report and should
be included.
FORD & LIBRAT RALD
- 3 -
2.
The information to be listed does not require
a showing of the amount of financial interest
in, indebtedness with respect to, or the value
of, real property.
3.
In the event any of the required information,
including holdings placed in trust, is not known
Not all In
to you but is known to another person, you
pjer 28 for 76
should request that other person to submit the
information on your behalf and should report
such request in Part IV of your statement.
4.
The interest, if any, of a spouse, minor child,
or other member of your immediate household
must be reported in this statement as your
interest. If that information is to be supplied
by others, it should be so indicated in Part IV.
" Member of your immediate household" includes
only those blood or in-law relations who are
residents of your household.
Any changes in, or additions to, the information
contained in your initial statement should be reported
NFA jun his
in a supplementary statement at the end of the calendar
quarter in which the change occurs, or in the case of
30
special Government employees, at the time the change
occurs.
you
If you have any questions regarding the foregoing,
please contact me at 395-4242.
FORD is LIBRARY PERALD
STANDARDS OF CONDUCT FOR THE
OFFICE OF THE VICE PRESIDENT
I. General Provisions.
1. Purpose and scope.
2. Definitions.
3. Special Government employees.
4. Counselor.
5. General responsibilities of employees.
6. Gereral tandards of conduct.
7. Disciplinary action.
II. Conflicts of Interest and Ethical Conduct.
8. Conflicts of interest.
9. Financial interests.
10. Additional prohibitions - regular employees.
11. Exemptions and exceptions from prohibition of
conflict of interest statutes.
12. Salary of employees payable only by United States.
13. Gifts, entertainment, and favors.
14. Outside employment and other activity.
15. Use of Government services and property.
16. Misuse of information.
17. Indebtedness.
18. Gambling, betting, and lotteries.
19. General conduct prejudicial to the Government.
20. Conduct and responsibilities of special Government
employees.
21. Additional prohibitions - special Government
employees.
22. Miscellaneous statutory provisions.
III. Reporting of Employment and Financial Interests.
23. Reporting of employment and financial interests -
regular employees.
24. Reporting of employment and financial interests -
special Government employees.
25. Reviewing statements - remedial action.
IV. Supplemental Regulations or Instructions.
26. Supplemental regulations or instructions.
FORD is LIBRARY GERALD
I. General Provisions.
1. Purpose and Scope.
(a) The maintenance of the highest standards of
honesty, integrity, impartiality, and ethical con-
duct by regular employees and special Government
employees is essential to assure the proper
performance of Government business and to command
the respect and confidence of the American public
in their Government. The avoidance of misconduct
and conflicts of interest on the part of regular
employees and special Government employees through
informed judgment is indispensable to the maintenance
of these standards.
(b) The standards of conduct outlined below are
required of all employees of the Office of the Vice
President in both the executive and legislative
branches. Applicability of these standards to em-
ployees of the legislative branch in no way relieves
them of their responsibilities under similar standards
imposed by that branch.
(c) The standards set forth herein reflect prohibi-
tions and requirements imposed by the laws of the
United States, but to the extent that such laws are
paraphrased below, such restatement is intended for
informational purposes only and in no way constitutes
an interpretation or construction of applicable laws
that is binding upon the Government. In addition,
attorneys who are employed by the Office of the Vice
President are subject to the Code of Professional
Responsibility of the American Bar Association.
2. Definitions.
(a) "Office" means Office of the Vice President.
(b) "Employee" or "regular employee" means any
employee of the Office, both those in the executive
branch and in the legislative branch, but does not
include a special Government employee.
BERALD FORD LIBRARY
-2-
(c) "Special Government employee" means an individual
who is retained, designated, appointed, or employed to
perform with or without compensation for a period not
to exceed 130 days during any period of 365 consecutive
days, temporary duties, either on a full time or
intermittent basis.
(d) "Person" means an individual, a corporation, a
company, an association, a firm, a partnership, a
society, a joint stock company, or any other organization
or institution.
(e) "Standards" means the standards of conduct,
Sections 1 through 26, outlined herein.
3. Special Government employees.
Except where specifically provided otherwise, or where
limited in terms or by the context to regular employees,
all provisions of these Standards relating to employees
are applicable also to special Government employees.
4. Counselor.
(a) The Legal Counsel of the Office is the "Counselor"
for the purposes of these Standards. The Counselor shall
advise employees as to the applicability and interpre-
tation of these Standards, and any laws and regulations
referred to herein.
(b) The Counselor shall serve as the Office's liaison
with the Civil Service Commission and the Department
of Justice on any matters covered by these Standards.
(c) Communications between the Counselor and an
ee shall remain confidential, except that the
Counselor may in appropriate circumstances disclose
such communications to the Vice President.
(d) The Counselor shall notify all employees and
special Government employees of the Office of the avail-
ability of counseling services and of how and where such
services are available. Such notification shall be
made within 90 days after the effective date of these
Standards and periodically thereafter. In the case
of a new employee or special Government employee
appointed after the date of such notification, notifica-
tion shall be given at the time of his/her entrance on,
duty.
RALD vasit R. FORD
-3-
(e) The Counselor shall have copies of these
Standards distributed to each employee and special
Government employee within 30 days after the effec-
tive date thereof. In the case of a new employee or
special Government employee entering on duty after the
date of such distribution, a copy shall be furnished at
the time of his/her entrance on duty.
5. General resconsibilities of employees.
(a) All employees and special Government employees
have the responsibility of reading and familiarizing
themselves with the contents of this Part and with
House Concurrent Resolution 175, 85th Congress, 2d
session, 72 Stat. B12, the "Code of Ethics for Government
Service" which is attached to these Standards as Appendix A.
(b) Copies of all regulations and statutes referred to
in these Standards together with various explanatory
materials, are available for inspection in the office
of the Counselor at any time during regular business
hours.
loyee or special Government employee who is
uncertain as to the application of any regulation in
these Standards, or of any provision of law, to any
particular situation in which he/she is or may be
involved, is obligated to contact the Counselor for
advice and guidance.
6. General standards of conduct.
(a) All employees shall conduct themselves on the job
in such a manner that the work of the Office is effi-
ciently accomplished, and courtesy, consideration, and
promptness are observed in dealings with the Congress,
the public and other governmental agencies.
(b) All employees shall conduct themselves off the job
in such a manner as not to reflect adversely upon the
Office or the Federal service.
(c) In all circumstances, employees shall conduct
themselves SO as to exemplify the highest standards of
integrity. An employee shall avoid any action, whether
or not specifically prohibited by these Standards,
which might result in, or create the appearance of:
(1) Using public office for private gain;
(2) Giving preferential treatment to any
LERALD FORD LIBRARY
person;
-4-
(3) Impeding Government efficiency or economy;
(4) Losing complete independence of judgment
or impartiality;
(5) Making a Government decision outside official
channels; or
(6) Affecting adversely the confidence of the
public in the integrity of the Government.
7. Disciplinary action.
(a) A violation of any provision of these Standards by
an employee may be cause for appropriate disciplinary
action which may be in addition to any penalties pre-
scribed by law. (As to other remedial action in cases
where an employee's or special Government employee's
financial interests result in a conflict or apparent
conflict of interest, see $25.)
Any disciplinary or remedial action taken pursuant to
these Standards shall be effected in accordance with
any applicable laws, Executive Orders, and regulations.
II. Conflicts of Interest and Ethical Conduct.
8. Conflicts of interest.
(a) A conflict of interest may exist whenever an
employee has a substantial personal or private interest
in a matter which involves his/her duties and respon-
sibilities as an employee. The maintenance of public
confidence in the Government demands that an employee
take no action which would constitute the use of his/
her official position to advance personal or private
interests. It is equally important that each employee
avoid becoming involved in situations which present the
possibility, or even the appearance, that his/her
official position might be used for private advantage.
(b) Neither the pertinent statutes nor the standards
of conduct prescribed in the Standards are to be
regarded as entirely comprehensive. Each employee must,
in each instance involving a personal or private interest
in a matter which also involves his/her duties and
responsibilities as an employee, make certain that his/
her actions do not have the effect or appearance of the
use of an official position for the furtherance of the
employee's interest or those of his/her family or
business associates.
FORD
any
LIBRA
-5-
(c) The principal statutory provisions relating to
bribery, graft, and conflicts of interest are contained
in Chapter II of the Criminal Code, 18 U.S.C. 201-224.
Penalties are provided for violations, including,
variously, fine, imprisonment, dismissal from holding
any office of honor, trust, or profit under the United
States.
9. Financial interests.
(a) Unless authorized to do so as provided hereafter
in this section, no employee shall participate personally
and substantially as a Government employee in a particular
matter in which, to the employee's own knowledge, he/
she has a financial interest (cf. 18 U.S.C. 208).
(1) For the purposes of this section
(i) An employee participates personally
and substantially in a particular matter
through decision, approval, disapproval,
recommendation, investigation, the render-
ing of advice, or otherwise;
(ii) A particular matter is a judicial or
other proceeding, an application, request
for ruling or other determination, a contract,
claim, controversy, charge, accusation, arrest
or other matter; and
(iii) A financial interest is the interest
of the employee or his/her spouse, minor
child, partner, organization in which the
employee is serving as an officer, director,
trustee, partner, or employee, or any person
or organization with whom the employee is
negotiating or has any arrangement concerning
prospective employment.
(b) An employee may not have a financial interest
which --
(1) Establishes a substantial personal or private
interest in a matter which involves his/her duties
as an employee; or
(2) Is entered into in reliance upon, or as a
result of, information obtained through his/her
employment; or
GERALD FORD LIBRAR
-6-
(3) Results from active and continuous trading
(as distinguished from the making of bona fide
investments) which is conducted on such a scale
as to interfere with the proper performance of
his/her duties.
(c) Aside from the restrictions prescribed in these
Standards, employees are free to engage in lawful
financial transactions to the same extent as private
citizens. Employees should be aware that the financial
interests of their spouses or minor children and blood
relatives who are full-time residents of their house-
holds are regarded, for the purposes of this section,
as financial interests of the employees themselves.
(d) An employee who has a financial interest (other
than a financial interest exempted under paragraph (e)
of this section) in a particular matter which is within
the scope of his/her official duties shall make a full
disclosure of that interest to the Counselor, in
writing. The employee shall not participate in such
matter unless and until he/she receives a written
determination by the Vice President that the interest
is not so substantial as to be deemed likely to affect
the integrity of the services which the Government
may expect of that employee (cf. 18 U.S.C. 208). If
the Vice President does not make such a determination,
then the Vice President shall direct such remedial
action as may be appropriate under the provisions of
$25.
(e) The financial interests described in (1) and (2)
below are hereby exempted from the restrictions of
paragraph (a) of this section as being too remote or
inconsequential to affect the integrity of an employee's
services in a matter (cf. 18 U.S.C. 208):
(1) Stocks, bonds, policies, properties, or
interests in a mutual fund, investment company,
trust, bank or insurance company, as to which
the employee has no managerial control or
directorship. In the case of a mutual fund or
investment company, this exemption applies only
where the assets of the fund or company are
diversified; it does not apply where the fund or
company advertises that it specializes in a
particular industry or commodity.
ERALD R.FORD
-7-
(2) Interest in an investment club: Provided,
That the fair value of the interest involved
does not exceed $5,000, and that the interest
does not exceed one-fourth of the total assets
of the investment club.
(f) This section does not apply to special Government
employees, who are subject to the provisions of $20.
30
Additional prohibitions regular employees.
(a) A regular employee is subject to the following
prohibitions.
(1) An employee may not, except in the discharge
of official duties, represent anyone else before
a court or Government agency in a matter in which
the United States is a party or has an interest.
This prohibition applies both to paid and unpaid
representation of another (18 U.S.C. 203 and 205).
(2) An employee may not, after his/her Government
employment has ended, represent anyone other than
the United States in connection with a matter in
which the United States is a party or has an interest
and in which the employee participated personally
and substantially for the Government (cf. 18 U.S.C.
207 (a)).
(3) An employee may not, for one year after his/
her Government employment has ended, represent
anyone other than the United States in connection
with a matter in which the United States is a party
or has an interest and which was within the
boundaries of the employee's official responsibility
during the last year of his/her Government service
(cf. 18 U.S.C. 207(b)). The temporary restraint is
permanent if the matter is one in which the
employee participated personally and substantially.
See subparagraph (2) of this paragraph.
(4) An employee may not receive any salary, or
supplementation of his/her Government salary, from
a private source as compensation for services as
a Government employee (cf. 18 U.S.C. 209). See $12 of
these Standards.
(b) Exemptions or exceptions from the prohibitions
described in paragraph (a) of this section are permitted
under certain circumstances For the method of obtaining
such exemptions or exceptions, see STT.
ALD. 8817 : FORD
-8-
11. Exemptions and exceptions from prohibitions of conflict
of interest statutes.
(a) Nothing in these Standards shall be deemed to
prohibit an employee, if it is not otherwise inconsis-
tent with the faithful performance of his/her duties,
from acting without compensation as agent or attorney
for any person in a disciplinary, loyalty, or other
Federal personnel administration proceeding involving
such person.
(b) Nothing in these Standards shall be deemed to pro-
hibit an employee from acting, with or without compensation,
as agent or attorney for that employee's parents, spouse,
child, or any person for whom, or for any estate for
which, the employee is serving as guardian, executor,
administrator, trustee, or other personal fiduciary, except
in those matters in which the employee has participated
personally and substantially as a Government employee,
through decision, approval, disapproval, recommendation,
the rendering of advice, investigation, or otherwise, or
which are the subject of his/her official responsibility,
as defined in section 202 (b) of Title 18, U.S.C., pro-
vided that the Vice President approves.
(c) Nothing in the Standards shall be deemed to prohibit
an employee from giving testimony under oath or from
making statements required to be made under penalty for
perjury or contempt.
(d) In addition to the exemptions and exceptions
described in this section and in §9, the conflict of
interest statutes permit certain exemptions and exceptions
in specific circumstances. The procedure for effecting
such exemptions or exceptions is as follows:
(1) Any regular employee or special Government
employee who desires approval or certification
of his/her activities as provided for by section
205 of Title 18, U.S.C., shall make application
therefor in writing to the Counselor.
(2) A former employee, including a former special
Government employee, who desires certification
with regard to his/her activities under section 207
of Title 18, U.S.C., shall make application therefor
in writing to the Counselor.
(3) The Counselor for the Office shall report
promptly to the Vice President all matters reported
FORD
-9-
to the Counselor under these Standards
which require consideration of approvals,
certifications, or determinations provided
herein.
12. Salary of employee payable only by United States.
(a) No employee, other than a special Government
employee or an employee serving without compensation,
shall receive any salary, or any contribution to or
supplementation of salary, as ccmpensation for his/her
services as an employee, from any source other than the
Government of the United States, except as may be
contributed out of the treasury of any State, county,
or municipality ( cf. 18 U.S.C. 209).
(b) Nothing in this section shall be deemed to prohibit
an employee from continuing to participate in a bona
fide pension, retirement, group life, health, or accident
insurance, profit-sharing, stock bonus, or other employee
welfare or benefit plan maintained by a former employer,
nor from accepting contributions, awards, or other
expenses under Chapter 41 of Title 5, U.S.C. (the
former Government Employees Training Act)
13. Gifts, entertainment and favors.
(a) Except as provided in paragraph (b) of this section
an employee shall not solicit or accept, directly or
indirectly, any gift, gratuity, favor, entertainment,
honorarium, travel or accommodations expense or the like,
loan, or any other thing of monetary value from a person
who:
(1) Has, or is seeking to obtain, contractual
or other business or financial relations with
a Government agency;
(2) Conducts operations or activities which
are regulated by a Government agency; or
(3) Has interests which may be substantially
affected by the performance or non-performance
of the employee's official duties.
FORD :- LIBRARY GERALD
-10-
(b) Notwithstanding paragraph (a) of this section,
an employee may:
(1) Accept a gift, gratuity, favor, entertain-
ment, honorarium, travel or accommodation expense
or the like or other thing of monetary value from
a friend, parent, spouse, child or other close
relative when the circumstances make it clear that
the family relationships involved are the motivating
factor;
(2) Accept food or refreshments in the ordinary
course of a luncheon or dinner meeting or other
meeting where an employee may properly be in
attendance;
(3) Accept reimbursement for travel expenses in
connection with official Government duties from a
an organization which is exempt from taxation under
Section 501 (c) (3) of the Internal Revenue Code
of 1954, as amended. Before the acceptance of
such reimbursement, the employee shall provide the
Counselor with a written description of the reim-
bursement to be provided, for the Counselor's
approval. The Counselor shall keep a copy of this
report and the official response on file;
(4) Accept loans from banks or other financial
institutions on customary terms to finance proper
or usual activities of employees, such as home
mortgage loans; and
(5) Accept unsolicited advertising or promotional
materials such as pens, pencils, note pads,
calendars, or other items of nominal intrinsic
value.
(c) An employee shall not solicit contributions from
another employee for a gift to an employee in a
superior official position. An employee in a superior
official position shall not accept a gift presented as
a contribution from employees receiving less salary
than the official. An employee shall not make a
donation as a gift to an employee in a superior official
position (5 U.S.C. 7351). However, this paragraph
does not prohibit a voluntary gift of nominal value or
donation in a nominal amount made on a special occasion
such as marriage, illness or retirement.
FORD i LIBRAR DIVE
-11-
(d) A gift or gratuity, the receipt of which is
prohibited by paragraph (a) of this section, shall be
returned to the donor with a written explanation why
the return is necessary. A copy of the written
explanation shall be submitted to the Counselor for
tiling in the employee's Official Personnel Folder.
When return of a gift is not possible, the gift or
gratuity shall be submitted to the Counselor with a
written explanation why the return is not feasible. The
Counselor shall turn the gift or gratuity over to a public
or private charity or charitable institution and make a
record of its disposition.
(e) The Constitution (Art. 1, sec. 9, par. 8) prohibits
acceptance from foreign governments, except with the
consent of Congress of any emolument, office, or title.
The Congress has provided for the receipt and disposi-
tion of foreign gifts and decorations in 5 U.S.C. 7342.
See also Executive Order 11320, 31 F.R. 13739, and the
regulations pursuant thereto in 22 CFR Part 3 (as added
32 F.R. 6569). Any such gift or thing which cannot
appropriately be refused shall be submitted to the
Counselor for transmittal to the State Department.
14. Outside employment and other activity.
(a) An employee shall not engage in outside employment,
activities, or professional practice not compatible with
the full and proper discharge of the duties and responsi-
bilities of his/her Government employment. Incompatible
activities include, but are not limited to:
(1) Acceptance of a fee, compensation, gift,
payment of expense, or any other thing of
monetary value in circumstances in which
acceptance may result in, or create the appear-
ance of, a conflict of interest; or
(2) Outside employment which tends to impair
the employee's mental or physical capacity to
CERTIFICATE
FORD
perform his/her Government duties and responsi
bilities in an acceptable manner.
GERALD
(b) Within the limitations imposed by this section,
employees are encouraged to engage in teaching,
lecturing, and writing. However, an employee shall not,
either for or without compensation, engage in teaching,
lecturing, or writing that is dependent on information
obtained as a result of his/her Government employment,
except when that information has been made available to
the general public or will be made available on request.
or when the Vice President gives written authorization
-12-
for the use of non-public information on the basis
that the use is in the public interest.
(c) An employee shall not engage in outside employ-
ment under a State or local government, except in
accordance with applicable regulations of the Civil
Service Commission (5 CFR 735.203).
(d) Neither this section nor $13 precludes an employee
from:
(1) Receipt of bona fide reimbursement, unless
prohibited by law, for actual expenses for
travel and such other necessary subsistence as
is compatible with these Standards and for which
no Government payment or reimbursement is made.
However, an employee may not be reimbursed, and
payment may not be made on his/her behalf, for
excessive personal living expenses, gifts,
entertainment, or other personal benefits.
(2) Participation in the activities of national
or State political parties not proscribed by law.
(3) Participation in the affairs of, or acceptance
of an award for a meritorious public contribution
or achievement given by, a charitable, religious,
professional, social, fraternal, nonprofit educa-
tional or recreational, public service, or, civil
organization.
(e) An employee who intends to engage in outside
employment shall obtain the approval, through the
Counselor, of the Vice President. A record of each
approval under this paragraph shall be filed in the
employee's Official Personnel Folder.
(f) This section does not apply to special Government
employees, who are subject to the provisions of $20.
15. Use of Government property.
An employee shall not directly or indirectly use, or
allow the use of, Government property of any kind,
including property leased to the Government, for other
FORD is BENALD LIBRAR
-13-
than officially approved activities. An employee has
a positive duty to protect and conserve Government
property including equipment, supplies, and other
property entrusted or issued to him/her.
16. Misuse of information.
(a) For the purpose of furthering a private interest,
an employee shall not, except as provided in paragraph
(b) of $14 directly or indirectly use, or allow the use
of, official information obtained through or in connec-
tion with his/her Government employment which has not
been made available to the general public.
(b) An employee shall not divulge restricted official
information outside the Office, except as permitted
under the instructions pertaining thereto and at the
time authorized for its release.
17. Indebtedness.
An employee shall pay each just financial obligation ir
a proper and timely manner, especially one imposed by
law-such as Federal, State, or local taxes. For the
purpose of this section, a "just financial obligation"
means one acknowledged by the employee, or reduced to
judgment by a court, or one imposed by law, such as
Federal, State or local taxes; "in a proper and timely
manner" means in a manner which the Office determines
does not, under the circumstances, reflect adversely
on the Government as his/her employer. In the event
of dispute between an- employee and an alleged creditor,
this section does not require the Office to determine
the validity or amount of the disputed debt.
18. Gambling, betting, and lotteries.
An employee shall not participate, while on Government-
owned or leased property or while on duty for the
Government, in any gambling activity, including the
operation of a gambling device, in conducting a lottery
or pool, in a game for money or property, or in selling
or purchasing a numbers slip or ticket.
FORD & LIBRARY 070839
-14-
19. General conduct prejudicial to the Government.
(a) An employee shall not engage in criminal,
infamous, dishonest, immoral, or notoriously dis-
9 ceful conduct, or other conduct prejudicial to
the Government.
(b) Discrimination on the basis of race, color,
eligion, sex, or national origin is conduct pre-
judicial to the Government. An employee, while
acting in an official capacity, shall not directly
or indirectly authorize, permit or participate in
any action, event, or course of conduct which sub-
jects any person to discrimination, or results in
any person being discriminated against, on the basis
of race, color, religion, sex or national origin.
20. Conduct and responsibilities of special Government
employees.
(a) A special Government employee shall not use his/
her Government employment for a purpose that is, or
gives the appearance of being, motivated by the desire
for private gain for himself/herself or another person,
particularly one with whom the employee has family,
business, or financial ties.
(b) A special Government employee shall not use
inside information obtained as a result of his/her
Government employment for private gain for himself/
herself or another person. whether by direct action
or by counsel, recommendation, or suggestion to
another person, particularly one with whom the
employee has family, business, or financial ties.
For the purposes of this section, "inside information"
means information obtained under Government authority
which has not become part of the body of public
information.
(c) A special Government employee who engages in
teaching, lecturing, or writing, whether for or
without compensation, shall not for such purposes
make use of information obtained as a result of his/
her Government employment, except when that informa-
tion has been made available to the general public
or will be made available on request, or when the
Vice President gives written authorization for the
use of non-public information on the basis that such
use is in the public interest.
FORD 3 LIBRA OTV
-15-
(d) A special Government employee shall not use
his/her Government employment to coerce, or give
the appearance of coercing, a person to provide
financial benefit to such employee or another
person, particularly one with whom the employee
has family, business, or financial ties.
(e) Except as provided in paragraph (f) of this
section, a special Government employee, while so
employed or in connection with his/her employment,
shall not receive or solicit from a person having
business with the Office anything of value as a gift,
gratuity, loan, entertainment, or favor for himself/
herself or another person, particularly one with
whom the employee has family, business, or financial
ties.
(f) Notwithstanding paragraph (e) of this section,
a special Government employee shall be allowed the
same latitude as is authorized for regular Government
employees by paragraph (b) of §13.
(g) Attention of special Government employees is
directed to the provisions of 83, making the provi-
sions of these Standards generally applicable to
their activities.
21. Additional prohibitions - special Government employees.
(a) A special Government employee is subject to the
following major prohibitions.
(1) An employee may not, except in the
discharge of official duties --
(i) Represent anyone else before a
court or Government agency in a matter
in which the United States is a party or
has an interest and in which the employee
has at any time participated personally
and substantially for the Government
(18 U.S.C. 203 and 205), or
(ii) Represent anyone else in a matter
pending before his/her agency unless the
employee served there no more than 60
days during the previous 365 (18 U.S.C.
203 and 205). The employee is bound by
this restraint despite the fact that the
matter is not one in which the employee
has ever participated personally and
substantially.
FORD ; 076930 LIBRARY
-16-
(2) The employee may not, after his/her
Government employment has ended, represent any-
one other than the United States in connection with
a particular matter in which the United States is a
arty or has an interest and in which the employee
participated personally and substantially for the
Government (cf. 18 U.S.C. 207(a)).
(3) The employee may not, for one year after his/
her Government employment has ended, present any-
one other than the United States in connection with
a particular matter in which the United States is a
party or has an interest and which was within the
boundaries of the employee's official responsi-
bility during the last year of his/her Government
service (cf. 18 U.S.C. 207(b)). This temporary
restraint is permanent if the matter is one in
which the employee participated personally and
substantially. See paragraph (2) of this section.
22. Miscellaneous statutory provisions.
Each employee shall acquaint himself/herself with each
statute that relates to his/her ethical and other con-
duct as an employee of the Office and of the Government.
In particular, attention of employees is directed to
the following statutory provisions:
(a) Chapter II of Title 18, U.S.C., relating to
bribery, graft, and conflicts of interest, as appro-
priate to the employees concerned.
(b) The prohibition against- lobbying with appropriated
funds (18 U.S.C. 1913).
(c) The prohibitions against disloyalty and striking
(5 U.S.C. 7311, U.S.C. 1918).
(d) The prohibition against the employment of a
member of a Communist organization (50 U.S.C. 784).
(e) The prohibition against (1) the disclosure of
classified information (18 U.S.C. 798, 50 U.S.C. 783);
and (2) the disclosure of confidential information
(18 U.S.C. 1905).
(f) The provision relating to the habitual use of
intoxicants to excess (5 U.S.C. 7352).
GERALD FORD LIBRAPA
-17-
(g) The prohibition against the misuse of a
Government vehicle (31 U.S.C. 638a (c)
(h) The prohibition against the misuse of the
franking privilege (18 U.S.C. 1719).
(i) The prohibition against the use of deceit in an
examination of personnel action in connection with
Government employment (5 U.S.C. 1917).
(j) The prchibition against fraud or false statements
in a Government matter (18 U.S.C. 1001).
(k) The prohibition against mutilating or destroying
a public record (18 U.S.C. 2071).
(1) The prohibition against ccunterfeiting and forging
transportation requests (18 U.S.C. 508).
(m) The prohibitions against (1) embezzlement of
Government money or property (18 U.S.C. 641);
(2) failing to account for public money (18 U.S.C.
643); and (3) embezzlement of the money or property
of another person in the possession of an employee by
reason of his/her employment (18 U.S.C. 654).
(n) The prohibition against unauthorized use of
documents relating to claims from or by the Govern-
ment (18 U.S.C. 285).
(o) The prohibition against an employee acting as
the agent of a foreign principal registered under
the Foreign Agents Registration Act (18 U.S.C. 219).
(p) Prohibitions against certain kinds of political
activities (18 U.S.C. 602, 603, 606, 607).
III. Reporting of Employment and Financial Interests.
23. Reporting of employment and financial interests -
regular employees.
(a) Not later than 90 days after the effective
date of these Standards, an employee designated
in paragraph (d) of this section shall submit
to the Vice President a statement, on a form made
available in the Counselor's office, which sets
forth the following information:
GERALD ? FORD
-18-
(1) A list of the names of all corporations,
companies, firms, or other business enter-
prises, partnerships, nonprofit organizations,
and educational or other institutions with or
in which the employee, the employee's spouse,
minor child or other member of his/her immediate
household has--
(i) Any connection as an employee,
officer, owner, director, member,
trustee, partner, adviser or consultant;
or
(ii) Any continuing financial interest,
through a pension or retirement plan,
shared income, or other arrangement as
a result of any current or prior employ-
ment or business or professional
association; or
(iii) Any financial interest through the
ownership of stocks, stock options, bonds,
securities, or other arrangements including
trusts.
However, an employee need not report any
financial interest exempted under §9 (e)
as too remote or inconsequential to affect
the integrity of an employee's services
in a matter.
(2) A list of the names of the employee's credi-
tors and the creditors of his/her spouse, minor
child, or other member of the immediate household,
other than those creditors to whom they may be
indebted by reason of a mortgage on property
which the employee occupies as a personal
residence or to whom they may be indebted for
current and ordinary household and living expenses
such as those incurred for household furnishings,
an automobile, education, vacations, or the like.
(3) A list of the employee's interests and those
of his/her spouse, minor child or other member
FOR
of the immediate household in real property or
rights in lands, other than property which the
employee occupies as a personal residence.
GERALD
(b) For the purpose of this section "member of the
immediate household" means a full-time resident of the
employee's household who is related by blood.
-19-
(c) Each employee designated in paragraph (d) of
this section who enters on duty after the effective
date of these Standards shall submit such statement
not later than 30 days after the date of his/her
entrance on duty, but not earlier than 90 days after
such effective date.
(d) Statements of employment and financial interest
are required of the following:
(1) Employees paid at a level of the Executive
Schedule in subchapter II of chapter 53 of
title 5, U.S.C., except a Presidential appointee
required to file a statement of financial
interests under section 401 of Executive Order
No. 11222 of May 8, 1965.
(2) Employees in classified positions of
GS-13 or above, or the equivalent thereof.
(e) Changes in, or additions to, the information con-
tained in an employee's statement of employment and
financial interests shall be reported in a supplementary
statement as of June 30 each year. If no changes or
additions occur, a negative report is required. Not-
withstanding the filing of the annual report required
by this paragraph, each employee shall at all times
avoid acquiring a financial interest that could result,
or taking an action that would result in a violation
of the conflicts-of-interest provisions of these
Standards.
(f) If any information required to be included on a
statement of employment and financial interests or
supplementary statement, including holdings placed in
trust, is not known to the employee but is known to
another person, the employee shall request that other
person to submit the information in his/her behalf.
(g) Paragraph (a) of this section does not require
an employee to submit any information relating to his/
her connection with, or interest in, a professional
society or a charitable, religious, social, fraternal,
recreational, public service, civic, or political
organization or a similar organization not conducted
as a business enterprise. For the purpose of this
section, educational and other institutions doing
research and development or related work involving
grants of money from or contracts with the Government
FORD is LIBRO 07V3
-20-
are deemed "business enterprises" and are required
to be included in an employee's statement of employ-
ment and financial interests.
(h) The Office shall hold each statement of employment
and financial interests in confidence. Each person
designated to review a statement of employment and
financial interests under §25 is responsible for main-
taining the statement in confidence and shall not allow
access to, or allow information to be disclosed from,
a statement except to carry out the purpose of these
Standards. The Office may not disclose information
from a statement except as the Civil Service Commission
or the Vice President may determine for good cause
shown.
(i) The statements of employment and financial interests
and supplementary statements required of employees are
in addition to, and not in substitution for, or in
derogation of, any similar requirement imposed by law,
order, or regulation. The submission of a statement
by an employee does not permit the employee or any
other person to participate in a matter in which the
employee or the other person's participation is pro-
hibited by law, order, or regulation.
(j) An employee who believes that his/her position
has been improperly included as one requiring the sub-
mission of a statement of employment and finantial
interests is entitled to obtain a review of his/her
complaint under the Office's grievance procedure.
(k) This section does not apply to special Govern-
ment employees who are subject to the provisions of
$24.
24. Reporting of employment and financial interests -
special Government employees.
(a) A special Government employee shall submit to the
Vice President, through the Counselor, a statement of
employment and financial interests which reports (1)
all current Federal Government employment, (2) names
of all corporations, companies, firms, State or local
government organizations, research organizations, and
educational or other institutions in or for which he/
she is an employee, officer, member, owner, trustee,
director, adviser, or consultant, with or without
compensation, (3) those financial interests which the
Office determines are relevant in the light of the
FORD
07V1
-21-
duties the employee is to perform, and (4) the names
of all partnerships in which the employee is engaged.
(b) A statement required under this section shall be
submitted at the time of employment and shall be kept
current throughout the term of a special Government
employee's service with the Office. A supplementary
statement shall be submitted at the time of any
reappointment; a negative report will suffice if no
changes have occurred since the submission of the last
statement.
25. Reviewing statements of financial interests -- remedial
action.
(a) A designee of the Vice President shall review the
statements required by §23 and §24 to determine whether
there exists a conflict, or appearance of conflict,
between the interests of the employee or special
Government employee concerned and the performance of
his/her service for the Government. If the designee
determines that such a conflict or appearance of con-
flict exists, the designee shall provide the employee
with an opportunity to explain the conflict or
appearance of conflict. If the designee concludes
that remedial action should be taken, the statement
shall be referred to the Vice President, through the
Counselor, with the designee's recommendation for such
action. The Vice President after consideration of the
employee's explanation and such investigation as the
Vice President deems appropriate, shall direct appro-
priate remedial action if it is deemed to be necessary.
In the absence of a designation by the Vice President
the Counselor shall serve as designee hereunder.
(b) Remedial action pursuant to paragraph (a) of this
section may include, but is not limited to:
(1) Changes in assigned duties.
(2) Divestment by the employee of his/her
conflicting interest.
(3) Disqualification for a particular action.
(4) Exemption pursuant to paragraph (e) of
§9 or paragraph (d) of §11.
(5) Disciplinary action.
FORD a LIBRAR, 07V339
-22-
IV. Supplemental Regulations or Instructions
26. Supplemental regulations or instructions.
The Vice President may issue supplemental and imple-
menting regulations or instructions not inconsistent
with these Standards as necessary to carry out the
full purpose and intent of Executive Order 11222 and
these Standards as may be required by the particular
circumstances of the Office. Such regulations or
instructions may include, but are not limited to,
delegation of any authority allowed by law pertaining
to the functions placed upon the Vice President by
these Standards. Such regulations or instructions
must be made available to employees and special Govern-
ment employees in the same manner as these Standards
(see §4).
FORD is LIBRARY
APPENDIX A--CODE OF ETHICS
FOR GOVERNMENT SERVICE
Resolved by the House of Representatives (the Senate
concurring), That it is the sense of the Congress that the
following Code of Ethics should be adhered to by all Govern-
ment employees, including officeholders:
CODE OF ETHICS FOR GOVERNMENT SERVICE
Any person in Government service should:
1. Put loyalty to the highest moral principles and to
country above loyalty to persons, party, or Government
department.
2. Uphold the Constitution, laws, and legal regulations
of the United States and of all governments therein and never
be a party to their evasion.
3. Give a full day's labor for a full day's pay; giving
to the performance of his duties his earnest effort and best
thought.
4. Seek to find and employ more efficient and economical
ways of getting tasks accomplished.
5. Never discriminate unfairly by the dispensing of
special favors or privileges to anyone, whether for renumera-
tion or not; and never accept, for himself or his family,
favors or benefits under circumstances which might be construed
by reasonable persons as influencing the performance of his
governmental duties.
6. Make no private promises of any kind binding upon the
duties of office, since a Government employee has no private
word which can be binding on public duty.
7. Engage in no business with the Government, either
directly or indirectly, which is inconsistent with the
conscientious performance of his governmental duties.
8. Never use any information coming to him confidentially
in the performance of governmental duties as a means for making
private profit.
GERALD ? FORD
-2-
9. Expose corruption wherever discovered.
10. Uphold these principles, ever conscious that public
office is a public trust.
Passed July 11, 1958.
GERALD LISSED ? FORD
E-1(c)
Public Law 87-849
87th Congress, H. R. 8140
October 23, 1962
En Elit
76 STAT. 1119.
To strengthen the criminal laws relating to bribery, graft, and conficts of
interest, and for other purposes.
Be it enacted by the Senate and House of Representatives of the
United States of America in Congress assembled, That (a) so much Bribery,
graft,
of chapter 11 of title 18 of the United States Code as precedes section and
conflicts
214 is amended to read as follows:
of interest.
18 USC 201
"CHAPTER 11-BRIBERY, GRAFT, AND CONFLICTS OF at see.
INTEREST
"See
"201. Bribery of public officials and witnesses.
"202 Definicions.
"203 Compensation of Members of Congress, officers and others, in matters
affecting the Government
"204. Practice in Court of Claims by Members of Congress.
"205. Activities of officers and employees in claims against and other matters
affecting the Government.
"206. Exemption of retired othicers of the uniformed services.
*207. Disqualification of former officers and employees In matters cornected with
former duties or official respousibilities; disqualideation of partners.
"208. Acts affecting a personal financial interest.
"209. Salary of-Government-otüiciala- and employees payable only. by United-
States.
"210. Offer to procure appointive puolle office.-
211. Acceptance or solicitation in notain appointive public office
"212 Offer of loan or gratuity to benk examiner.
*213. Acceptance of loan or gratuity by bank examiner.
"214. Offer for procurement of Federal Reserve bank loan and discount of
commercial paper.
"213. Receipt of commissions or gifts for procuring loens.
"216. Receipt or charge of commissions or gifts for farm loan, land bank, or
amail business transactions.
"217. Acceptance of consideration for adjustment of farm indebtedness.
"218. Voiding transactions in violation of chapter; recovery by the United States.
"§ 201. Bribery of public officials and witnesses
"(a) For the purpose of this section:
as 'public official' means Member of Congress, or Resident Com- Definitions.
missioner, either before or after he has qualified, or an officer or
employee or person acting for or on behalf of the United States,
or any department, agency or branch of Government thereof,
including the District of Columbia, in any official function, under
or by authority of any such department, agency, or branch of
Government, or a juror; and
"person who has been selected to be a public official' means
any person who has been nominated or appointed to be & public
official, or has been officially informed that he will be so nominated
or appointed; and
" official act' means any décision or action on any question, mat-
ter, cause, suit, proceeding or controversy, which may at any time
be pending, or which may by law be brought before any public
official, in his official capacity, or in his place of trust or profit.
(b) Whoever, directly or indirectly, corruptly gives, offers or
promises anything of value to any public official or person who has
been selected to be a public official, or offers or promises any public
official or any person who has been selected to be A public official to
give anything of value to any other person or entity, with intent-
(1) to influence any official act: or
(2) to influence such public official or person who has been
solected to be a public official to commit or aid in committing,
or collude in, or allow, any fraud, or make opportunity for the
commission of any fraud, on the United States: or
FORD
GERALD
ABOVEIT
1.
Pub. Law 87-849
October 23, 1962
'75 STAT. 1120.
"(3) to induce such public official or such person who has
been selected to be a public official to do or omit to do any act
in violation of his lawful duty, or
"(c) Whoever, being a public official or person selected to be a
public official, directly or indirectly, corruptly asks, demands, eracts,
solicits, seeks, accepts, receives, or agrees to receive anything of value
for himseif or for any other person or entity, in return for:
(1) being influenced in his performance of any official act; or
(2) being influenced to commit or sid in committing, or to
collude in, or allow, any fraud, or make opportunity for the
commission of any fraud, on the United States; or
(3) being induced to do or omit to do any act in violation of
his official duty; or
(d) Whoever, directly or indirectly, corruptly gives, offers,
or promises anything of value 10 any person, or one 3 or promises
such person to give anything of value to any other person or entity,
with intent to influ nce the testimony under oath or altirmation of
such first-inentioned person as a witness upon a trial, hearing, or other
proceeding, before any court, any committee of either House or both
Houses of Congress, or any agency, commission, or officer authorized
by the laws of the United States to hear evidence or take testimony,
or with intent to influence such person to absent himself therefrom; or
"(e) Whoever, directly or indirectly, corruptly asks, demands,
exacts, solicits, seeks, accepts, receives, or agrees to receive anything
of value for himself or for any other person-or-entity in return for
being influenced in his testimony under oath or affirmation as a wit-
ness upon any such trial, hearing, or other proceeding, or in return
for absenting himself therefrom—
"Shall be fined not more than $20,000 or three times the monetary
equivalent of the thing of value, whichever is greater, or imprisoned
for not more than fifteen years, or both, and may be disqualified from
holding any office of honor, trust, or profit under the United States.
(f) Whoever, otherwise than as provided by law for the proper
discharge of official duty, directly or indirectly gives, offers, or
promises anything of value to any public official, former public official,
or person selected to be a public official, for or because of any official
act performed or to be performed by such public official, former
public official, or person selected to be a public official; or
"(g) Whoever, being a public official, former public official, or
person selected to be a public official, otherwise than as provided by
law for the proper discharge of official duty, directly or indirectly
asks, demands, exacts, solicits, seeks, accepts, receives, or agrees to
receive anything of value for himself for or because of any official act
performed or to be performed by him; or
"(h) Whoever, directly or indirectly, gives, offers, or promises any-
thing of value to any person, for or because of the testimony under
oath or affirmation given or to be given by such person as a witness
upon a trial, hearing, or other proceeding, before any court, any
committee of either House or-both Houses of Congress, or any agency,
commission, or officer authorized by the laws of the United States to
hear evidence or take testimony, or for or because of his absence
therefrom; or
"(i) Whoever, directly or indirectly, asks, demands, exacts, solicits,
seeks, accepts, receives, or agrees to receive anything of value for
himself for or because of the testimony under oath or affirmation given
or to be given by him as R witness upon any such trial, hearing, or
other proceeding, or for or because of his absence therefrom-
"Shall be fined not more than $10,000 or imprisoned for not more
than two years, or both.
GERALD LIBRARY ? FORD
October 23, 1962
Pub. Law 87-849
75. STAT. 1121.
"(i) Subsections (d), (a), (h), and (i) shall not be construed to
prohioit the payment or receipt of witness fees provided by law, or
the payment, by the party upon whose behalf a witness is called and
receipt by a witness, of the reasonable cost of travel and subsistance
incurred and the reasonable value of time lost in attendance at any
such trial, hearing, or proceeding, or, in the case of expirt witnesses,
involving a technical or professional opinion, a reasonable fee for time
spent in the preparation of such opinion, and in appearing and
testifying.
"(½) The offenses and penalties prescribed in this section are seos-
rate from and in addition to those prescribed in sections 1303, 1504,
and 1505 of this tide.
62 Stat. 759.
"S 202 Definitions
"(a) For the purpose of sections 203, 205, 207, 208, and 209 of this
title the term 'special Government employee' shall mean an officer or
employee of the executive or legislative branch of the United States
Government, of any independent agency of the United States or of
the District of Columbia, who is retained, designated, appointed, or
employed to perform, with or without compensation, for not to exceed
one hundred and thirty days during any period of three hundred and
sixty-five consecutive days, temporary duties either on a full-time
or intermittent basis, or n part-time United States Commissioner.
Notwithstanding the next preceding sentence, every person serving as
a part-time local representative of a Member of Congress in the
Member's home district or State shall be classified as a special Gov-
ernment employee. Notwithstanding section 20 (c) and (d) of the
Act of August 10, 1956 (TOA Stat. 632; 5 U.S.C. 30r (c) and (d)),
a Reserve officer of the Armed Forces, or an officer of the National
Guard of the United States, unless otherwise an officer or employee of
the United States, shall be classified as a special Government employee
while on active duty solely for training. A Reserve officer of the
Armed Forces or an officer of the National Guard of the United States
who is voluntarily serving a period of extended active duty in excess
of one hundred and thirty days shall be classified as an officer of the
United States within the meaning of section 203 and sections 205
through 200 and 218. A Reserve officer of the Armed Forces or an
officer of the National Guard of the United States who is serving
involuntarily shall be classified as a special Government employee.
The terms 'officer or employed' and 'special Government employee' as
used in sections 203, 205, 207 through 209, and 218, shall not include
enlisted members of the Armed Forces.
"(b) For the purposes of sections 205 and 207 of this title, the
term 'official responsibility' means the direct administrative or oper-
ating authority, whether intermediate or final, and either exercisable
alone or with others, and either personally or through subordinates,
to approve; disapprove, or otherwise direct Government action.
"§ 203. Compensation to Members of Congress, officers, and others
in matters affecting the Government
"(a) Whoever, otherwise than as provided by law for the proper
discharge of official duties, directly or indirectly receives or agrees to
receive, or asks, demands, solicits, or seeks, any compensation for any
services rendered or to be rendered either by himself or another-
"(1) at a time when he is a Member of Congress, Member of
Congress Elect, Resident Commissioner, or Resident Commis-
sioner Elect; or
"(2) at A time when he is an officer or employee of the United
States in the executive, legislative, or judicial branch of the Gov-
ernment, or in any agency of the United States, including the Dis-
trict of Columbia,
GERALD FORD
Pub. Law 37-849
75 STAT. 1122.
October 23, 1962
in relation to any proceeding, application, request for a ruling or other
determination, contract, claim, controversy, charge, accusation, arrest,
or other particular matter in which the United States is 2 party or has
a direct and substantial interest, before nny department, agency, court-
martial, officer, or any civil, military, or naval commission, or
"(b) Whoever, knowingly, otherwise than as provided by law for
the proper discharge of official duties, directly or indirectly gives,
promises, or offers any compensation for any such services rendered
or to be rendered at a time when the person to whom the compensation
is given, promised, or offered, is or was such a Member, Commissioner,
officer, or employee-
"Shall be fined not more than $10,000 or imprisoned for not more
than two years, or both; and shall be incapable of holding any office of
honor, trust, or profit under the United States.
"(c) A special Government employee shall be subject to subsection
(a) only in relation to a particular matter involving a specific party
or parties (1) in which he has at any time participated personally
and substantially as a Government employee or as a special Govern-
ment employee through decision, approval, disapproval, recommenda-
tion, the rendering of advice, investigation or otherwise, or (2) which
is pending in the department or agency of the Government in which
he is serving: Provided, That clause (2) shall not apply in the case
of a special Government employee who has served in such department
or agency no more than sixty days during the immediately preceding
period of three hundred and sixty-five consecutive days.
"§ 204. Practice in Court of Claims by Members of Congress
"Whoever, being a Member of Congress, Member of Congress Elect,
Resident Commissioner, or Resident Commissioner Elect, practices in
the Court of Claims, shall be fined not more than $10,000 or imprisoned
for not more than two years, or both, and shall be incapable of holding
any office of honor, trust, or profit under the United States.
"§ 205. Activities of officers and employees in-claims against and
other matters affecting the Government
"Whoever, being an officer or employee of the United States in the
executive, legislative, or judicial branch of the Government or in
any agency of the United States, including the District of Columbia,
otherwise than in the proper discharge of his official duties-
"(1) acts as agent or attorney for prosecuting any claim against
the United States, or receives any gratuity, or any share of or
interest in any such claim in consideration of assistance in the
prosecution of such claim, or
"(2) acts as agent or attorney for anyone before any depart-
ment, agency, court, court-martial, officer, or any civil, military,
or naval commission in connection with any proceeding, appli-
cation, request for n ruling or other determination, contract,
claim, controversy, charge, accusation, arrest, or other particular
matter in which the United States is & party or has a direct and
substantial interest—
"Shall be fined not more than $10,000 or imprisoned for not more
than two years, or both.
"A special Government employee shall be subject to the preceding
paragraphs only in relation to a particular matter involving a specific
party or parties (1) in which he has at any time participated per-
sonally and substantially as n Government employee or as a special
Government employee through decision, approval, disapproval, recom-
mendation, the rendering of advice, investigation or otherwise, or (2)
which is pending in the department or agency of the Government in
which he is serving: Provided, That clause (2) shall not apply in the
FORD
GERALD
October 23, 1962
Pub. Law 87-849
75 STAT. 1123.
case of u special Government employee who has served in such depart-
ment or agency no more than sixty days during the immediately pre-
ceding period of three hundred and sixty-five consecutive days.
"Nothing herein prevents an officer or employee, if not inconsistent
with the faithful performance of his duties, from acting without com-
pensation 33 agent or attorney for any person who 13 the subject of
disciplinary, loyalty, or other personnel administration proceedings
in connection with those proceedings.
"Nothing herein or in section 203 prevents an officer or employee,
including = special Government employee, from acting, with or with-
out compensation, as agent or attorney for his parents, spouse, child,
or any person for whom, or for any estate for which, he is serving as
guardian, executor, administrator, trustee, or other personal fiduciary
except in those matters in which he has participated personally and
substantially as a Government employee, through decision, approval,
disapproval, recommendation, the rendering of advice, investigation,
or otherwise, or which are the subject of his official responsibility,
provided that the Government official responsible for appoir tment to
his position approves.
"Nothing herein or in section 203 prevents a special Government
employee from acting as agent or attorney for another person in the
performance of work under a grant by, or a contract with or for
the benefit of, the United States provided that the head of the depart-
ment or agency concerned with the grant or contract shall certify in
writing that the national interest so requires.
"Such certification shall be published in the Federal Register.
Publication in
"Nothing herein prevents an officer or employee from giving testi- F. R.
mony under oath or from making statements required to be made
under penalty for perjury or contempt.
"§ 206. Exemption of retired officers of the uniformed services
"Sections 203 and 205 of this title shall not apoly to a retired
officer of the uniformed services of the United States while not on
active duty and not otherwise an officer or employee of the United
States, or to any person specially excepted by Act of Congress.
"§ 207. Disqualification of former officers and employees in
matters connected with former duties or official respon-
sibilities; disqualification of partners
"(a) Whoever, having been an officer or employee of the executive
branch of the United States Government, of any independent agency
of the United States, or of the District of Columbia, including a
special Government employee, after his employment has ceased, know-
ingly acts as agent or attorney for anyone other than the United States
in connection with any judicial or other proceeding, application,
request for a ruling or other determination, contract, claim, contro-
versy, charge, accusation, arrest, or other particular matter involving
a specific party or parties in which the United States is a party or has
a direct and substantial interest and in which he participated per-
sonally and substantialiy as an officer or employee, through decision,
approval, disapproval, recommendation, the rendering of advice,
investigation, or otherwise, while so employed, or
"(b) Whoever, having been so employed, within one year after his
employment has cersed, appears personally before any court or depart-
ment or agency of the Government as agent, or attorney for, anyone
other than the United States in connection with any proceeding, appli-
cation, request for a ruling or other determination, contract, claim,
controversy, charge, accusation, arrest, or other particular matter
involving a specific party or parties in which the United States is a
party or directly and substantially interested, and which was under
FORD
GERALD
)
Pub. Law 87-849
October 23, 1962
75 STAT. 1124.
his official responsibility as an officer or employee of the Govern-
ment at any time within a period of one year prior to the termination
of such resconsibility-
"Shall be fined not more than $10,000 or imprisoned for not more
than two years, or both: Provided, That nothing in subsection (a)
or (b) prevents 3 former officer or employee, including a former
special Government employee, with outstanding scientific or tech-
nological qualifications from acting as attorney or agent or appearing
personally in connection with a particular matter in a acientific or
technological field if the head of the department or agency concerned
with the matter shall make a certification in writing, published in the
Publication in
Federal Register, that the national interest would be served by such
F.R.
action or appearance by the former officer or employee.
"(c) Whoever, being a partner or an officer or employee of the
executive branch of the United States Government, of any independ-
ent agency of the United States. or of the District of Columbia, includ-
ing 3 special Government employee, acts as agent or attorney for any-
one other than the United States, in connection with any judicial or
other proceeding, application, request for a rali g or other determina-
tion, contract, claim, controversy, charge, accusation, arrest, or other
particular matter in which the United States is a party or has a direct
and substantial interest and in which such officer or employee of the
Government or special Government employee participates or has par-
ticipated personally and substantially as a Government employee
through decision, roproval disapproval, recommendation, the render-
ing of advice, investigation or otherwise, or which is the subject of his
official responsibility-
"Shall be fined not more than $5,000, or imprisoned not more than
one year, or both.
"A partner of a present or former officer or employee of the execu-
tive branch of the United States Government, of any independent
agency of the United Scates, or of the District of Columbia or of n
present or former special Government employee shall as such be sub-
ject to the provisions of sections 203, 205, and 207 of this title only as
expressly provided in subsection (c) of this section.
"§ 208. Acts affecting a personal financial interest
"(a) Except as permitted by subsection (b) hereof, whoever, being
an officer or employee of the executive branch of the United States
Government, of any independent agency of the United States, or of the
District of Columbia, including a special Government employee
participates personally and substantially as a Government officer or
employee, through decison, approval, disapproval, recommendation,
the rendering of advice, investigation, or otherwise, in a judicial or
other proceeding, application, request for a ruling or other deter-
mination, contract, claim, controversy, charge, accusation, arrest, or
other particular matter in which. to his knowledge, he, his spouse,
minor child, partner, organization in which he is serving as officer,
director, trustee, partner or employee, or any person or organization
with whom he is negotiating or has any arrangement concerning
prospective employment, has a financial interest-
"Shall be fined not more than $10,000, or imprisoned not more than
two years, or both.
(b) Subsection (a) hereof shall not apply (1) if the officer or
employee first advises the Government official responsible for appoint-
ment to his position of the nature and circumstances of the judicial
or other proceeding, application, request for a ruling or other deter-
mination, contract, claim, controversy, charge, accusation, arrest, or
other particular matter and makes full disclosure of the financial
interest and receives in advance a written determination made by such
FORD,
GERALD
IBRARY
October 23, 1962
Pub. Law 37-849
76 STAT. 1125.
official that the interest is not so substantial as to be deemed likely to
affect the integrity of the services which the Government may expect
from such officer or employee, or (2) if, by general rule or regulation
published in the Federal Register, the financial interest has been Publication in
exempted from the requirements of clause (1) hereof as being too F. R.
remote or too inconsequential to affect the integrity of Government
officers' or employees' services.
"§ 209. Salary of Government officials and employees payable only
by United States
"(2) Whoever receives any salary, or any contribution to or supple-
mentation of salary, as compensation for his services as an officer or
employee of the executive branch of the United States Government,
of any adependent agency of the United States, or of the District of
Columbia, from any source other than the Government of the United
States, except as may be contributed out of the treasury of any State,
county, or municipality; or
"Whoever, whether an individual, partnership, association, corpo-
ration, or other organization pays, or makes any contribution to, or in
any way supplements the salary of, any such officer or employee under
circumstances which would make its receipt a violation of this sub-
section-------
"Shall be fined not more than $5,000 or imprisoned not more than
one year, or both.
" (b) Nothing herein prevents an officer or employee of the executive
branch of the United States Government, or of any independent
agency of the United States, or of the District of Columbia, from con-
tinuing to participate in a bona fide pension, retirement, group life,
health or accident insurance. profit-sharing, stock bonus, or other
employee welfare or benefit plan maintained by a former employer.
(c) This section does not apply to a special Government employee Exception.
or to an officer or employee of the Government serving without com-
pensation, whether or not he is a special Government employee, or to
any person paying, contributing to, or supplementing his salary as
such.
(d) This section does not prohibit payment or acceptance of con-
tributions, awards, or other expenses under the terms of the Govern-
ment Employees Training Act (Public Law 85-507, 72 Stat. 327; 5
U.S.C. 2301-2319, July 7, 1053)."
(b) Sections 214 and 215 of chapter 11 of title 18 of the United
States Code are respectively redesignated sections 210 and 211;
(c) Sections 216 and 223 of chapter 11 of title 18 of the United Raptal.
States Code are repealed;
(d) Sections 217, 218, 219, 220, 221, and 222 of chapter 11 of title 18
of the United States Code are respectively redesignated sections 212,
213, 214, 215, 216, and 217;
(e) Chapter 11 of title 18 of the United States Code is further 18 USC 201
amended by adding at the end thereof the following new section: et saq.
"§ 218. Voiding transactions in violation of chapter; recovery by
the United States
"In addition to any other remedies provided by law the President
or, under regulations prescribed by him, the head of any department-
or agency involved, may declare void and rescind any contract, loan,
grant, subsidy, license, right, permit, franchise, use, authority,
privilege, benefit, certificate, ruling, decision, opinion, or rate schedule
awarded, granted, paid, furnished, or published, or the performance
of any service or transfer or delivery of any thing to, by or for any
agency of the United States or officer or employee of the United
States or person acting on behalf thereof, in relation to which there
GERALD FORD
Pub. Law 87-849
October 23, 1962
76 STAT. 1126.
has been a final conviction for any violation of this chapter, and the
United States shall be entitled to recover in addition to any penalty
prescribed by law or in a contract the amount expended or the thing
transferred or delivered on i:3 behalf, or the reasonable value thereof.
Repaal.
Sac. 2. Sections 281 and 233 (except AS they may apply to retired
officers of the armed forces of the United States), 252 and 234 of
chapter 15 of title 18, section 104 of chapter 23 of title 13, and section
1914 of chapter 03 of title 18 of the United States Code are repealed
and will, respectively, be supplanted by sections 203, 203, 20+, 207,
208, and 200 of title 18 of the United States Coda as set forth in section
Exemptions.
1 of this Act. All exemptions from the provisions of sections 2S1, 282,
283, 234, 134, or 1914 of title 18 of the United States Code heretofore
created or authorized by statute which are in force on the effective
date of this Act shall, on and after that date, is deemed to be exemo-
tions from sections 203, 204, 205, 207, 208, or 269, respectively, of litle
18 of the United States Code except to the extent that they affect
officers or employees of the executive branch of the United States
Government, of 2.,ty independent agency of the United States, or of
the District of Columbia, as to whom they are no longer applicable.
Repeal.
Sec. 8. Section 100 of the Revised Statutes (5 U.S.C.99) is repealed.
Effective date.
SEC. 4. This Act shall take effect ninety days after the date of its
enactment.
Approved October 23, 1962.
FORD
GERALD
IBRARY
". & GOVERNMENT PRINTING OFFICE: 1974 0 361-434
STANDARDS OF CONDUCT
FOR THE
WHITE HOUSE STAFF
TABLE OF CONTENTS
Paragraph
1. Introduction
1
2. Conflicts of Interest
2
3. Financial Interests and Activities
3
4. Gifts, Loans, Entertainment and Favors
5
5. Reimbursement of Travel, Lodging and Related Expenses While on
Official Business
6
6. Gifts, Decorations and Awards from Foreign Governments
7
7. Honoraria and Compensation for Speeches, Teaching and Writing
7
8. Lobbying
8
9. Disclosure or Use of Official Information
9
10. Political Activities
10
11. Contact With Independent Regulatory Agencies and Procurement
Agencies
11
12. Standards for Departing Personnel
12
13. Statutory and Executive Requirements
Enclosure E-1
Executive Order 11222(a)
U.S. Code, Title 3, Part 100(b)
Public Law 87-349(c)
GERALD FORD LIBRARA
Intranuction
tion the integrity of the government and its Jiii-
cials, the harm is done. In such instances. even if
of this document is to acquaint you
there was no impropriaty intended or proced,
of the othical concepts and legal TO-
the Administration or members of the stad mar :-
strictions applicable to you as it member of the
required to spend an inordinate amount of time
White House Office staff. It is hoped that by being
explaining or defending innocent actions rather
aware of these standards of official conduct, you
than implementing the objectives of the President
will by able to recognize and avoid conflict of inter-
and 2 cloud may be case over the merits of our
tor improper conduct situ. ors you may
decisions. All staf members must, therefore, be
encounter, and will be alect to seek assistance in
constantly aware of improper "appearances" as
resolving any questions that may arise. Please note
well as actual conflicts when dealing with others
that this memorandum is not designed to cover all
in or outside of the government.
simplies and problems with which you may be
confronted; rather it, is only intended to highlight
For each area of conduct discussed herein, more
detailed information and assistance can be ob-
in general terms some of the most reoccurring is-
tained from the OEce of the Counsel to the Presi-
sues with which you may be confronted.
The official regulation governing the standards
dent. Whenever you have 2 problem or question in
of conduct for the White House Office is set forth
this regard, you should immediately contact that
Office for a resolution of the matter.
in 3 OFR Chapter V, Part 100. This regulation was
issueri parsuant to Executive Order 11222 which
prescribes general standards of ethical conduct for
2. Conflicts of Interest
all government officers and employees. Copies of
the regulation and the Executive Order are at-
A conflict of interest may exist whenever a mem-
tached. It is strongly suggested that they be read
ber of the staff has a personal or private interest
thoroughly as soon as possible, and retained for
in a matter which is related to his official duties
your further reference in addition, you should be
and responsibilities or the activities of the staff.
with the tututes relating
The major prohibitions to which you are subject
to
dards of conduct and conflicts of interest,
in order to avoid such situations may be stated
which are also included in the materials provided.
generally as follows:
As = general statement of guidance, it might be
(a) You may 200 participate in your official
said that the statutes and regulations which are ap-
capacity in any matter in which you, your
plicable to you as a member of the staff are directed
spouse, minor child. outside business associate or
to insuring the achievement of the following
person with whom you are negotiaring for am-
objectives:
ployment has 2 financial interest.
(2) the fair, impartial and equal treatment of
(b) You may not receive anji salary, or sup-
those dealing with the government;
plementation of your government salary, from
(4) government decisions
a private source as compensation for your serv-
an employee's private
ices to the government. You may. however,
daterests;
continue to participate in a bona fide pension,
(c) the maintenance of public confidence in
retirement, group life. health, or accident in-
the integrity of government operations;
surance, profit-sharing. stock bonus, or other
(d) the prevention of use of public office for
employee welfare or benefit plan maintained by
private gain; and
a former employer. But such is financial interest
(e) the prevention of any impediment to the
disqualifies you under phragraph :a) in the
economy of government business.
absence of a waiver.
At the outset you should be also aware of one
(c) You may not. except in the discharge of
very apartant factor which is relevant in every
your official duties. represent anyone else before
matter discussed in this document and which
a government agency 00 1 court in = matter in
should always be part of your evaluation of any
which the United States is it party or has an
,"U:- encounter: Ic is just as important to
interest. This probibition applies kord to paid
.? appearance of 'L conflict or unethical
and unpaid representation of another.
FORD
ac actual Conduct may in short of
Stated another Tax. government personal
i: 16 levis Line Alc to ques-
should 11:30 step 02: of taeis official role and :ICE
is 3 private capacity to assist privace parties in
qualifying. However, you should not toly it upon
dealings with the government, whether for
yourrelf to make such 2 decision, rather you should
-nsation 0: not. ,1130. a public official-must
submit the matter to: review.
in a position of seting for the government
Each staff member viso is paid # 12:-1 guive-
whom his private interests are involved, nor should
lent to GS-13 or above, is required :-) subject is the
le receive payments from private sources for the
Counsel to the President, within 30 days siter his
performance of his governmental duties.
entrance on duty, or promocion, = confidential
You will also nota in reading the standards of
statement which discloses all his personal employ-
conduct regulations that there are some specific
ment and Enancial interests and activities as well
exceptions to these prohibitions. If you feel they
as those of his spouse, minor children and members
are applicable to your situation, this should be
of his immediate family.
immediately reviewed with the Counsel to the
Those filing such statements are required to re-
President.
port any significant changes, and all ANGE Ela a
It should be again stressed that it is of utmost
supplementary statement as of June 30 of each
importance to the maintenance of public confi-
year, even if no changes or addition: have
dence in the government that you avoid not only
occurred.
these specific prohibitions, but also any conduct or
These statements are reviewed by the Col asel
activity which would give the appearance of a
to the President to determine whether , confict,
conflict or use of your position for the furtherance
or appearance of conflict, exists between c.ve inter
of personal goals or interests.
ests of the sceff member and the performance 01
his duties, and r:commendations for remedisi ac-
3. Financial Interasts and Activities
tions are made where appropriate. These state-
ments are held in confidence and no information
As isnoted generally above, a White House staff
contained therein may be disclosed except by di-
member may not participate in his official capacity
rection of the President for good cause shown.
in any decision, recommendation or similar activ-
If you are required to file such a statement, the
ity involving any matter in which he has a "finan-
appropriate forms should have been supplied to
cial interest." Further, a staff member may not
you upon your entrance on duty. Please consult
have financial interests which are entered into as
with the Counsel to the President if you have any
a result of information obtained through his
questions or need specific advice or guidance re-
employment.
garding the retention of former employee benefits,
Under this restriction a "financial interest" in-
possible divesture of holdings, or any problems
cludes not only that which you may have, but also
related to the establishment of trusts or other
that of your spouse, minor child, partner, organi-
financial arrangements which might be necessary
zation in which you have any significant interest,
to avoid (e. conflict of interest with your position.
or any person or organization with whom you are
Please nota that the fact that a staff member
negotiating or have any arrangement concerning
might not be required to file such a statement does
future employment (including, of course, any con-
not relieve him of the obligation to refrain from
pany from which you may have a leave of
participation in any matter in which he or his
absence).
If you have a financial interest which is in-
immediate family or business associates may have
a financial interest. Also, although these state-
volved or may be affected by a matter on which
ments are a form of notice of a staff member's
you are to work, you may not SO participate until
financial and employment interests, this should not
you have reviewed the situation with the Counsel
be considered to relieve him of the requirement
to the President and received a written determina-
to disclose his financial interest in a matter upon
tion that your interest is not so substantial as to
which he is called to work and to refrain from any
by in conflict with your performance in that
further participation until the question of possible
conflict of interest is resolved.
Obviously, most funancial interests are in the
focus of ownership of investment property or
4. Gifts, Loans, Entertainment and Favors
stocks and bonds, or = directorship or similar posi-
don in a company or organization. Quite often,
Federal statures prohibit your acceptance of i
such interests are not SO signiticant as to be dis-
gift from a fellow employee receiving less pay thua
FORD
GERALD
LIBRARY
is
to law to solicit
intrinsic value, such 23 pens, pencils, note puls,
rifts to all employee in a superior
calenders, etc. As .- Title of rhumb, gites having
or to individually give such : gift
a value of 310 or less are considered w be of
0:
These restrictions are designed to
"nominal value." Please note that if the item is
22X question that :! person might attempt
not of an advertising of promotional nature, it
to gein favor with a superior by the giving of a
should is returned, regardiess of its retus, unless
gift, and also to resolve that no such gifts are
there is another justification for its retencion.
expected, and therefore are not interpreted to pre-
Nor do these rules preclude your acceptance of
chula the exchange nf of nominal value be-
food or refreshments of nominal value in the ordi-
www.inrs particular office on
nary course of a luncheon or dinner meeting, or
traditional occasions.
while in attendance at 2 function where you are
Members of the White Bouse staff may not solicit
otherwise properly in attendance.
10: accept 2 air favor, administment, loan or any
Likewise, you are obviously not precluded from
otherthing of imonetary value from any corpora-
accepting loans from financial institutions on
tion or person who has or is seeking contractual or
customary terms for use in financing the pur-
business dealings with any department or agency
chase of a home, automobile or incurring similar
in the Executive Branch, or who cond activities
expenditures.
which are regulated by any department or agency
in the Executive Branch, or who has any interests
5. Reimbursement of Travel, Lodging and Reioted
which be substantially affected by the per-
Expenses While on Official Business
formacre of your job. This latter group may in-
clude persons in the federal government 23 well as
When a staff member is travelling on official
those outside the government.
business, the general rule is that it is not permissi-
ble for him to accept hotel accommodations or
There are, of course, some exceptions to these
reimbursement for transportation or lodging ex-
prohibitions. You may consider accepting a rea-
penses from any person or non-governmental
sonable gift or entertainment from a close per-
organization. Likewise, it is not permissible to
ist" tend or relative who lms dealings with the
accept transportation in private aircraft. There
go
clear that the motivation
are sicuations, however, in which the staff member
for the gift is the personal relationship. However,
may, under limited conditions, accept either trans-
in such it case, due consideration must be given to
portation reimbursement or accommodations. For
avoiding an appearance of a conflict of interest. If,
example, a-statf member could accept an invitation
for example, the representative of a company
to stay at the private residence of his host it, this
Juving extensive government contracts is a neigh-
would be appropriate under the circumstances or
bor with whom you have been socially close and ex.
his visit. In judging the propriety of staying at
changed Christmas gifts for years, there would be
the private residence of a close personal friend or
no real conflict in accepting a gift offered. How-
any other person, the normal rules apply and the
exer, if the appearance created by receipt of such
staff member may accept only when this will not
in create a problem, then it would be
create u conflict or appearance of conflict with his
best-not to accept. ise gift. Again, appearances of
position or otherwise be 21. source of embarrass-
conflict often crente greater problems than true
ment to the President.
conflicts.
Any proscribed gift should be returned to the
6. Gifts, Decorations and Awards From Foreign
donor, accompanied by a written explanation of
Governments
the reasons for its necessary return. It is recom-
The Constitution prohibits acceptance from
used youretain 11 copy of this letter in your
foreign governments. except with the consent of
return of a gift is not possible
Congress. of any emoiument, office, or title. Con-
Inr any reason, the gift should be forwarded to the
gress has provided that a staff member may keep
Office of the Counsel to the President with 2 writ-
courtesy or souvenir gifts of minimal value and
ten explanation of the infeasibility of its return.
that a staff member may accept a gift of more
The gift. will then be turned over to charity.
than minimal value on behalf of the U.S. Govern-
Y
e not prechuled from accepting unsolic-
ment, if is concludes that ii would cause offense
tising or promotional items of IL cominal
or embarrassment ii) the docor or adversely affect
FORD
P.
LIBRARY
relations if refused.-Any such gift which
(s) National Security Information
cannos appropriately be refused becomes the prop-
The disclosure of classified national security in-
:: the government and should be submitted
formation to unauthorized persons is scrietly pro-
immediately to the Connsel to the President for
hibited by Iew. and violators they be prosecuted
transmittal to the State Department.
and discharged. The term "medional security
information" refers to defense information classi-
% Honoraria end Compansation for Speeches,
Toaching and Writing
fied pursuint to Executive Order 19501 which
bears the markings "Confidencial," "Secret" or
As a general policy, a White House staff mem-
"Top Secret," mistricted data classified under the
ber should not accept an honorarium or compensa-
Atomic Energy Act of 1054 which bears the mark-
tion for speeches, lectures, teaching or writing on
ing "Restricted Data Atomic Energy Act of 1054,"
2 subject which is in any way related to his oficial
and classified crypromaterial which bears mark-
position or to the operations or activities of the
ings as authorized by the appropriate agencias,
White House staff or the Executive Office of the
Materials classified in this manner invoive in-
President.
formation concerning national defense, interna-
This restriction does not preclude the acceptance
tional relations and cryptology, the unauthorized
of an award for a meritorious public contribution
disclosures of which could be prejudicial or dam-
or achievement given by a charitable, professional,
aging to United States security interests.
religious, nonprofit, educational, civic or similar
It should be noted that the terms designated to
organization, but you should consult with the
identify such classified information (e.g., "Con-
Counsel to the President before accepting any such
fidential," "Sarch" and "Top Secret") should not
award which entails a monetary grant or which
be used on documents which do not fall within
may raise a question of conflict of interest.
the respective dednitions.
8. Lobbying
(b) Confdential Business and Personal Injorma-
The direct or indirect use of uppropriated funds
tion
for lobbying activities without express authoriza-
A number of statutes and regulations restrict
tion by Congress is prohibited by law. This in-
the disclosure by federal officials to unauthorized
cludes use of appropriated funds to pay for per-
persons of certain confidential information which
sonal services, advertisements, communications or
businesses or individuals disclose othicially to "
devices of any kind to influence a Member of Con-
federal agency or employee. Such information is
gress in acting upon legislation. Violators of this
not formally classified but still must be treated in
prohibition may be criminally prosecuted or re-
a confidential manner. Types of this information
moved from office. This prohibition obviously is
include trade secrets, business operations and
not intended to prevent staff members from com-
statistics, personal and business financial data, tax
municating with Members of Congress and provid-
returns, investigative reports of law enforcement
ing information about legislation to Members of
agencies, and personnel and medical information.
Congress. However, the line between proper infor-
Staff members are subject to criminal sanctions
mational publicity in legislative matters and
if they do not protect this information from use
improper lobbying activities should always be kept
by unauthorized personnel. Care should be exer-
in mind. Although the sanctions under this law
cised in passing any such information to make
have rarely if ever been used, care should be taken
certain that only authorized persons receive it.
in this regard to avoid criticism by Members of
Congress and the Comptroller General.
(c) Administratively Restricted Information
When it is desired to control materials adminis-
9. Disclosure or Use of Official information
tratively; i.e., where the contents are not or a
There are many types of information to which
national security name covered by the deñnitions
staff members become privy. With some of this
for security classifications, but are to be restricted
sensitive information, legal and ethical restrie-
to the view of only certain officials, there are nd-
tions are imposed upon your disclosure, handling
ministrative classifications which you may use.
and use of it. The following paragraphs highlight
They are "For Official Use Only," "Administra-
some of the problems of which you should be aware
tively Confidential" or "For The Eyes of (partic-
in this regard.
ular official or officials) Only." In certain cases,
&
FORD
GERALD
LIBRARY
is
be desirable to classify confidential
White House Ofice staff. The principal activities
ersonal information in this manner.
prohibited by these criminal statutes are:
T
institutions may also be employed in re-
(1) Solicitation or receipt of political contri-
proposed pelicies DE similar sensitive mat-
butions by one federal employee from another
ters when it limited dissemination is desired. Each
(18 USC
staff member must use his own discretion in classi-
(2) The giving or handing over of = political
fjing information administratively.
contribution by one federal employee to another
Information
(18 USC 607).
(3) Solicitation or receipt of political contri-
White House staff members are prohibited from
butions in 2 federal building by any person,
using for private gain or personal interest any
whether or not 32 employee of the government
tinformation obtained asm resulting heir osition
(18 USC 803).
which is Available to the public.
(4) Solicitation or receipt of anything of
Each stationfies should establish adequata in-
value, either for personal reward or 23 2 politi-
ternal procedures to assure that classified and
cal contribution, in return. for the promise to
sensitive documents and related materials are pro-
use, or the use of, influence to secure an appoint-
tected at all times. A specific person in each office
ive office (18 USC211).
should be given this responsibility, but it should be
(5) Promising employment, compensation or
made clear that the last person in an office assumes
other benefits made possible of act of Congress
the responsibility for the security of classified
as consideration or reward for political activity
unaterial. Such materials should not be taken from
(18 USC 600).
the White House or EOB except when opera-
(€) Discrimination by = federal employee in
tionally necessary, and then only when appropri-
favor of or against another officer or employee
ate measures are taken to safeguard it.
on account of political contributions (is USC
The Executive Protective Service (EPS) has
606).
bee unted TO conduct 2 thorough after-hours
se
inspection ff office in the White
11. Contact With Independent Regulatory Agencies
Ho and EOB on a nightly basis. Their author-
and Procurement Agencies
ity to inspect extends to all exposed classified or
sensitive documents, as well as all other related
You should also be familiar with the standards
beaterials not properly secured. Classified material
of conduct governing the activities of the White
never be left unattended on desks, and when
House staff in its contacts with the regulatory
an office is closed or vacant, materials should be
agencies and Executive Branch departments and
locked in a secure cabinet. In the event of a serious
agencies with procurement responsibilities.
security violation, EPS will file a formal report
Regulatory Agencies: The cases that come be.
with the office concerned.
fore these agencies are of two general types: rule-
All classified and sensitive materials to be de-
making and adjudicative. Both are normally ex-
stroyed should be separal ed from other office trash
tremely complicated. extremely important to the
and raile materials and either destroyed in a
parties concerned. and involve large amounts of
ishredd PT placed in "burn bags" which are col-
money. While there are exceptional occasions
lected under EPS supervision and are disposed of
when White House staff contact with agency per-
in the secure macerator located in the EOB.
sonnel is justified in rule-making proceedings,
there i3 no justification for involvement in adjudi-
10. Political Activities
cative proceedings. As a general rule, no member
of the staff should make an es parte contact with
Federal Haw, primarily through the Hatch Act,
2 regulatory agency involving any matter pending
Timits the political activity of federal employees.
before that agency. regardless of whether the pro-
White Frouse Office staff members (i.c., on the
credings are deemed 5.) be rule-making or
White House budget payroll) are exempt from ti:e
adjudicative, when such a contact may imply pref-
Hatch 1.4 prohibitions against engaging in politi-
crential treatment or the use of induence on the
cal
"j and management.
decision-making process.
I
#:3 other federal laws dealing with politi-
Should you receive inquiries with regard to such
which apply without exception to the
matters, you should refer the inquiring party to
i
FORD
GERALD
LIBRARY
agency involved, and express 50 opinion on the
(a) Disquelification in matters
mise! In short, White Home stati members
with former duties or official responsibility
And avoid even tisin mere appearance of interest
A former stad member is MINI
0. inthence-and the easiest way to do 50 is w
from acting us 22 egent or naturney 202
avoid discussing matters pending before the inde-
other than the United States in connection with
pandent regulatory agencies with interested parties
a particular matter in which the United States
and avoid making ex-parte contacts with agency
is a party or has an interest and in which he
buld 2C occasion arise in the course
participated personally and substacticily for
of your duties where is appears necessary to dis-
the government.
cass general policy matters with the staff of an
A former full-time staff member may not for a
independent regulatory agency, to avoid any ap-
period of one your after the termination of his
of impropriaty, you should film consult
government employment appear personally
with the office of the Counsel to the President to
before any court, department or agency as egent
determine whether such contact would be appro-
or attorney for anyone other than the United
priate under the circumstances.
States in connection with any particular matter
Procursment Agencies: In recent years the pub-
in which the United Scates is a party or has a!
lic has become increasingly sensitive to the allega-
interest and which was under the official respon-
tions of improper influence in the awarding of
sibility of the former stad member during the
recument contracts. Obviously no member of the
last year of his government service.
This House staff should contact any procurement
(b) Prohibition against receipt of compansa-
officer about a contract in which he has a personal
tion jor representative services performed before
financial interest or in which 2 relative, friend, or
government agencies by jormer stap members
business associate has a financial interest. This is
or-others during the period of employment 23 a
true not only as to calls or contacts in which in-
staff member.
fluence is directly exerted, but also as to so-called
1 former staff member as well as a present
calls or other communications which
staff member is prohibited from receiving or
might direct the attention of the procurement of-
soliciting any compensation for services ren-
ficer to the fact that the White House starf member
dered before any department, agency or com-
has ail interest.
mission by himself or uny other person while
There are likely to be occasions when the White
he was a staff member in relation to a particular
House has a legitimate interest in information
matter in which the United States is a party or
about procurement matters; in such instances, the
has an interest. It should be noted that the :ep-
communication should be made by persons who
resentative services covered do not include
have no direct interest themselves, and whose
appearances before courts-only agencies, de-
friends or associates have no such interests. It is
partments or commissions.
advisable that the lack of such interest be made
This prohibition affects the circumstances
their to those receiving the communication so
under which n former starf member may join or
mintended inferences do not arise. To the
rejoin a firm which is engaged in his particular
extent that it can be done, information should be
business. The statute makes it. unlawful fill ::
obtained after the contracting procedure is com-
former employee to share in any fees received by
pleted, or from persons not involved in the deci-
the firm for services in relation to a particular
sion-making process. To avoid the appearance of
matter, in which the United States is a party or
conflict and subsequent embarrassment, White
has an interest, performed by the firm at any
House staff members who must contact procure-
time during the period of his government ein-
agencies with regard to pending contracts
ployment. This is so even though the matter was
should also first contact the Counsel to the
not ever before his particular department or
President.
agency and did not come to his attention before
his separation from the government.
in Standards for Departing Personnel
The new firm member and the firm must make
an arrangement whereby his share of its income
All departing White House staff members are
iз attributed to sources other than iss of the
of gitterel to observe 1.110 following statutory stand-
firm decived from activities covered by this
2.06 of conduct:
prohibition.
is
FORD
GERALD
LIBRARY
) R4 trictions on partners of former staff
a former staff member from sharing compensa-
Ser:.
tion with him for certain services rendered inr.
Partners of former staff members are 25 such
ing his period of government service.
not within the scope of the conflict of interest
In addition is the foregoing, departing staff
statutes discussed in paragraphs (a) and (b).
personnel with = legal background who have served
Partnership with the former staff member does
on the staff in = legal capacity should also famil-
qualif them ir majures in which
iarize themselves with additional restrictions im-
the sixin member is disqualified. however, as in-
posed by the Code of Professional Responsibility
dicated above, the law prohibits the partners of
of the American Bar Association.
FORD : LIBRARY 07V839
is
GERALD
FORD LIBRARY
CONFIDENTIAL STATEMENT OF EMPLOYMENT AND FINANCIAL INTERESTS
(FOR USE BY GOVERNMENT EMPLOYEES)
issue flast, firse. initial)
2. TITLE OF POSITION
:. DATE OF APPOINTMENT IN PRESENT POSITION
4. AGENCY AND MAJOR ORGANIZA NONAL SEGMENT
PART 1. EMPLOYMENT AND FINANCIAL INTERESTS. List
financial interests, through a pension or retirement plan, shared
the names of all corporations, companies, time, or other business
income, or other arrangement as a reault of any current or prior
enterprises, partnerships, nonprofit organizations, and educational,
employment o: business oz professional association; or (c) in
or other institutions: (a) with which you 319 connected as an
which you have any financial interest through the ownership of
employee, officer, owner, director, member, trustee, partner,
stock, stock options, bonds, securities, or other arrangements
adviser, or consultant; or (b) in which you have any continuing
including trusts. If none, write NONE
NAME 8 KIND OF ORGA.
POSITION IN ORGANIZATION.
NATURE OF FINANCIAL
NIZATION [USI PART 1
ADDRESS
(usc PART i(a) DESIGNATIONS.
INTEREST. e.2.. STOCK. PRIOR
DESIONATIONS WHERE
IF APPLICABLE.)
BUSINESS INCOME. lusz PART 1(b)
APPLICABLE.1
to (c) DESIGNATIONS. " APPLICABLE.
PART 11. CREDITORS. List the names of your creditors other
you may be Indected for current and ordinary household and IIV
than those to whoer you may be indebled by reason of a mortgage
ing expenses such as household furnishings, automobile, edual
on property which you occupy as a personal residence cr to whom
tion, vacation, and similar expenses. If none, write NONE
CHARACTER OF INDEBTEDNESS, 0.3., PERSONAL
NAME AND ADDRESS OF CREDITOR
LOAN, NOTE, SECURITY
PART III. INTERESTS IN REAL PROPERTY. List your Interest in real property or rights in lands, other than property which yo
occupy as a personal residence. If none, write NONE
NATURE OF INTEREST, C.F.
TYPE OF PROPERTY, e.z.:
OWNERSHIP. HORTGAGE, LIEN,
RESIDENCE, HOTEL. APARTMENT,
ADDRESS. (IF RUPAL. GIVE RFD,
INVESTMENT TRUST
FARM, UNDEVELOPED LAND
OP COUNTY AND STATE.)
PART 1% INFORMATION REQUESTED OF OTHER PERSONS.
and address of such persons, the date upon which you requeste
If any information is to be supplied by other persons, es,
that the information be supplied, and the nature of subject mat-
trustes, altorney, accountant, relative, please indicate the name
ter Involved. Ii none, write NONE.
NAME AND ADDRESS
DATE OF
REQUEST
NATURE OF SUBJECT MATTER
AGENCY MAY INSERT ADDITIONAL INSTRUCTIONS IN THE SPACE BELOW
I certify that the statements ! have made are ime, complete, and correct to :he best of my knowledge and belie!.
FORD
GERALD
LIBRARY
Page data
- Page
- 1
- Source index
- 0
- Type
- document
- Media ID
- 4c25846bc9e5e54c
- Size
- unknown
Document data
- ID
- 12000407
- Core
- doc
- Type
- document
DTO data
{
"id": "12000407",
"sourceUrl": "https://catalog.archives.gov/id/12000407",
"contentType": "document",
"title": "Transition Reports (1977) - Vice President (5)",
"citationUrl": "https://catalog.archives.gov/id/12000407",
"collections": [
"John O. Marsh Files (Ford Administration)",
"John Marsh's General Subject Files"
],
"subjects": [
"Presidential transitions",
"Veterans"
],
"iiifBase": "https://s3.amazonaws.com/NARAprodstorage/opastorage/live/7/4/12000407/content/library/document/0067/12000407.pdf",
"thumbnailUrl": "https://s3.amazonaws.com/NARAprodstorage/opastorage/live/7/4/12000407/content/library/document/0067/12000407.pdf",
"largeImageUrl": "https://s3.amazonaws.com/NARAprodstorage/opastorage/live/7/4/12000407/content/library/document/0067/12000407.pdf",
"imageCount": 1,
"hasImages": true,
"source": "import",
"hasTranscription": false
}
Context sent to Scholar
Document identity
{
"localId": "12000407",
"label": "Transition Reports (1977) - Vice President (5)",
"core": "doc",
"dtoType": "document",
"citationUrl": "https://catalog.archives.gov/id/12000407"
}
Document source metadata
{
"id": "12000407",
"sourceUrl": "https://catalog.archives.gov/id/12000407",
"contentType": "document",
"title": "Transition Reports (1977) - Vice President (5)",
"citationUrl": "https://catalog.archives.gov/id/12000407",
"collections": [
"John O. Marsh Files (Ford Administration)",
"John Marsh's General Subject Files"
],
"subjects": [
"Presidential transitions",
"Veterans"
],
"iiifBase": "https://s3.amazonaws.com/NARAprodstorage/opastorage/live/7/4/12000407/content/library/document/0067/12000407.pdf",
"thumbnailUrl": "https://s3.amazonaws.com/NARAprodstorage/opastorage/live/7/4/12000407/content/library/document/0067/12000407.pdf",
"largeImageUrl": "https://s3.amazonaws.com/NARAprodstorage/opastorage/live/7/4/12000407/content/library/document/0067/12000407.pdf",
"imageCount": 1,
"hasImages": true,
"source": "import",
"hasTranscription": false
}
Document source extras
{
"url": "https://catalog.archives.gov/id/12000407",
"naId": 12000407,
"coverageEndDate": {
"logicalDate": "1976-11-30",
"month": 11,
"year": 1976
},
"coverageStartDate": {
"logicalDate": "1976-11-01",
"month": 11,
"year": 1976
},
"levelOfDescription": "fileUnit",
"recordType": "description",
"ocrSource": "nara-archive"
}
Page context
{
"seq": 1,
"pageIndex": 0,
"type": "document",
"url": "https://s3.amazonaws.com/NARAprodstorage/opastorage/live/7/4/12000407/content/library/document/0067/12000407.pdf",
"mediaId": "4c25846bc9e5e54c",
"ocrText": "The original documents are located in Box 40, folder \"Transition Reports (1977) - Vice\nPresident (5)\" of the John Marsh Files at the Gerald R. Ford Presidential Library.\nCopyright Notice\nThe copyright law of the United States (Title 17, United States Code) governs the making of\nphotocopies or other reproductions of copyrighted material. Gerald R. Ford donated to the United\nStates of America his copyrights in all of his unpublished writings in National Archives collections.\nWorks prepared by U.S. Government employees as part of their official duties are in the public\ndomain. The copyrights to materials written by other individuals or organizations are presumed to\nremain with them. If you think any of the information displayed in the PDF is subject to a valid\ncopyright claim, please contact the Gerald R. Ford Presidential Library.\nDigitized from Box 40 of the John Marsh Files at the Gerald R. Ford Presidential Library\nCONTENTS\nC - Selected additional current procedural memoranda\n1. File Manual (1974)\n2. Fire Alarm System (July 3, 1975)\n3. Standards of Conduct/Confidential Statement\nof Employment and Financial Interests\n(July 9, 1975)\n4. Restrictions on Political Participation by\nEmployees of the Vice President's Office\n(July 14, 1975)\n5. Security Procedures (November 4, 1975)\n6. Procedures in case of Riot or Disorder Enroute\n(February 11, 1976)\n7. Control and Reduction of Official Travel Costs\n(March 3, 1976)\n8. Federal Travel Allowances and Preparation of\nNecessary Travel Forms (March 3, 1976)\n9. Absences from the Office of the Vice President\n(Annual Leave, Sick Leave and Compensatory Time)\n(March 3, 1976)\n10. Transportation (March 19, 1976)\n11. Guests on the Vice President's Airplane\n(March 24, 1976)\n12. Use of Burn Bags for Classified Material\n(May 18, 1976)\n13. Minimum Ground Time Requirements (June 1, 1976)\n14. Thank-You Letters (June 22, 1976)\n15. Vice Presidential Gifts Received on Trips\n(July 23, 1976)\nFORD is LIBRARY GERALD\n16. Service Academy Nominations by the Vice\nPresident (Vice President's Military Office\nOperating Procedure 1-76) (October 12, 1976)\n17. Correspondence Analysis, 22 July 1975 -\n31 July, 1976) (included as a sample)\nis\nFORD\nSERALD\nFILE\nOFFICE OF\nTHE VICE PRESIDENT\nFILE MANUAL\n1974\nBERALD FORD LIBRARY\nSection I\nFILES OPERATION\nThe success or failure of the filing system is dependent on properly\ncarrying out several basic steps. These steps consist of setting un the\nsystem, preparing the filing material, finding papers in the files and\ncharging them out, keeping the files orderly, breaking the files, and\nretiring inactive files.\nThese steps are explained in detail so that an efficient filing system\ncan be provided.\nA. Setting up the System\n1. Selecting Folders, Labels, and Guides\nThe types of folders, labels, and guides used and their manner\nof preparation affect the appearance and efficiency of the files.\nThe specific arrangement of the folders with the folder labels\nand their guides will be discussed in Section II. Supplies\nshould be standardized as much as possible to obtain the follow-\ning advantages:\n- Neater appearance through uniformity.\n- Faster supply replenishment.\n- Fewer requisitions.\na. File Folders\nExtensive tests of various types of file folders have shown\nthat kraft folders are the best for general use because of\ndurability, economy, and space occupied in the file drawers.\nKraft folders, 11-point, square-cut, with reinforced top,\nare recommended.\nSquare-cut folders have a tab which covers the full width\nof the folder. They provide neatness and uniformity in\nappearance.\nb. Folder Labels\nLabels should be placed on the left side of the folder tab\nending approximately one-half inch from the end of the tab.\nPressure sensitive, color-code labels are recommended, as\nthey may be typed, peeled off the back and attached to the\nfolders. They adhere to the folder, and the corners of the\nlabel will not come loose.\ni\nFORD\n2\nRALD\nc. File Guides\n(1) Guide cards, with the first position tabs, should be\nused to mark the beginning of each primary subject\nin the file.\n(2) Guide cards, with second or third position tabs, should\nbe used to identify sub-subjects, where volume of\nfiles and range of subjects require guiding to ease\nfiles reference.\n2. Typing File Copies\nAll letters to be typed will have in addition to the original, a\nset of manifold carbon copies. These manifolds will consist of:\nYellow (Gfficial File Copy)\nFiled by Subject.\nWhite (Cross Reference)\nFiled by Subject or name.\nGreen (Alphabetic Name or Control File\nFiled alphabetic by name.\nCopy)\nPink (Chronologic Copy)\nFiled in date order by\npreparing office.\nBlue (Reading Copy)\nFiled in date order and\ndestroyed when seen by\nappropriate officials.\nB. Preparing Material for the Files\nThe real test of any file system is not how quickly material can be\nfiled but how quickly it can be produced. Therefore, give the utmost\ncare to the classifying and preparation of material for filing.\n1. Inspecting\nInspect material to make certain that all file copies are present.\n2. Assembling\nAssemble each unit of file material by stapling the yellow file\ncopy on top of the incoming communication, if any, and place the\ngreen copy on top, unfastened.\n3. Classifying\na. Classification and Its Importance\nClassification is the process of finding the correct file\ngroup under which a record should be filed and the sub-\nordinate subjects (or file groups) which should be cross-\nreferenced. This is the most vital of all processes having\nto do with getting papers into the files.\n3\nERALD FORD\nThe ability to locate papers promptly after they have been\nfiled depends largely on the care and skill used to determine\nthe proper subject of the papers at the time they are placed\nin the files.\nA paper may cover one subject or several. The subjects may\nbe either obvious or obscure. The system outlined in this\nmanual is intended to bring together related subjects.\nPapers on related subjects, however, can be logically and\nconsistently brought together in the files only when classi-\nfying techniques are sound.\nSuccessful classification is based upon the following\nrequirements:\n- Knowledge and understanding of the office and its activities;\nfamiliarity with how records are asked for and used; and\nknowledge of. the classification or subject outline in this\nmanual.\n- Analytical ability.\n- Proper techniques.\nb. Classifying Techniques\nRead and analyze the correspondence or other material to\nselect the proper file designation by referring to the\nSubject Outline or the Alphabetic Index. Be consistent\nin classification. Similar or overlapping subjects may\nrequire cross-referencing.\nc. Official File Copy\nAn Official File Copy consists of the original incoming\ndocuments, plus the yellow outgoing file copy. Sometimes\nthere will be no outgoing response and therefore an ori-\nginal incoming document is then considered an Official File\ncopy. Conversely there will also be times when you will\nonly have a yellow outgoing file copy.\nd. Marking for the File\nAfter determining the classification, mark it in the upper\nright corner of the Official File copy.\nAU, GERALD BIT FORD\n4\n4. Cross-referencing\nCross-references are needed to facilitate prompt location of\ndocuments. Cross-references are of three types:\n- A carbon copy of an outgoing letter.\n- A-quick-copy of the letter or other paper (Copy the cover\nsheet only if there are several pages).\n- A cross-reference form. (EXHIBIT I)\nIf possible, prepare at typing time sufficient cross-reference\ncopies. Cross-reference copies for the Subject Files are white.\nIf there is no outgoing correspondence, or if too few copies\nwere typed, use a quick-copy.\nA common occurence which requires cross-referencing is when\nmore than one name or subject is connected with a case.\nC. Filing Records\n1. Sorting and Arranging\nWhen the material has been properly marked and assembled,\nseparate it into file groups (i.e., Agriculture, Public\nRelations, and so forth), and arrange it in alphabetical order\nor numerical sequence, as the case may be. Be consistent\nwhen arranging alphabetically. Unless one set of rules is\nfollowed, it will become difficult to find wanted documents.\na. Sort subject file material in alphabetical sequence\naccording to subject title. Within each subject, arrange\nmaterial in numerical sequence.\nb. Place each unit of file material in the appropriate\nfolder with the left side of the material down. Material\nwithin the folder should be arranged with the latest\ndate in front. If successive folders containing material\non the same subject are necessary, the folders should\nbe arranged chronologically with the latest in front.\n2. Do's and Don'ts of Good Filing\nNeatness and orderliness are the essence of filing efficiency.\nThe following are a few suggestions that will help maintain\nthe office files in a neat and orderly manner:\nis\nFORD\nGERALD\na. Identify File Drawers\nLabel file drawers adequately to indicate what files,\nsubjects, or names are filed in them. Also indicate the\nyear. Filing can be accomplished much more rapidly if\ncabinets are arranged systematically and all file drawers\nare properly labeled. The material in file drawers\nshould be arranged from front to back in strict sequence\nof the subject outline.\nb. Keep Papers Straight\nWhen placing material in file folders, do not let the\npapers extend beyond the edges of the folders.\nc. Avoid Overloaded File Folders\nThe scoring along the bottom of the folders should be\ncreased, as necessary, to adjust the folder to increased\ncontents. About three-quarters of an inch is the normal\ncapacity of the kraft folder. When the capacity of the\nfolder has been reached, additional material on the same\nsubject should be placed in another folder bearing identi-\ncal identification to the full folder and arranged with\nthe folder containing the more recent material in front.\nThe inclusive dates of the material should be marked on\nthe tab of the earlier folder.\nd. Avoid Overcrowed File Drawers\nIf the file drawer is not too crowded, papers can be\nadded without removing the contents of the folder.\ne. Fastening Papers\nFastening of papers to the folders is only justified when:\n(1) Papers need to be divided into temporary and\npermanent categories.\n(2) Papers need to be divided within a- folder to provide\nimmediate reference to a particular type of document.\n(3) Papers are highly valuable or irreplaccable.\n(4) There is not much interfiling of papers.\nf. Keep the Filing Current\nFORD\nDon't let a backlog of unfiled material accumulate. Try\nto file material each day on an established schedule.\nGERALD\n6\nD. Finding Records\nTo find papers desired, use the information available concerning\nthem and relate this information to the filing system. The fol-\nlowing steps illustrate how to do this:\n1. When receiving a request for file material, obtain,\nif possible, sufficient information to identify the\nfile, that is, the names of individuals or agencies,\nthe dates, and the subject of the material.\n2. If uncertain of the exact file or subject, consult\nthe Subject Outline or the Alphabetic Index to help\nlimit the area of search.\n3. If only name references are given, search the Alphabe-\ntical Name File which sometimes is known as the Central\nControl File.\n4. If the material cannot be located in the files and\nis of a recent date, a check of the unfiled materials\nshould be made. If this effort does not prove success-\nful, consider the following possibilities:\na. It may never have been received.\nb. It was received but is in the hands of\nsome other staff member.\nc. It has been misfiled or misplaced.\nd. It was received but was forwarded to another\nstaff member without being charged out.\n5. When removing material from a file drawer or folder,\nprepare a charge-out card. (Exhibit II) Put it into\nthe folder or file drawer in place of the material\nremoved. Punch holes in top of requested documents\nand ACCO file on a File Backing Sheet with latest date\non top. Backing sheet must be stamped \"Return to\nVP Central Files.\" When the material has been re-\nturned to the file, the charge-out card should be\nremoved and the entry indicating the charge can be\ncancelled by drawing a line through it.\nBERRLD R. FORD\n7\nE. Breaking the Files\n1. Definition\nFiles are \"broken\" or \"art off\" by stopping the filing of\ndocuments in one set of folders as of a predetermined date\nand thereafter filing under the same file classification\nin another set of folders.\n2. Continuity Reference\nWhen files are cut off or broken, material necessary to\ncurrent operations should be brought forward into the new\nfiles. When earlier material must be brought forward,\nprepare E Continuity Reference Form (Exhibit III) for each\nfile that is being consolidated with the latest correspon-\ndence. The Continuity Reference Form is used to show that\nmaterial has been brought forward from one year to another.\nFill in the appropriate information opposite each caption.\nF. Retiring and Disposing of Records\nA goal of good records management is to avoid keeping files in\noperating office space when they are not used frequently. Such\nfiles can be transferred regularly to a less active area.\nSystematic records retirement is essential if files needed for\ncurrent operations are not to be clogged with obsolete material.\nScreening or \"weeding\" of files on a paper-by-paper basis. should\nnot be undertaken for retirement of files. This method of\nsorting is a cumbersome, time-consuming way to reduce bulk.\nG. Filing Classified and/or Sensitive Records\nClassified papers are filed under the same guidelines as used\nfor unclassified material. However, classified papers are\nhoused in equipment affording necessary security. A cross-\nreference form placed in the file folder indicating that the\nmaterial is filed in security cabinets will provide a guide\nto finding. The cross-reference form will not reveal the con-\ntent of the classified material. If an entire folder is kept\nin security cabinets, a charge-out card should be used.\nH. Location of File Manual\nThe master File Manual should be located in the front of the\nfirst drawer of the files. Additional refinements of the\nfile system will be made only after consulting the person\nresponsible for the files, and at that time, all copies of the\nfile manual will be amended to reflect the latest change.\nFORD\nBLD\n8\nSection II\nFILE GROUPS\nA. Subject Files\nSubject Files are maintained for subject-oriented papers. The\nsubject material housed in these files includes correspondence,\nmemoranda, reports, and other documents which are logically\nclassified and filed under subject categories. They are filed\nin a series of folders labeled in accordance with an approved\nsubject system of coding.\n1. Classification\nEach piece of material sent to the file must be classified,\nand that subject classification actually marked on the paper\nin the upper right-hand corner. All material to be refiled\nmust be placed in the same location it occupied previously.\nMarking the classification allows exact replacement of the\nmaterial in the file and eliminates the man-hour loss as-\nsociated with repeated reclassification of material being\nreturned to the file. In using the subject classification\nscheme, some subjects will be rarely used. In these instances\nonly a primary folder should be prepared, and all documents\nfiled in this folder regardless of the secondary or tertiary\nclassification marked on them. Should this single folder\nreach ten or more documents in size, it can then be sub-\ndivided into possible two or more secondary folders for easy\nfinding.\n2. Arrangement\nThe file folders are arranged in the file by primary subject\ncategories, then by secondary and tertiary subjects. These\ncategories form logical subdivisions of the primary subjects,\nwhich pull together all material on a given subject, Folders\nshould only be made for those subject titles for which there\nis a definite current or anticipated need. If only an occasional\ndocument relates to a secondary subject, the material may be\nfiled in the primary folder, behind the guide card. A separate\nfolder is prepared for a secondary subdivision when ten papers\nor more have accumulated in the primary folder.\n3. Guide Cards\nGuide cards, 1/3 cut, are the best choice for subject files,\nsince the first or left tab card is the principal one used.\nThe left position is used to show each of the primary subjectso\n9\nin the classification scheme. Occasionally a secondary topic\nin the system becomes so important to the users of the file\nthat this may justify setting up a guide card in the second or\ncenter position to speed retrieval of material from that seg-\nment of the file. Use of the guide cards with proper primary\nlabeling will materially reduce the search effort required\nto find and use the material contained in the subject file\n(EXHIBIT IV).\nB. Alrhabetic Name File - Sometime known as the Central Control File\nFile here, alphabetically by name, all documents pertaining to\na specific person, company, or organization. Do not file material\nhere that could be filed more appropriately in a subject file.\nDo not set up a folder for each name, but file in general alphabetic\nfolders. When sufficient volume on a specific person or organiza-\ntion is accumulated, remove this from the general file, make a\nfolder, and file it behind the general alphabetic folder.\nC. Magnetic Card Produced Letter File\nLetters answered by a form or robo letter shall be filed separately\nand identified as to the type of letter used as a response.\nIncoming letters only will be batch filed by date of response.\nD. No Answer File\nDrop file here, alphabetic by first letter of last name, all\ncorrespondence which does not require an answer. Prepare only\na folder for each letter of the alphabet. When a folder has\nreached its capacity, close out the folder by date, and prepare\nanother folder which states portion of alphabet covered, date\nspan, and file in front of the previous lettered folder.\nFORD\n071,\n10\nCROSS-\nFERENCE\n(name, number, or\nsubject under\nwhich this form\nis filed)\nDATE\nTO\nIDENTIF\nFROM\nCATION\no:\nRECORD\nBRIEF\nSUMMARY\nOF\nCONTENTS\nFILED\n(Name, number, or subject\nunder which the document\nitself is filed)\n&\nFORD\nOptional Thrm 21\nFib. 1\"\nGSA Circular 259\nCROSS-REFERENCE\nEXHIBIT I\nII\nOUT\nII EXHIBIT\nIDENTIFICATION OF RECORD\n12\nCHARGED TO\n3\n(NUMBER, TITLE AND/OR SUBJECT, DATE Of FILE OR DOCUMENT)\n(PERSON & OFFICE)\nRALD\nsand\nj\nOPTIONAL FORM 23\nFE3 1962\nCHARGEOUT RECORD\n* GPO : 1962 OF-512734-\n8\nGSA Circular No. 259\n5023-101\nino\n(PERSON & OFFICE)\nCHARGED\n(NUMSER, TITLE AND/OR SUBJECT, DATE OF FILE OR DOCUMENT)\n01 CHARGED\nDATE\nIDENTIFICATION OF RECORD\nOUT\nDESCRIPTION OF CORRESPONDENCE OR DOCUMENT BEING BROUGHT FORWARD\nSUBJECT\n,ider which this form\nis filed)\nDATE (Under which\nthis form is filed)\nTO\nFROM\nBRIEF SUMMARY\nOF\nCONTENTS\nBROUGHT FORWARD and filed with the documents described below\nSUBJECT\nDATE\nTO\nFROM\nFORD\nis\nLD\nOptional Form 22\n7.1. 1962\nCONTINUITY REFERENCE\nCSA r N., 250\nEXHIBIT III\n13\nARRANGEMENT OF FOLDERS, GUIDES AND LABELS\nLabels with\nFile designation\ninclusive dates\nLabels\naffixed to the folder\nCA 4\nJan 1, 1974\nRoutes-Navigation\nthru\nCA 4\nRoutes-Navigatio\nCIVIL AVIATION (CA)\nCIVIL\nAVIATION (CA)\nAG 3-1\nJan 1, 1974\nMarketing Protection Programs\nthru\nAG 3\nJan 1, 1974\nMarketing\nthru\nAG 1\nJan 1, 1974\nHome Economics\nthru\nAG 1\nHome Economics\nJan L 1974\nthru\nAGRICULTURE\n(AG)\nPRIMARY SUBJECTS\nSECONDARY SUBJECTS\nTERTIARY SUBJECTS\n1st Position Guides\n2nd Position Guidea\n3rd Position Guides\nNOTE; In the average drawer, one guide for every 10 to 15\nfolders should serve.\nALD 1817 ? FORD\n14\nEXHIBIT IV\nFILING CATEGORIES\nPRIMARY SUBJECTS\nSYMBOLS\nAGRICULTURE\nAG\nARTS\nAR\nATOMIC ENERGY\nAT\nBUSINESS-ECONOMICS\nBE\nCIVIL AVIATION\nCA\nCOMMODITIES\nCM\nCOUNTRIES\nCO\nDISASTERS\nDI\nEDUCATION\nED\nEMPLOYMENT ASSISTANCE\nEM\nENDORSEMENTS\nEN\nFEDERAL AID\nFA\nFEDERAL GOVERNMENT\nFE\nFEDERAL GOVERNMENT-ORGANIZATIONS\nFG\nFINANCE\nFI\nFOREIGN AFFAIRS\nFO\nGIFTS\nGI\nHEALTH\nHE\nHIGHWAYS-BRIDGES\nHI\nHOLIDAYS\nHO\nHOUSING\nHS\nHUMAN RIGHTS\nHU\nIMMIGRATION-NATURALIZATION\nIM\nINDIAN AFFAIRS\nIN\nINSURANCE\nIS\nINTERNATIONAL ORGANIZATIONS\nIT\nINVITATIONS\nIV\nJUDICIAL-LEGAL MATTERS\nJL\nLABOR-MANAGEMENT RELATIONS\nLA\nLEGISLATION\nLE\nMEDALS-AWARDS\nMA\nMEETINGS-CONFERENCES\nMC\nMESSAGES\nME\nNATIONAL SECURITY-DEFENSE\nND\nNATURAL RESOURCES\nNR\nOUTER SPACE\nOS\nPARKS-MONUMENTS\nPA\nPEACE\nPC\nPERSONNEL MANAGEMENT\nPE\nPOLITICAL AFFAIRS\nPL\nPOSTAL SERVICE\nPO\nPRESIDENT\nPP\nPROCUREMENT-DISPOSAL\nPQ\nSALD R. FORD\n15\nPUBLIC RELATIONS\nPR\nPUBLICATIONS\nPU\nREAL PROPERTY\nRA\nRECREATION-SPORTS\nRE\nRELIGIOUS MATTERS\nRM\nREPORTS-STATISTICS\nRS\nSCIENCES\nSC\nSOCIAL APPAIRS\nSO\nSPEECHES\nSP\nSTATE AND LOCAL GOVERNMENTS\nST\nTRADE\nTA\nTRANSPORTATION\nTN\nTRIPS\nTR\nUTILITIES\nUT\nVICE PRESIDENT\nVP\nVICE PRESIDENT'S OFFICE\nVS\nWELFARE\nWE\ni\nFORD\n110\n16\n2\n$\n#\n5.\n#\nOFFICE OF THE VICE PRESIDENT\nWASHINGTON\nJuly 3 1975\nMEMORANDUM FOR:\nThe Vice Presidential Staff\nSUBJECT\nFire Alarm System\nThe General Services Administration has recently completed the installation\nof a new Fire Alarm System for the Old Executive Office Building.\nShould the System be activated by a Pull Box, a voice announcement will\nautomatically be transmitted throughout OEOB via loud speakers.\nThe voice announcement will indicate the location of the fire and direct\noccupants to leave the building. Occupants are directed NOT to use the\nelevators.\nOccupants should become familiar with the closest exits from their office\nlocation and location of the Fire Alarm Pull Boxes.\nPull Box locations closest to the Vice Presidential Staff offices are\noutside of Room 289A, 299, 261 1/2, 597 and the interior of Room 578.\nShould there be a false alarm a manual overide feature of the new Fire\nAlarm System can be used to inform occupants that there is no fire and\nto return to their offices.\nThe Frank R. Pagnotta\nAssistant to the Vice President\nfor Administration\nFORD LIBRARY s GERALD\n3\nRichard Allison\n4\nOFFICE OF THE VICE PRESIDENT\nWASHINGTON\nJuly\n1975\nMEMORANDUM FOR THE STAFF OF THE A VICE PRESIDENT\nFROM :\nCounsel to the Vice Plu President\nPeter J. Wallison\nSUBJECT:\nStandards of Conduct/Confidential State-\nment of Employment and Financial Interests\nThe Vice President has adopted official Standards\nof Conduct for employees of his Office. These Standards\nformally supersede similar guidelines which applied to\nthe conduct of the White House staff in general,\nincluding the Vice President's Executive Office staff.\nThe Counsel to the Vice President will act as \"Counselor\"\nas that term is used in the Standards.\nThese Standards apply to employees, consultants,\nand special Government employees of the Office of the\nVice President, whether or not their salaries or fees\nare paid out of funds appropriated to the President.\nor to the Senate. Members of the Vice President's\nstaff who are paid out of Senate funds must of course\ncontinue to adhere to applicable regulations of conduct\nfor Senate employees.\nI have attached:\n(a) a copy of the Standards (Tab A) together\nwith (as an appendix to the Standards) a copy of the\nCode of Ethics for Senate employees;\n(b) a copy of the Federal criminal statutes\non conflicts of interest and related matters (P.L. 87-\n949) applicable to both Executive and Legislative branch\nemployees (Tab B) i these and other statutory and\nexecutive requirements are included in the Standards;\nGERALD R. LIQUIRY FORD\n- 2 -\n(c) a summary of the regulations applicable\nto the White House staff (Tab C) ; the regulations\nwhich apply to the White House staff are substantially\nthe same as the Standards, and the attached summary\nis included to assist you in quickly reviewing the\nStandards.\nPlease read these materials carefully and retain\nthem for future reference.\nFinancial Disclosure\nAll employees paid at a level equivalent to GS-13\n($20,677) and above, and all special Government\nemployees regardless of grade, are required to submit\nto the Counselor a \"Confidential Statement of Employ-\nment and Financial Interests.\" The Vice President\nhas requested that both Executive and Legislative\nbranch employees of the Office complete this form.\nEven if you have already completed such a form,\nCivil Service Commission regulations require that\nyour statement be updated as of June 30 in each year.\nTwo copies of the form are attached to this memo\n(Tab D).\nPlease return one completed original copy of the\nform to me, Office of the Vice President, Old Executive\nOffice Building, Room 280, in a sealed envelope marked\n\"Personal-In-Confidence.\" One copy should be retained\nfor your files. All information reported will be kept\nconfidential, subject to the applicable regulations\ngoverning review and determination as to conflicts of\ninterest.\nPlease note, in completing the Statement, that:\n1.\nYou are not required to submit any information\nrelating to your connection with, or interest in,\nany professional society or any charitable,\nreligious, social, fraternal, recreational,\npublic service, civic, or political organization\nor any similar organization not conducted as a\nbusiness enterprise. Educational and other\ninstitutions doing research and development or\nrelated work involving grants of money from the\nUnited States are deemed to be \"business enter-\nprises\" for purposes of this report and should\nbe included.\nFORD & LIBRAT RALD\n- 3 -\n2.\nThe information to be listed does not require\na showing of the amount of financial interest\nin, indebtedness with respect to, or the value\nof, real property.\n3.\nIn the event any of the required information,\nincluding holdings placed in trust, is not known\nNot all In\nto you but is known to another person, you\npjer 28 for 76\nshould request that other person to submit the\ninformation on your behalf and should report\nsuch request in Part IV of your statement.\n4.\nThe interest, if any, of a spouse, minor child,\nor other member of your immediate household\nmust be reported in this statement as your\ninterest. If that information is to be supplied\nby others, it should be so indicated in Part IV.\n\" Member of your immediate household\" includes\nonly those blood or in-law relations who are\nresidents of your household.\nAny changes in, or additions to, the information\ncontained in your initial statement should be reported\nNFA jun his\nin a supplementary statement at the end of the calendar\nquarter in which the change occurs, or in the case of\n30\nspecial Government employees, at the time the change\noccurs.\nyou\nIf you have any questions regarding the foregoing,\nplease contact me at 395-4242.\nFORD is LIBRARY PERALD\nSTANDARDS OF CONDUCT FOR THE\nOFFICE OF THE VICE PRESIDENT\nI. General Provisions.\n1. Purpose and scope.\n2. Definitions.\n3. Special Government employees.\n4. Counselor.\n5. General responsibilities of employees.\n6. Gereral tandards of conduct.\n7. Disciplinary action.\nII. Conflicts of Interest and Ethical Conduct.\n8. Conflicts of interest.\n9. Financial interests.\n10. Additional prohibitions - regular employees.\n11. Exemptions and exceptions from prohibition of\nconflict of interest statutes.\n12. Salary of employees payable only by United States.\n13. Gifts, entertainment, and favors.\n14. Outside employment and other activity.\n15. Use of Government services and property.\n16. Misuse of information.\n17. Indebtedness.\n18. Gambling, betting, and lotteries.\n19. General conduct prejudicial to the Government.\n20. Conduct and responsibilities of special Government\nemployees.\n21. Additional prohibitions - special Government\nemployees.\n22. Miscellaneous statutory provisions.\nIII. Reporting of Employment and Financial Interests.\n23. Reporting of employment and financial interests -\nregular employees.\n24. Reporting of employment and financial interests -\nspecial Government employees.\n25. Reviewing statements - remedial action.\nIV. Supplemental Regulations or Instructions.\n26. Supplemental regulations or instructions.\nFORD is LIBRARY GERALD\nI. General Provisions.\n1. Purpose and Scope.\n(a) The maintenance of the highest standards of\nhonesty, integrity, impartiality, and ethical con-\nduct by regular employees and special Government\nemployees is essential to assure the proper\nperformance of Government business and to command\nthe respect and confidence of the American public\nin their Government. The avoidance of misconduct\nand conflicts of interest on the part of regular\nemployees and special Government employees through\ninformed judgment is indispensable to the maintenance\nof these standards.\n(b) The standards of conduct outlined below are\nrequired of all employees of the Office of the Vice\nPresident in both the executive and legislative\nbranches. Applicability of these standards to em-\nployees of the legislative branch in no way relieves\nthem of their responsibilities under similar standards\nimposed by that branch.\n(c) The standards set forth herein reflect prohibi-\ntions and requirements imposed by the laws of the\nUnited States, but to the extent that such laws are\nparaphrased below, such restatement is intended for\ninformational purposes only and in no way constitutes\nan interpretation or construction of applicable laws\nthat is binding upon the Government. In addition,\nattorneys who are employed by the Office of the Vice\nPresident are subject to the Code of Professional\nResponsibility of the American Bar Association.\n2. Definitions.\n(a) \"Office\" means Office of the Vice President.\n(b) \"Employee\" or \"regular employee\" means any\nemployee of the Office, both those in the executive\nbranch and in the legislative branch, but does not\ninclude a special Government employee.\nBERALD FORD LIBRARY\n-2-\n(c) \"Special Government employee\" means an individual\nwho is retained, designated, appointed, or employed to\nperform with or without compensation for a period not\nto exceed 130 days during any period of 365 consecutive\ndays, temporary duties, either on a full time or\nintermittent basis.\n(d) \"Person\" means an individual, a corporation, a\ncompany, an association, a firm, a partnership, a\nsociety, a joint stock company, or any other organization\nor institution.\n(e) \"Standards\" means the standards of conduct,\nSections 1 through 26, outlined herein.\n3. Special Government employees.\nExcept where specifically provided otherwise, or where\nlimited in terms or by the context to regular employees,\nall provisions of these Standards relating to employees\nare applicable also to special Government employees.\n4. Counselor.\n(a) The Legal Counsel of the Office is the \"Counselor\"\nfor the purposes of these Standards. The Counselor shall\nadvise employees as to the applicability and interpre-\ntation of these Standards, and any laws and regulations\nreferred to herein.\n(b) The Counselor shall serve as the Office's liaison\nwith the Civil Service Commission and the Department\nof Justice on any matters covered by these Standards.\n(c) Communications between the Counselor and an\nee shall remain confidential, except that the\nCounselor may in appropriate circumstances disclose\nsuch communications to the Vice President.\n(d) The Counselor shall notify all employees and\nspecial Government employees of the Office of the avail-\nability of counseling services and of how and where such\nservices are available. Such notification shall be\nmade within 90 days after the effective date of these\nStandards and periodically thereafter. In the case\nof a new employee or special Government employee\nappointed after the date of such notification, notifica-\ntion shall be given at the time of his/her entrance on,\nduty.\nRALD vasit R. FORD\n-3-\n(e) The Counselor shall have copies of these\nStandards distributed to each employee and special\nGovernment employee within 30 days after the effec-\ntive date thereof. In the case of a new employee or\nspecial Government employee entering on duty after the\ndate of such distribution, a copy shall be furnished at\nthe time of his/her entrance on duty.\n5. General resconsibilities of employees.\n(a) All employees and special Government employees\nhave the responsibility of reading and familiarizing\nthemselves with the contents of this Part and with\nHouse Concurrent Resolution 175, 85th Congress, 2d\nsession, 72 Stat. B12, the \"Code of Ethics for Government\nService\" which is attached to these Standards as Appendix A.\n(b) Copies of all regulations and statutes referred to\nin these Standards together with various explanatory\nmaterials, are available for inspection in the office\nof the Counselor at any time during regular business\nhours.\nloyee or special Government employee who is\nuncertain as to the application of any regulation in\nthese Standards, or of any provision of law, to any\nparticular situation in which he/she is or may be\ninvolved, is obligated to contact the Counselor for\nadvice and guidance.\n6. General standards of conduct.\n(a) All employees shall conduct themselves on the job\nin such a manner that the work of the Office is effi-\nciently accomplished, and courtesy, consideration, and\npromptness are observed in dealings with the Congress,\nthe public and other governmental agencies.\n(b) All employees shall conduct themselves off the job\nin such a manner as not to reflect adversely upon the\nOffice or the Federal service.\n(c) In all circumstances, employees shall conduct\nthemselves SO as to exemplify the highest standards of\nintegrity. An employee shall avoid any action, whether\nor not specifically prohibited by these Standards,\nwhich might result in, or create the appearance of:\n(1) Using public office for private gain;\n(2) Giving preferential treatment to any\nLERALD FORD LIBRARY\nperson;\n-4-\n(3) Impeding Government efficiency or economy;\n(4) Losing complete independence of judgment\nor impartiality;\n(5) Making a Government decision outside official\nchannels; or\n(6) Affecting adversely the confidence of the\npublic in the integrity of the Government.\n7. Disciplinary action.\n(a) A violation of any provision of these Standards by\nan employee may be cause for appropriate disciplinary\naction which may be in addition to any penalties pre-\nscribed by law. (As to other remedial action in cases\nwhere an employee's or special Government employee's\nfinancial interests result in a conflict or apparent\nconflict of interest, see $25.)\nAny disciplinary or remedial action taken pursuant to\nthese Standards shall be effected in accordance with\nany applicable laws, Executive Orders, and regulations.\nII. Conflicts of Interest and Ethical Conduct.\n8. Conflicts of interest.\n(a) A conflict of interest may exist whenever an\nemployee has a substantial personal or private interest\nin a matter which involves his/her duties and respon-\nsibilities as an employee. The maintenance of public\nconfidence in the Government demands that an employee\ntake no action which would constitute the use of his/\nher official position to advance personal or private\ninterests. It is equally important that each employee\navoid becoming involved in situations which present the\npossibility, or even the appearance, that his/her\nofficial position might be used for private advantage.\n(b) Neither the pertinent statutes nor the standards\nof conduct prescribed in the Standards are to be\nregarded as entirely comprehensive. Each employee must,\nin each instance involving a personal or private interest\nin a matter which also involves his/her duties and\nresponsibilities as an employee, make certain that his/\nher actions do not have the effect or appearance of the\nuse of an official position for the furtherance of the\nemployee's interest or those of his/her family or\nbusiness associates.\nFORD\nany\nLIBRA\n-5-\n(c) The principal statutory provisions relating to\nbribery, graft, and conflicts of interest are contained\nin Chapter II of the Criminal Code, 18 U.S.C. 201-224.\nPenalties are provided for violations, including,\nvariously, fine, imprisonment, dismissal from holding\nany office of honor, trust, or profit under the United\nStates.\n9. Financial interests.\n(a) Unless authorized to do so as provided hereafter\nin this section, no employee shall participate personally\nand substantially as a Government employee in a particular\nmatter in which, to the employee's own knowledge, he/\nshe has a financial interest (cf. 18 U.S.C. 208).\n(1) For the purposes of this section\n(i) An employee participates personally\nand substantially in a particular matter\nthrough decision, approval, disapproval,\nrecommendation, investigation, the render-\ning of advice, or otherwise;\n(ii) A particular matter is a judicial or\nother proceeding, an application, request\nfor ruling or other determination, a contract,\nclaim, controversy, charge, accusation, arrest\nor other matter; and\n(iii) A financial interest is the interest\nof the employee or his/her spouse, minor\nchild, partner, organization in which the\nemployee is serving as an officer, director,\ntrustee, partner, or employee, or any person\nor organization with whom the employee is\nnegotiating or has any arrangement concerning\nprospective employment.\n(b) An employee may not have a financial interest\nwhich --\n(1) Establishes a substantial personal or private\ninterest in a matter which involves his/her duties\nas an employee; or\n(2) Is entered into in reliance upon, or as a\nresult of, information obtained through his/her\nemployment; or\nGERALD FORD LIBRAR\n-6-\n(3) Results from active and continuous trading\n(as distinguished from the making of bona fide\ninvestments) which is conducted on such a scale\nas to interfere with the proper performance of\nhis/her duties.\n(c) Aside from the restrictions prescribed in these\nStandards, employees are free to engage in lawful\nfinancial transactions to the same extent as private\ncitizens. Employees should be aware that the financial\ninterests of their spouses or minor children and blood\nrelatives who are full-time residents of their house-\nholds are regarded, for the purposes of this section,\nas financial interests of the employees themselves.\n(d) An employee who has a financial interest (other\nthan a financial interest exempted under paragraph (e)\nof this section) in a particular matter which is within\nthe scope of his/her official duties shall make a full\ndisclosure of that interest to the Counselor, in\nwriting. The employee shall not participate in such\nmatter unless and until he/she receives a written\ndetermination by the Vice President that the interest\nis not so substantial as to be deemed likely to affect\nthe integrity of the services which the Government\nmay expect of that employee (cf. 18 U.S.C. 208). If\nthe Vice President does not make such a determination,\nthen the Vice President shall direct such remedial\naction as may be appropriate under the provisions of\n$25.\n(e) The financial interests described in (1) and (2)\nbelow are hereby exempted from the restrictions of\nparagraph (a) of this section as being too remote or\ninconsequential to affect the integrity of an employee's\nservices in a matter (cf. 18 U.S.C. 208):\n(1) Stocks, bonds, policies, properties, or\ninterests in a mutual fund, investment company,\ntrust, bank or insurance company, as to which\nthe employee has no managerial control or\ndirectorship. In the case of a mutual fund or\ninvestment company, this exemption applies only\nwhere the assets of the fund or company are\ndiversified; it does not apply where the fund or\ncompany advertises that it specializes in a\nparticular industry or commodity.\nERALD R.FORD\n-7-\n(2) Interest in an investment club: Provided,\nThat the fair value of the interest involved\ndoes not exceed $5,000, and that the interest\ndoes not exceed one-fourth of the total assets\nof the investment club.\n(f) This section does not apply to special Government\nemployees, who are subject to the provisions of $20.\n30\nAdditional prohibitions regular employees.\n(a) A regular employee is subject to the following\nprohibitions.\n(1) An employee may not, except in the discharge\nof official duties, represent anyone else before\na court or Government agency in a matter in which\nthe United States is a party or has an interest.\nThis prohibition applies both to paid and unpaid\nrepresentation of another (18 U.S.C. 203 and 205).\n(2) An employee may not, after his/her Government\nemployment has ended, represent anyone other than\nthe United States in connection with a matter in\nwhich the United States is a party or has an interest\nand in which the employee participated personally\nand substantially for the Government (cf. 18 U.S.C.\n207 (a)).\n(3) An employee may not, for one year after his/\nher Government employment has ended, represent\nanyone other than the United States in connection\nwith a matter in which the United States is a party\nor has an interest and which was within the\nboundaries of the employee's official responsibility\nduring the last year of his/her Government service\n(cf. 18 U.S.C. 207(b)). The temporary restraint is\npermanent if the matter is one in which the\nemployee participated personally and substantially.\nSee subparagraph (2) of this paragraph.\n(4) An employee may not receive any salary, or\nsupplementation of his/her Government salary, from\na private source as compensation for services as\na Government employee (cf. 18 U.S.C. 209). See $12 of\nthese Standards.\n(b) Exemptions or exceptions from the prohibitions\ndescribed in paragraph (a) of this section are permitted\nunder certain circumstances For the method of obtaining\nsuch exemptions or exceptions, see STT.\nALD. 8817 : FORD\n-8-\n11. Exemptions and exceptions from prohibitions of conflict\nof interest statutes.\n(a) Nothing in these Standards shall be deemed to\nprohibit an employee, if it is not otherwise inconsis-\ntent with the faithful performance of his/her duties,\nfrom acting without compensation as agent or attorney\nfor any person in a disciplinary, loyalty, or other\nFederal personnel administration proceeding involving\nsuch person.\n(b) Nothing in these Standards shall be deemed to pro-\nhibit an employee from acting, with or without compensation,\nas agent or attorney for that employee's parents, spouse,\nchild, or any person for whom, or for any estate for\nwhich, the employee is serving as guardian, executor,\nadministrator, trustee, or other personal fiduciary, except\nin those matters in which the employee has participated\npersonally and substantially as a Government employee,\nthrough decision, approval, disapproval, recommendation,\nthe rendering of advice, investigation, or otherwise, or\nwhich are the subject of his/her official responsibility,\nas defined in section 202 (b) of Title 18, U.S.C., pro-\nvided that the Vice President approves.\n(c) Nothing in the Standards shall be deemed to prohibit\nan employee from giving testimony under oath or from\nmaking statements required to be made under penalty for\nperjury or contempt.\n(d) In addition to the exemptions and exceptions\ndescribed in this section and in §9, the conflict of\ninterest statutes permit certain exemptions and exceptions\nin specific circumstances. The procedure for effecting\nsuch exemptions or exceptions is as follows:\n(1) Any regular employee or special Government\nemployee who desires approval or certification\nof his/her activities as provided for by section\n205 of Title 18, U.S.C., shall make application\ntherefor in writing to the Counselor.\n(2) A former employee, including a former special\nGovernment employee, who desires certification\nwith regard to his/her activities under section 207\nof Title 18, U.S.C., shall make application therefor\nin writing to the Counselor.\n(3) The Counselor for the Office shall report\npromptly to the Vice President all matters reported\nFORD\n-9-\nto the Counselor under these Standards\nwhich require consideration of approvals,\ncertifications, or determinations provided\nherein.\n12. Salary of employee payable only by United States.\n(a) No employee, other than a special Government\nemployee or an employee serving without compensation,\nshall receive any salary, or any contribution to or\nsupplementation of salary, as ccmpensation for his/her\nservices as an employee, from any source other than the\nGovernment of the United States, except as may be\ncontributed out of the treasury of any State, county,\nor municipality ( cf. 18 U.S.C. 209).\n(b) Nothing in this section shall be deemed to prohibit\nan employee from continuing to participate in a bona\nfide pension, retirement, group life, health, or accident\ninsurance, profit-sharing, stock bonus, or other employee\nwelfare or benefit plan maintained by a former employer,\nnor from accepting contributions, awards, or other\nexpenses under Chapter 41 of Title 5, U.S.C. (the\nformer Government Employees Training Act)\n13. Gifts, entertainment and favors.\n(a) Except as provided in paragraph (b) of this section\nan employee shall not solicit or accept, directly or\nindirectly, any gift, gratuity, favor, entertainment,\nhonorarium, travel or accommodations expense or the like,\nloan, or any other thing of monetary value from a person\nwho:\n(1) Has, or is seeking to obtain, contractual\nor other business or financial relations with\na Government agency;\n(2) Conducts operations or activities which\nare regulated by a Government agency; or\n(3) Has interests which may be substantially\naffected by the performance or non-performance\nof the employee's official duties.\nFORD :- LIBRARY GERALD\n-10-\n(b) Notwithstanding paragraph (a) of this section,\nan employee may:\n(1) Accept a gift, gratuity, favor, entertain-\nment, honorarium, travel or accommodation expense\nor the like or other thing of monetary value from\na friend, parent, spouse, child or other close\nrelative when the circumstances make it clear that\nthe family relationships involved are the motivating\nfactor;\n(2) Accept food or refreshments in the ordinary\ncourse of a luncheon or dinner meeting or other\nmeeting where an employee may properly be in\nattendance;\n(3) Accept reimbursement for travel expenses in\nconnection with official Government duties from a\nan organization which is exempt from taxation under\nSection 501 (c) (3) of the Internal Revenue Code\nof 1954, as amended. Before the acceptance of\nsuch reimbursement, the employee shall provide the\nCounselor with a written description of the reim-\nbursement to be provided, for the Counselor's\napproval. The Counselor shall keep a copy of this\nreport and the official response on file;\n(4) Accept loans from banks or other financial\ninstitutions on customary terms to finance proper\nor usual activities of employees, such as home\nmortgage loans; and\n(5) Accept unsolicited advertising or promotional\nmaterials such as pens, pencils, note pads,\ncalendars, or other items of nominal intrinsic\nvalue.\n(c) An employee shall not solicit contributions from\nanother employee for a gift to an employee in a\nsuperior official position. An employee in a superior\nofficial position shall not accept a gift presented as\na contribution from employees receiving less salary\nthan the official. An employee shall not make a\ndonation as a gift to an employee in a superior official\nposition (5 U.S.C. 7351). However, this paragraph\ndoes not prohibit a voluntary gift of nominal value or\ndonation in a nominal amount made on a special occasion\nsuch as marriage, illness or retirement.\nFORD i LIBRAR DIVE\n-11-\n(d) A gift or gratuity, the receipt of which is\nprohibited by paragraph (a) of this section, shall be\nreturned to the donor with a written explanation why\nthe return is necessary. A copy of the written\nexplanation shall be submitted to the Counselor for\ntiling in the employee's Official Personnel Folder.\nWhen return of a gift is not possible, the gift or\ngratuity shall be submitted to the Counselor with a\nwritten explanation why the return is not feasible. The\nCounselor shall turn the gift or gratuity over to a public\nor private charity or charitable institution and make a\nrecord of its disposition.\n(e) The Constitution (Art. 1, sec. 9, par. 8) prohibits\nacceptance from foreign governments, except with the\nconsent of Congress of any emolument, office, or title.\nThe Congress has provided for the receipt and disposi-\ntion of foreign gifts and decorations in 5 U.S.C. 7342.\nSee also Executive Order 11320, 31 F.R. 13739, and the\nregulations pursuant thereto in 22 CFR Part 3 (as added\n32 F.R. 6569). Any such gift or thing which cannot\nappropriately be refused shall be submitted to the\nCounselor for transmittal to the State Department.\n14. Outside employment and other activity.\n(a) An employee shall not engage in outside employment,\nactivities, or professional practice not compatible with\nthe full and proper discharge of the duties and responsi-\nbilities of his/her Government employment. Incompatible\nactivities include, but are not limited to:\n(1) Acceptance of a fee, compensation, gift,\npayment of expense, or any other thing of\nmonetary value in circumstances in which\nacceptance may result in, or create the appear-\nance of, a conflict of interest; or\n(2) Outside employment which tends to impair\nthe employee's mental or physical capacity to\nCERTIFICATE\nFORD\nperform his/her Government duties and responsi\nbilities in an acceptable manner.\nGERALD\n(b) Within the limitations imposed by this section,\nemployees are encouraged to engage in teaching,\nlecturing, and writing. However, an employee shall not,\neither for or without compensation, engage in teaching,\nlecturing, or writing that is dependent on information\nobtained as a result of his/her Government employment,\nexcept when that information has been made available to\nthe general public or will be made available on request.\nor when the Vice President gives written authorization\n-12-\nfor the use of non-public information on the basis\nthat the use is in the public interest.\n(c) An employee shall not engage in outside employ-\nment under a State or local government, except in\naccordance with applicable regulations of the Civil\nService Commission (5 CFR 735.203).\n(d) Neither this section nor $13 precludes an employee\nfrom:\n(1) Receipt of bona fide reimbursement, unless\nprohibited by law, for actual expenses for\ntravel and such other necessary subsistence as\nis compatible with these Standards and for which\nno Government payment or reimbursement is made.\nHowever, an employee may not be reimbursed, and\npayment may not be made on his/her behalf, for\nexcessive personal living expenses, gifts,\nentertainment, or other personal benefits.\n(2) Participation in the activities of national\nor State political parties not proscribed by law.\n(3) Participation in the affairs of, or acceptance\nof an award for a meritorious public contribution\nor achievement given by, a charitable, religious,\nprofessional, social, fraternal, nonprofit educa-\ntional or recreational, public service, or, civil\norganization.\n(e) An employee who intends to engage in outside\nemployment shall obtain the approval, through the\nCounselor, of the Vice President. A record of each\napproval under this paragraph shall be filed in the\nemployee's Official Personnel Folder.\n(f) This section does not apply to special Government\nemployees, who are subject to the provisions of $20.\n15. Use of Government property.\nAn employee shall not directly or indirectly use, or\nallow the use of, Government property of any kind,\nincluding property leased to the Government, for other\nFORD is BENALD LIBRAR\n-13-\nthan officially approved activities. An employee has\na positive duty to protect and conserve Government\nproperty including equipment, supplies, and other\nproperty entrusted or issued to him/her.\n16. Misuse of information.\n(a) For the purpose of furthering a private interest,\nan employee shall not, except as provided in paragraph\n(b) of $14 directly or indirectly use, or allow the use\nof, official information obtained through or in connec-\ntion with his/her Government employment which has not\nbeen made available to the general public.\n(b) An employee shall not divulge restricted official\ninformation outside the Office, except as permitted\nunder the instructions pertaining thereto and at the\ntime authorized for its release.\n17. Indebtedness.\nAn employee shall pay each just financial obligation ir\na proper and timely manner, especially one imposed by\nlaw-such as Federal, State, or local taxes. For the\npurpose of this section, a \"just financial obligation\"\nmeans one acknowledged by the employee, or reduced to\njudgment by a court, or one imposed by law, such as\nFederal, State or local taxes; \"in a proper and timely\nmanner\" means in a manner which the Office determines\ndoes not, under the circumstances, reflect adversely\non the Government as his/her employer. In the event\nof dispute between an- employee and an alleged creditor,\nthis section does not require the Office to determine\nthe validity or amount of the disputed debt.\n18. Gambling, betting, and lotteries.\nAn employee shall not participate, while on Government-\nowned or leased property or while on duty for the\nGovernment, in any gambling activity, including the\noperation of a gambling device, in conducting a lottery\nor pool, in a game for money or property, or in selling\nor purchasing a numbers slip or ticket.\nFORD & LIBRARY 070839\n-14-\n19. General conduct prejudicial to the Government.\n(a) An employee shall not engage in criminal,\ninfamous, dishonest, immoral, or notoriously dis-\n9 ceful conduct, or other conduct prejudicial to\nthe Government.\n(b) Discrimination on the basis of race, color,\neligion, sex, or national origin is conduct pre-\njudicial to the Government. An employee, while\nacting in an official capacity, shall not directly\nor indirectly authorize, permit or participate in\nany action, event, or course of conduct which sub-\njects any person to discrimination, or results in\nany person being discriminated against, on the basis\nof race, color, religion, sex or national origin.\n20. Conduct and responsibilities of special Government\nemployees.\n(a) A special Government employee shall not use his/\nher Government employment for a purpose that is, or\ngives the appearance of being, motivated by the desire\nfor private gain for himself/herself or another person,\nparticularly one with whom the employee has family,\nbusiness, or financial ties.\n(b) A special Government employee shall not use\ninside information obtained as a result of his/her\nGovernment employment for private gain for himself/\nherself or another person. whether by direct action\nor by counsel, recommendation, or suggestion to\nanother person, particularly one with whom the\nemployee has family, business, or financial ties.\nFor the purposes of this section, \"inside information\"\nmeans information obtained under Government authority\nwhich has not become part of the body of public\ninformation.\n(c) A special Government employee who engages in\nteaching, lecturing, or writing, whether for or\nwithout compensation, shall not for such purposes\nmake use of information obtained as a result of his/\nher Government employment, except when that informa-\ntion has been made available to the general public\nor will be made available on request, or when the\nVice President gives written authorization for the\nuse of non-public information on the basis that such\nuse is in the public interest.\nFORD 3 LIBRA OTV\n-15-\n(d) A special Government employee shall not use\nhis/her Government employment to coerce, or give\nthe appearance of coercing, a person to provide\nfinancial benefit to such employee or another\nperson, particularly one with whom the employee\nhas family, business, or financial ties.\n(e) Except as provided in paragraph (f) of this\nsection, a special Government employee, while so\nemployed or in connection with his/her employment,\nshall not receive or solicit from a person having\nbusiness with the Office anything of value as a gift,\ngratuity, loan, entertainment, or favor for himself/\nherself or another person, particularly one with\nwhom the employee has family, business, or financial\nties.\n(f) Notwithstanding paragraph (e) of this section,\na special Government employee shall be allowed the\nsame latitude as is authorized for regular Government\nemployees by paragraph (b) of §13.\n(g) Attention of special Government employees is\ndirected to the provisions of 83, making the provi-\nsions of these Standards generally applicable to\ntheir activities.\n21. Additional prohibitions - special Government employees.\n(a) A special Government employee is subject to the\nfollowing major prohibitions.\n(1) An employee may not, except in the\ndischarge of official duties --\n(i) Represent anyone else before a\ncourt or Government agency in a matter\nin which the United States is a party or\nhas an interest and in which the employee\nhas at any time participated personally\nand substantially for the Government\n(18 U.S.C. 203 and 205), or\n(ii) Represent anyone else in a matter\npending before his/her agency unless the\nemployee served there no more than 60\ndays during the previous 365 (18 U.S.C.\n203 and 205). The employee is bound by\nthis restraint despite the fact that the\nmatter is not one in which the employee\nhas ever participated personally and\nsubstantially.\nFORD ; 076930 LIBRARY\n-16-\n(2) The employee may not, after his/her\nGovernment employment has ended, represent any-\none other than the United States in connection with\na particular matter in which the United States is a\narty or has an interest and in which the employee\nparticipated personally and substantially for the\nGovernment (cf. 18 U.S.C. 207(a)).\n(3) The employee may not, for one year after his/\nher Government employment has ended, present any-\none other than the United States in connection with\na particular matter in which the United States is a\nparty or has an interest and which was within the\nboundaries of the employee's official responsi-\nbility during the last year of his/her Government\nservice (cf. 18 U.S.C. 207(b)). This temporary\nrestraint is permanent if the matter is one in\nwhich the employee participated personally and\nsubstantially. See paragraph (2) of this section.\n22. Miscellaneous statutory provisions.\nEach employee shall acquaint himself/herself with each\nstatute that relates to his/her ethical and other con-\nduct as an employee of the Office and of the Government.\nIn particular, attention of employees is directed to\nthe following statutory provisions:\n(a) Chapter II of Title 18, U.S.C., relating to\nbribery, graft, and conflicts of interest, as appro-\npriate to the employees concerned.\n(b) The prohibition against- lobbying with appropriated\nfunds (18 U.S.C. 1913).\n(c) The prohibitions against disloyalty and striking\n(5 U.S.C. 7311, U.S.C. 1918).\n(d) The prohibition against the employment of a\nmember of a Communist organization (50 U.S.C. 784).\n(e) The prohibition against (1) the disclosure of\nclassified information (18 U.S.C. 798, 50 U.S.C. 783);\nand (2) the disclosure of confidential information\n(18 U.S.C. 1905).\n(f) The provision relating to the habitual use of\nintoxicants to excess (5 U.S.C. 7352).\nGERALD FORD LIBRAPA\n-17-\n(g) The prohibition against the misuse of a\nGovernment vehicle (31 U.S.C. 638a (c)\n(h) The prohibition against the misuse of the\nfranking privilege (18 U.S.C. 1719).\n(i) The prohibition against the use of deceit in an\nexamination of personnel action in connection with\nGovernment employment (5 U.S.C. 1917).\n(j) The prchibition against fraud or false statements\nin a Government matter (18 U.S.C. 1001).\n(k) The prohibition against mutilating or destroying\na public record (18 U.S.C. 2071).\n(1) The prohibition against ccunterfeiting and forging\ntransportation requests (18 U.S.C. 508).\n(m) The prohibitions against (1) embezzlement of\nGovernment money or property (18 U.S.C. 641);\n(2) failing to account for public money (18 U.S.C.\n643); and (3) embezzlement of the money or property\nof another person in the possession of an employee by\nreason of his/her employment (18 U.S.C. 654).\n(n) The prohibition against unauthorized use of\ndocuments relating to claims from or by the Govern-\nment (18 U.S.C. 285).\n(o) The prohibition against an employee acting as\nthe agent of a foreign principal registered under\nthe Foreign Agents Registration Act (18 U.S.C. 219).\n(p) Prohibitions against certain kinds of political\nactivities (18 U.S.C. 602, 603, 606, 607).\nIII. Reporting of Employment and Financial Interests.\n23. Reporting of employment and financial interests -\nregular employees.\n(a) Not later than 90 days after the effective\ndate of these Standards, an employee designated\nin paragraph (d) of this section shall submit\nto the Vice President a statement, on a form made\navailable in the Counselor's office, which sets\nforth the following information:\nGERALD ? FORD\n-18-\n(1) A list of the names of all corporations,\ncompanies, firms, or other business enter-\nprises, partnerships, nonprofit organizations,\nand educational or other institutions with or\nin which the employee, the employee's spouse,\nminor child or other member of his/her immediate\nhousehold has--\n(i) Any connection as an employee,\nofficer, owner, director, member,\ntrustee, partner, adviser or consultant;\nor\n(ii) Any continuing financial interest,\nthrough a pension or retirement plan,\nshared income, or other arrangement as\na result of any current or prior employ-\nment or business or professional\nassociation; or\n(iii) Any financial interest through the\nownership of stocks, stock options, bonds,\nsecurities, or other arrangements including\ntrusts.\nHowever, an employee need not report any\nfinancial interest exempted under §9 (e)\nas too remote or inconsequential to affect\nthe integrity of an employee's services\nin a matter.\n(2) A list of the names of the employee's credi-\ntors and the creditors of his/her spouse, minor\nchild, or other member of the immediate household,\nother than those creditors to whom they may be\nindebted by reason of a mortgage on property\nwhich the employee occupies as a personal\nresidence or to whom they may be indebted for\ncurrent and ordinary household and living expenses\nsuch as those incurred for household furnishings,\nan automobile, education, vacations, or the like.\n(3) A list of the employee's interests and those\nof his/her spouse, minor child or other member\nFOR\nof the immediate household in real property or\nrights in lands, other than property which the\nemployee occupies as a personal residence.\nGERALD\n(b) For the purpose of this section \"member of the\nimmediate household\" means a full-time resident of the\nemployee's household who is related by blood.\n-19-\n(c) Each employee designated in paragraph (d) of\nthis section who enters on duty after the effective\ndate of these Standards shall submit such statement\nnot later than 30 days after the date of his/her\nentrance on duty, but not earlier than 90 days after\nsuch effective date.\n(d) Statements of employment and financial interest\nare required of the following:\n(1) Employees paid at a level of the Executive\nSchedule in subchapter II of chapter 53 of\ntitle 5, U.S.C., except a Presidential appointee\nrequired to file a statement of financial\ninterests under section 401 of Executive Order\nNo. 11222 of May 8, 1965.\n(2) Employees in classified positions of\nGS-13 or above, or the equivalent thereof.\n(e) Changes in, or additions to, the information con-\ntained in an employee's statement of employment and\nfinancial interests shall be reported in a supplementary\nstatement as of June 30 each year. If no changes or\nadditions occur, a negative report is required. Not-\nwithstanding the filing of the annual report required\nby this paragraph, each employee shall at all times\navoid acquiring a financial interest that could result,\nor taking an action that would result in a violation\nof the conflicts-of-interest provisions of these\nStandards.\n(f) If any information required to be included on a\nstatement of employment and financial interests or\nsupplementary statement, including holdings placed in\ntrust, is not known to the employee but is known to\nanother person, the employee shall request that other\nperson to submit the information in his/her behalf.\n(g) Paragraph (a) of this section does not require\nan employee to submit any information relating to his/\nher connection with, or interest in, a professional\nsociety or a charitable, religious, social, fraternal,\nrecreational, public service, civic, or political\norganization or a similar organization not conducted\nas a business enterprise. For the purpose of this\nsection, educational and other institutions doing\nresearch and development or related work involving\ngrants of money from or contracts with the Government\nFORD is LIBRO 07V3\n-20-\nare deemed \"business enterprises\" and are required\nto be included in an employee's statement of employ-\nment and financial interests.\n(h) The Office shall hold each statement of employment\nand financial interests in confidence. Each person\ndesignated to review a statement of employment and\nfinancial interests under §25 is responsible for main-\ntaining the statement in confidence and shall not allow\naccess to, or allow information to be disclosed from,\na statement except to carry out the purpose of these\nStandards. The Office may not disclose information\nfrom a statement except as the Civil Service Commission\nor the Vice President may determine for good cause\nshown.\n(i) The statements of employment and financial interests\nand supplementary statements required of employees are\nin addition to, and not in substitution for, or in\nderogation of, any similar requirement imposed by law,\norder, or regulation. The submission of a statement\nby an employee does not permit the employee or any\nother person to participate in a matter in which the\nemployee or the other person's participation is pro-\nhibited by law, order, or regulation.\n(j) An employee who believes that his/her position\nhas been improperly included as one requiring the sub-\nmission of a statement of employment and finantial\ninterests is entitled to obtain a review of his/her\ncomplaint under the Office's grievance procedure.\n(k) This section does not apply to special Govern-\nment employees who are subject to the provisions of\n$24.\n24. Reporting of employment and financial interests -\nspecial Government employees.\n(a) A special Government employee shall submit to the\nVice President, through the Counselor, a statement of\nemployment and financial interests which reports (1)\nall current Federal Government employment, (2) names\nof all corporations, companies, firms, State or local\ngovernment organizations, research organizations, and\neducational or other institutions in or for which he/\nshe is an employee, officer, member, owner, trustee,\ndirector, adviser, or consultant, with or without\ncompensation, (3) those financial interests which the\nOffice determines are relevant in the light of the\nFORD\n07V1\n-21-\nduties the employee is to perform, and (4) the names\nof all partnerships in which the employee is engaged.\n(b) A statement required under this section shall be\nsubmitted at the time of employment and shall be kept\ncurrent throughout the term of a special Government\nemployee's service with the Office. A supplementary\nstatement shall be submitted at the time of any\nreappointment; a negative report will suffice if no\nchanges have occurred since the submission of the last\nstatement.\n25. Reviewing statements of financial interests -- remedial\naction.\n(a) A designee of the Vice President shall review the\nstatements required by §23 and §24 to determine whether\nthere exists a conflict, or appearance of conflict,\nbetween the interests of the employee or special\nGovernment employee concerned and the performance of\nhis/her service for the Government. If the designee\ndetermines that such a conflict or appearance of con-\nflict exists, the designee shall provide the employee\nwith an opportunity to explain the conflict or\nappearance of conflict. If the designee concludes\nthat remedial action should be taken, the statement\nshall be referred to the Vice President, through the\nCounselor, with the designee's recommendation for such\naction. The Vice President after consideration of the\nemployee's explanation and such investigation as the\nVice President deems appropriate, shall direct appro-\npriate remedial action if it is deemed to be necessary.\nIn the absence of a designation by the Vice President\nthe Counselor shall serve as designee hereunder.\n(b) Remedial action pursuant to paragraph (a) of this\nsection may include, but is not limited to:\n(1) Changes in assigned duties.\n(2) Divestment by the employee of his/her\nconflicting interest.\n(3) Disqualification for a particular action.\n(4) Exemption pursuant to paragraph (e) of\n§9 or paragraph (d) of §11.\n(5) Disciplinary action.\nFORD a LIBRAR, 07V339\n-22-\nIV. Supplemental Regulations or Instructions\n26. Supplemental regulations or instructions.\nThe Vice President may issue supplemental and imple-\nmenting regulations or instructions not inconsistent\nwith these Standards as necessary to carry out the\nfull purpose and intent of Executive Order 11222 and\nthese Standards as may be required by the particular\ncircumstances of the Office. Such regulations or\ninstructions may include, but are not limited to,\ndelegation of any authority allowed by law pertaining\nto the functions placed upon the Vice President by\nthese Standards. Such regulations or instructions\nmust be made available to employees and special Govern-\nment employees in the same manner as these Standards\n(see §4).\nFORD is LIBRARY\nAPPENDIX A--CODE OF ETHICS\nFOR GOVERNMENT SERVICE\nResolved by the House of Representatives (the Senate\nconcurring), That it is the sense of the Congress that the\nfollowing Code of Ethics should be adhered to by all Govern-\nment employees, including officeholders:\nCODE OF ETHICS FOR GOVERNMENT SERVICE\nAny person in Government service should:\n1. Put loyalty to the highest moral principles and to\ncountry above loyalty to persons, party, or Government\ndepartment.\n2. Uphold the Constitution, laws, and legal regulations\nof the United States and of all governments therein and never\nbe a party to their evasion.\n3. Give a full day's labor for a full day's pay; giving\nto the performance of his duties his earnest effort and best\nthought.\n4. Seek to find and employ more efficient and economical\nways of getting tasks accomplished.\n5. Never discriminate unfairly by the dispensing of\nspecial favors or privileges to anyone, whether for renumera-\ntion or not; and never accept, for himself or his family,\nfavors or benefits under circumstances which might be construed\nby reasonable persons as influencing the performance of his\ngovernmental duties.\n6. Make no private promises of any kind binding upon the\nduties of office, since a Government employee has no private\nword which can be binding on public duty.\n7. Engage in no business with the Government, either\ndirectly or indirectly, which is inconsistent with the\nconscientious performance of his governmental duties.\n8. Never use any information coming to him confidentially\nin the performance of governmental duties as a means for making\nprivate profit.\nGERALD ? FORD\n-2-\n9. Expose corruption wherever discovered.\n10. Uphold these principles, ever conscious that public\noffice is a public trust.\nPassed July 11, 1958.\nGERALD LISSED ? FORD\nE-1(c)\nPublic Law 87-849\n87th Congress, H. R. 8140\nOctober 23, 1962\nEn Elit\n76 STAT. 1119.\nTo strengthen the criminal laws relating to bribery, graft, and conficts of\ninterest, and for other purposes.\nBe it enacted by the Senate and House of Representatives of the\nUnited States of America in Congress assembled, That (a) so much Bribery,\ngraft,\nof chapter 11 of title 18 of the United States Code as precedes section and\nconflicts\n214 is amended to read as follows:\nof interest.\n18 USC 201\n\"CHAPTER 11-BRIBERY, GRAFT, AND CONFLICTS OF at see.\nINTEREST\n\"See\n\"201. Bribery of public officials and witnesses.\n\"202 Definicions.\n\"203 Compensation of Members of Congress, officers and others, in matters\naffecting the Government\n\"204. Practice in Court of Claims by Members of Congress.\n\"205. Activities of officers and employees in claims against and other matters\naffecting the Government.\n\"206. Exemption of retired othicers of the uniformed services.\n*207. Disqualification of former officers and employees In matters cornected with\nformer duties or official respousibilities; disqualideation of partners.\n\"208. Acts affecting a personal financial interest.\n\"209. Salary of-Government-otüiciala- and employees payable only. by United-\nStates.\n\"210. Offer to procure appointive puolle office.-\n211. Acceptance or solicitation in notain appointive public office\n\"212 Offer of loan or gratuity to benk examiner.\n*213. Acceptance of loan or gratuity by bank examiner.\n\"214. Offer for procurement of Federal Reserve bank loan and discount of\ncommercial paper.\n\"213. Receipt of commissions or gifts for procuring loens.\n\"216. Receipt or charge of commissions or gifts for farm loan, land bank, or\namail business transactions.\n\"217. Acceptance of consideration for adjustment of farm indebtedness.\n\"218. Voiding transactions in violation of chapter; recovery by the United States.\n\"§ 201. Bribery of public officials and witnesses\n\"(a) For the purpose of this section:\nas 'public official' means Member of Congress, or Resident Com- Definitions.\nmissioner, either before or after he has qualified, or an officer or\nemployee or person acting for or on behalf of the United States,\nor any department, agency or branch of Government thereof,\nincluding the District of Columbia, in any official function, under\nor by authority of any such department, agency, or branch of\nGovernment, or a juror; and\n\"person who has been selected to be a public official' means\nany person who has been nominated or appointed to be & public\nofficial, or has been officially informed that he will be so nominated\nor appointed; and\n\" official act' means any décision or action on any question, mat-\nter, cause, suit, proceeding or controversy, which may at any time\nbe pending, or which may by law be brought before any public\nofficial, in his official capacity, or in his place of trust or profit.\n(b) Whoever, directly or indirectly, corruptly gives, offers or\npromises anything of value to any public official or person who has\nbeen selected to be a public official, or offers or promises any public\nofficial or any person who has been selected to be A public official to\ngive anything of value to any other person or entity, with intent-\n(1) to influence any official act: or\n(2) to influence such public official or person who has been\nsolected to be a public official to commit or aid in committing,\nor collude in, or allow, any fraud, or make opportunity for the\ncommission of any fraud, on the United States: or\nFORD\nGERALD\nABOVEIT\n1.\nPub. Law 87-849\nOctober 23, 1962\n'75 STAT. 1120.\n\"(3) to induce such public official or such person who has\nbeen selected to be a public official to do or omit to do any act\nin violation of his lawful duty, or\n\"(c) Whoever, being a public official or person selected to be a\npublic official, directly or indirectly, corruptly asks, demands, eracts,\nsolicits, seeks, accepts, receives, or agrees to receive anything of value\nfor himseif or for any other person or entity, in return for:\n(1) being influenced in his performance of any official act; or\n(2) being influenced to commit or sid in committing, or to\ncollude in, or allow, any fraud, or make opportunity for the\ncommission of any fraud, on the United States; or\n(3) being induced to do or omit to do any act in violation of\nhis official duty; or\n(d) Whoever, directly or indirectly, corruptly gives, offers,\nor promises anything of value 10 any person, or one 3 or promises\nsuch person to give anything of value to any other person or entity,\nwith intent to influ nce the testimony under oath or altirmation of\nsuch first-inentioned person as a witness upon a trial, hearing, or other\nproceeding, before any court, any committee of either House or both\nHouses of Congress, or any agency, commission, or officer authorized\nby the laws of the United States to hear evidence or take testimony,\nor with intent to influence such person to absent himself therefrom; or\n\"(e) Whoever, directly or indirectly, corruptly asks, demands,\nexacts, solicits, seeks, accepts, receives, or agrees to receive anything\nof value for himself or for any other person-or-entity in return for\nbeing influenced in his testimony under oath or affirmation as a wit-\nness upon any such trial, hearing, or other proceeding, or in return\nfor absenting himself therefrom—\n\"Shall be fined not more than $20,000 or three times the monetary\nequivalent of the thing of value, whichever is greater, or imprisoned\nfor not more than fifteen years, or both, and may be disqualified from\nholding any office of honor, trust, or profit under the United States.\n(f) Whoever, otherwise than as provided by law for the proper\ndischarge of official duty, directly or indirectly gives, offers, or\npromises anything of value to any public official, former public official,\nor person selected to be a public official, for or because of any official\nact performed or to be performed by such public official, former\npublic official, or person selected to be a public official; or\n\"(g) Whoever, being a public official, former public official, or\nperson selected to be a public official, otherwise than as provided by\nlaw for the proper discharge of official duty, directly or indirectly\nasks, demands, exacts, solicits, seeks, accepts, receives, or agrees to\nreceive anything of value for himself for or because of any official act\nperformed or to be performed by him; or\n\"(h) Whoever, directly or indirectly, gives, offers, or promises any-\nthing of value to any person, for or because of the testimony under\noath or affirmation given or to be given by such person as a witness\nupon a trial, hearing, or other proceeding, before any court, any\ncommittee of either House or-both Houses of Congress, or any agency,\ncommission, or officer authorized by the laws of the United States to\nhear evidence or take testimony, or for or because of his absence\ntherefrom; or\n\"(i) Whoever, directly or indirectly, asks, demands, exacts, solicits,\nseeks, accepts, receives, or agrees to receive anything of value for\nhimself for or because of the testimony under oath or affirmation given\nor to be given by him as R witness upon any such trial, hearing, or\nother proceeding, or for or because of his absence therefrom-\n\"Shall be fined not more than $10,000 or imprisoned for not more\nthan two years, or both.\nGERALD LIBRARY ? FORD\nOctober 23, 1962\nPub. Law 87-849\n75. STAT. 1121.\n\"(i) Subsections (d), (a), (h), and (i) shall not be construed to\nprohioit the payment or receipt of witness fees provided by law, or\nthe payment, by the party upon whose behalf a witness is called and\nreceipt by a witness, of the reasonable cost of travel and subsistance\nincurred and the reasonable value of time lost in attendance at any\nsuch trial, hearing, or proceeding, or, in the case of expirt witnesses,\ninvolving a technical or professional opinion, a reasonable fee for time\nspent in the preparation of such opinion, and in appearing and\ntestifying.\n\"(½) The offenses and penalties prescribed in this section are seos-\nrate from and in addition to those prescribed in sections 1303, 1504,\nand 1505 of this tide.\n62 Stat. 759.\n\"S 202 Definitions\n\"(a) For the purpose of sections 203, 205, 207, 208, and 209 of this\ntitle the term 'special Government employee' shall mean an officer or\nemployee of the executive or legislative branch of the United States\nGovernment, of any independent agency of the United States or of\nthe District of Columbia, who is retained, designated, appointed, or\nemployed to perform, with or without compensation, for not to exceed\none hundred and thirty days during any period of three hundred and\nsixty-five consecutive days, temporary duties either on a full-time\nor intermittent basis, or n part-time United States Commissioner.\nNotwithstanding the next preceding sentence, every person serving as\na part-time local representative of a Member of Congress in the\nMember's home district or State shall be classified as a special Gov-\nernment employee. Notwithstanding section 20 (c) and (d) of the\nAct of August 10, 1956 (TOA Stat. 632; 5 U.S.C. 30r (c) and (d)),\na Reserve officer of the Armed Forces, or an officer of the National\nGuard of the United States, unless otherwise an officer or employee of\nthe United States, shall be classified as a special Government employee\nwhile on active duty solely for training. A Reserve officer of the\nArmed Forces or an officer of the National Guard of the United States\nwho is voluntarily serving a period of extended active duty in excess\nof one hundred and thirty days shall be classified as an officer of the\nUnited States within the meaning of section 203 and sections 205\nthrough 200 and 218. A Reserve officer of the Armed Forces or an\nofficer of the National Guard of the United States who is serving\ninvoluntarily shall be classified as a special Government employee.\nThe terms 'officer or employed' and 'special Government employee' as\nused in sections 203, 205, 207 through 209, and 218, shall not include\nenlisted members of the Armed Forces.\n\"(b) For the purposes of sections 205 and 207 of this title, the\nterm 'official responsibility' means the direct administrative or oper-\nating authority, whether intermediate or final, and either exercisable\nalone or with others, and either personally or through subordinates,\nto approve; disapprove, or otherwise direct Government action.\n\"§ 203. Compensation to Members of Congress, officers, and others\nin matters affecting the Government\n\"(a) Whoever, otherwise than as provided by law for the proper\ndischarge of official duties, directly or indirectly receives or agrees to\nreceive, or asks, demands, solicits, or seeks, any compensation for any\nservices rendered or to be rendered either by himself or another-\n\"(1) at a time when he is a Member of Congress, Member of\nCongress Elect, Resident Commissioner, or Resident Commis-\nsioner Elect; or\n\"(2) at A time when he is an officer or employee of the United\nStates in the executive, legislative, or judicial branch of the Gov-\nernment, or in any agency of the United States, including the Dis-\ntrict of Columbia,\nGERALD FORD\nPub. Law 37-849\n75 STAT. 1122.\nOctober 23, 1962\nin relation to any proceeding, application, request for a ruling or other\ndetermination, contract, claim, controversy, charge, accusation, arrest,\nor other particular matter in which the United States is 2 party or has\na direct and substantial interest, before nny department, agency, court-\nmartial, officer, or any civil, military, or naval commission, or\n\"(b) Whoever, knowingly, otherwise than as provided by law for\nthe proper discharge of official duties, directly or indirectly gives,\npromises, or offers any compensation for any such services rendered\nor to be rendered at a time when the person to whom the compensation\nis given, promised, or offered, is or was such a Member, Commissioner,\nofficer, or employee-\n\"Shall be fined not more than $10,000 or imprisoned for not more\nthan two years, or both; and shall be incapable of holding any office of\nhonor, trust, or profit under the United States.\n\"(c) A special Government employee shall be subject to subsection\n(a) only in relation to a particular matter involving a specific party\nor parties (1) in which he has at any time participated personally\nand substantially as a Government employee or as a special Govern-\nment employee through decision, approval, disapproval, recommenda-\ntion, the rendering of advice, investigation or otherwise, or (2) which\nis pending in the department or agency of the Government in which\nhe is serving: Provided, That clause (2) shall not apply in the case\nof a special Government employee who has served in such department\nor agency no more than sixty days during the immediately preceding\nperiod of three hundred and sixty-five consecutive days.\n\"§ 204. Practice in Court of Claims by Members of Congress\n\"Whoever, being a Member of Congress, Member of Congress Elect,\nResident Commissioner, or Resident Commissioner Elect, practices in\nthe Court of Claims, shall be fined not more than $10,000 or imprisoned\nfor not more than two years, or both, and shall be incapable of holding\nany office of honor, trust, or profit under the United States.\n\"§ 205. Activities of officers and employees in-claims against and\nother matters affecting the Government\n\"Whoever, being an officer or employee of the United States in the\nexecutive, legislative, or judicial branch of the Government or in\nany agency of the United States, including the District of Columbia,\notherwise than in the proper discharge of his official duties-\n\"(1) acts as agent or attorney for prosecuting any claim against\nthe United States, or receives any gratuity, or any share of or\ninterest in any such claim in consideration of assistance in the\nprosecution of such claim, or\n\"(2) acts as agent or attorney for anyone before any depart-\nment, agency, court, court-martial, officer, or any civil, military,\nor naval commission in connection with any proceeding, appli-\ncation, request for n ruling or other determination, contract,\nclaim, controversy, charge, accusation, arrest, or other particular\nmatter in which the United States is & party or has a direct and\nsubstantial interest—\n\"Shall be fined not more than $10,000 or imprisoned for not more\nthan two years, or both.\n\"A special Government employee shall be subject to the preceding\nparagraphs only in relation to a particular matter involving a specific\nparty or parties (1) in which he has at any time participated per-\nsonally and substantially as n Government employee or as a special\nGovernment employee through decision, approval, disapproval, recom-\nmendation, the rendering of advice, investigation or otherwise, or (2)\nwhich is pending in the department or agency of the Government in\nwhich he is serving: Provided, That clause (2) shall not apply in the\nFORD\nGERALD\nOctober 23, 1962\nPub. Law 87-849\n75 STAT. 1123.\ncase of u special Government employee who has served in such depart-\nment or agency no more than sixty days during the immediately pre-\nceding period of three hundred and sixty-five consecutive days.\n\"Nothing herein prevents an officer or employee, if not inconsistent\nwith the faithful performance of his duties, from acting without com-\npensation 33 agent or attorney for any person who 13 the subject of\ndisciplinary, loyalty, or other personnel administration proceedings\nin connection with those proceedings.\n\"Nothing herein or in section 203 prevents an officer or employee,\nincluding = special Government employee, from acting, with or with-\nout compensation, as agent or attorney for his parents, spouse, child,\nor any person for whom, or for any estate for which, he is serving as\nguardian, executor, administrator, trustee, or other personal fiduciary\nexcept in those matters in which he has participated personally and\nsubstantially as a Government employee, through decision, approval,\ndisapproval, recommendation, the rendering of advice, investigation,\nor otherwise, or which are the subject of his official responsibility,\nprovided that the Government official responsible for appoir tment to\nhis position approves.\n\"Nothing herein or in section 203 prevents a special Government\nemployee from acting as agent or attorney for another person in the\nperformance of work under a grant by, or a contract with or for\nthe benefit of, the United States provided that the head of the depart-\nment or agency concerned with the grant or contract shall certify in\nwriting that the national interest so requires.\n\"Such certification shall be published in the Federal Register.\nPublication in\n\"Nothing herein prevents an officer or employee from giving testi- F. R.\nmony under oath or from making statements required to be made\nunder penalty for perjury or contempt.\n\"§ 206. Exemption of retired officers of the uniformed services\n\"Sections 203 and 205 of this title shall not apoly to a retired\nofficer of the uniformed services of the United States while not on\nactive duty and not otherwise an officer or employee of the United\nStates, or to any person specially excepted by Act of Congress.\n\"§ 207. Disqualification of former officers and employees in\nmatters connected with former duties or official respon-\nsibilities; disqualification of partners\n\"(a) Whoever, having been an officer or employee of the executive\nbranch of the United States Government, of any independent agency\nof the United States, or of the District of Columbia, including a\nspecial Government employee, after his employment has ceased, know-\ningly acts as agent or attorney for anyone other than the United States\nin connection with any judicial or other proceeding, application,\nrequest for a ruling or other determination, contract, claim, contro-\nversy, charge, accusation, arrest, or other particular matter involving\na specific party or parties in which the United States is a party or has\na direct and substantial interest and in which he participated per-\nsonally and substantialiy as an officer or employee, through decision,\napproval, disapproval, recommendation, the rendering of advice,\ninvestigation, or otherwise, while so employed, or\n\"(b) Whoever, having been so employed, within one year after his\nemployment has cersed, appears personally before any court or depart-\nment or agency of the Government as agent, or attorney for, anyone\nother than the United States in connection with any proceeding, appli-\ncation, request for a ruling or other determination, contract, claim,\ncontroversy, charge, accusation, arrest, or other particular matter\ninvolving a specific party or parties in which the United States is a\nparty or directly and substantially interested, and which was under\nFORD\nGERALD\n)\nPub. Law 87-849\nOctober 23, 1962\n75 STAT. 1124.\nhis official responsibility as an officer or employee of the Govern-\nment at any time within a period of one year prior to the termination\nof such resconsibility-\n\"Shall be fined not more than $10,000 or imprisoned for not more\nthan two years, or both: Provided, That nothing in subsection (a)\nor (b) prevents 3 former officer or employee, including a former\nspecial Government employee, with outstanding scientific or tech-\nnological qualifications from acting as attorney or agent or appearing\npersonally in connection with a particular matter in a acientific or\ntechnological field if the head of the department or agency concerned\nwith the matter shall make a certification in writing, published in the\nPublication in\nFederal Register, that the national interest would be served by such\nF.R.\naction or appearance by the former officer or employee.\n\"(c) Whoever, being a partner or an officer or employee of the\nexecutive branch of the United States Government, of any independ-\nent agency of the United States. or of the District of Columbia, includ-\ning 3 special Government employee, acts as agent or attorney for any-\none other than the United States, in connection with any judicial or\nother proceeding, application, request for a rali g or other determina-\ntion, contract, claim, controversy, charge, accusation, arrest, or other\nparticular matter in which the United States is a party or has a direct\nand substantial interest and in which such officer or employee of the\nGovernment or special Government employee participates or has par-\nticipated personally and substantially as a Government employee\nthrough decision, roproval disapproval, recommendation, the render-\ning of advice, investigation or otherwise, or which is the subject of his\nofficial responsibility-\n\"Shall be fined not more than $5,000, or imprisoned not more than\none year, or both.\n\"A partner of a present or former officer or employee of the execu-\ntive branch of the United States Government, of any independent\nagency of the United Scates, or of the District of Columbia or of n\npresent or former special Government employee shall as such be sub-\nject to the provisions of sections 203, 205, and 207 of this title only as\nexpressly provided in subsection (c) of this section.\n\"§ 208. Acts affecting a personal financial interest\n\"(a) Except as permitted by subsection (b) hereof, whoever, being\nan officer or employee of the executive branch of the United States\nGovernment, of any independent agency of the United States, or of the\nDistrict of Columbia, including a special Government employee\nparticipates personally and substantially as a Government officer or\nemployee, through decison, approval, disapproval, recommendation,\nthe rendering of advice, investigation, or otherwise, in a judicial or\nother proceeding, application, request for a ruling or other deter-\nmination, contract, claim, controversy, charge, accusation, arrest, or\nother particular matter in which. to his knowledge, he, his spouse,\nminor child, partner, organization in which he is serving as officer,\ndirector, trustee, partner or employee, or any person or organization\nwith whom he is negotiating or has any arrangement concerning\nprospective employment, has a financial interest-\n\"Shall be fined not more than $10,000, or imprisoned not more than\ntwo years, or both.\n(b) Subsection (a) hereof shall not apply (1) if the officer or\nemployee first advises the Government official responsible for appoint-\nment to his position of the nature and circumstances of the judicial\nor other proceeding, application, request for a ruling or other deter-\nmination, contract, claim, controversy, charge, accusation, arrest, or\nother particular matter and makes full disclosure of the financial\ninterest and receives in advance a written determination made by such\nFORD,\nGERALD\nIBRARY\nOctober 23, 1962\nPub. Law 37-849\n76 STAT. 1125.\nofficial that the interest is not so substantial as to be deemed likely to\naffect the integrity of the services which the Government may expect\nfrom such officer or employee, or (2) if, by general rule or regulation\npublished in the Federal Register, the financial interest has been Publication in\nexempted from the requirements of clause (1) hereof as being too F. R.\nremote or too inconsequential to affect the integrity of Government\nofficers' or employees' services.\n\"§ 209. Salary of Government officials and employees payable only\nby United States\n\"(2) Whoever receives any salary, or any contribution to or supple-\nmentation of salary, as compensation for his services as an officer or\nemployee of the executive branch of the United States Government,\nof any adependent agency of the United States, or of the District of\nColumbia, from any source other than the Government of the United\nStates, except as may be contributed out of the treasury of any State,\ncounty, or municipality; or\n\"Whoever, whether an individual, partnership, association, corpo-\nration, or other organization pays, or makes any contribution to, or in\nany way supplements the salary of, any such officer or employee under\ncircumstances which would make its receipt a violation of this sub-\nsection-------\n\"Shall be fined not more than $5,000 or imprisoned not more than\none year, or both.\n\" (b) Nothing herein prevents an officer or employee of the executive\nbranch of the United States Government, or of any independent\nagency of the United States, or of the District of Columbia, from con-\ntinuing to participate in a bona fide pension, retirement, group life,\nhealth or accident insurance. profit-sharing, stock bonus, or other\nemployee welfare or benefit plan maintained by a former employer.\n(c) This section does not apply to a special Government employee Exception.\nor to an officer or employee of the Government serving without com-\npensation, whether or not he is a special Government employee, or to\nany person paying, contributing to, or supplementing his salary as\nsuch.\n(d) This section does not prohibit payment or acceptance of con-\ntributions, awards, or other expenses under the terms of the Govern-\nment Employees Training Act (Public Law 85-507, 72 Stat. 327; 5\nU.S.C. 2301-2319, July 7, 1053).\"\n(b) Sections 214 and 215 of chapter 11 of title 18 of the United\nStates Code are respectively redesignated sections 210 and 211;\n(c) Sections 216 and 223 of chapter 11 of title 18 of the United Raptal.\nStates Code are repealed;\n(d) Sections 217, 218, 219, 220, 221, and 222 of chapter 11 of title 18\nof the United States Code are respectively redesignated sections 212,\n213, 214, 215, 216, and 217;\n(e) Chapter 11 of title 18 of the United States Code is further 18 USC 201\namended by adding at the end thereof the following new section: et saq.\n\"§ 218. Voiding transactions in violation of chapter; recovery by\nthe United States\n\"In addition to any other remedies provided by law the President\nor, under regulations prescribed by him, the head of any department-\nor agency involved, may declare void and rescind any contract, loan,\ngrant, subsidy, license, right, permit, franchise, use, authority,\nprivilege, benefit, certificate, ruling, decision, opinion, or rate schedule\nawarded, granted, paid, furnished, or published, or the performance\nof any service or transfer or delivery of any thing to, by or for any\nagency of the United States or officer or employee of the United\nStates or person acting on behalf thereof, in relation to which there\nGERALD FORD\nPub. Law 87-849\nOctober 23, 1962\n76 STAT. 1126.\nhas been a final conviction for any violation of this chapter, and the\nUnited States shall be entitled to recover in addition to any penalty\nprescribed by law or in a contract the amount expended or the thing\ntransferred or delivered on i:3 behalf, or the reasonable value thereof.\nRepaal.\nSac. 2. Sections 281 and 233 (except AS they may apply to retired\nofficers of the armed forces of the United States), 252 and 234 of\nchapter 15 of title 18, section 104 of chapter 23 of title 13, and section\n1914 of chapter 03 of title 18 of the United States Code are repealed\nand will, respectively, be supplanted by sections 203, 203, 20+, 207,\n208, and 200 of title 18 of the United States Coda as set forth in section\nExemptions.\n1 of this Act. All exemptions from the provisions of sections 2S1, 282,\n283, 234, 134, or 1914 of title 18 of the United States Code heretofore\ncreated or authorized by statute which are in force on the effective\ndate of this Act shall, on and after that date, is deemed to be exemo-\ntions from sections 203, 204, 205, 207, 208, or 269, respectively, of litle\n18 of the United States Code except to the extent that they affect\nofficers or employees of the executive branch of the United States\nGovernment, of 2.,ty independent agency of the United States, or of\nthe District of Columbia, as to whom they are no longer applicable.\nRepeal.\nSec. 8. Section 100 of the Revised Statutes (5 U.S.C.99) is repealed.\nEffective date.\nSEC. 4. This Act shall take effect ninety days after the date of its\nenactment.\nApproved October 23, 1962.\nFORD\nGERALD\nIBRARY\n\". & GOVERNMENT PRINTING OFFICE: 1974 0 361-434\nSTANDARDS OF CONDUCT\nFOR THE\nWHITE HOUSE STAFF\nTABLE OF CONTENTS\nParagraph\n1. Introduction\n1\n2. Conflicts of Interest\n2\n3. Financial Interests and Activities\n3\n4. Gifts, Loans, Entertainment and Favors\n5\n5. Reimbursement of Travel, Lodging and Related Expenses While on\nOfficial Business\n6\n6. Gifts, Decorations and Awards from Foreign Governments\n7\n7. Honoraria and Compensation for Speeches, Teaching and Writing\n7\n8. Lobbying\n8\n9. Disclosure or Use of Official Information\n9\n10. Political Activities\n10\n11. Contact With Independent Regulatory Agencies and Procurement\nAgencies\n11\n12. Standards for Departing Personnel\n12\n13. Statutory and Executive Requirements\nEnclosure E-1\nExecutive Order 11222(a)\nU.S. Code, Title 3, Part 100(b)\nPublic Law 87-349(c)\nGERALD FORD LIBRARA\nIntranuction\ntion the integrity of the government and its Jiii-\ncials, the harm is done. In such instances. even if\nof this document is to acquaint you\nthere was no impropriaty intended or proced,\nof the othical concepts and legal TO-\nthe Administration or members of the stad mar :-\nstrictions applicable to you as it member of the\nrequired to spend an inordinate amount of time\nWhite House Office staff. It is hoped that by being\nexplaining or defending innocent actions rather\naware of these standards of official conduct, you\nthan implementing the objectives of the President\nwill by able to recognize and avoid conflict of inter-\nand 2 cloud may be case over the merits of our\ntor improper conduct situ. ors you may\ndecisions. All staf members must, therefore, be\nencounter, and will be alect to seek assistance in\nconstantly aware of improper \"appearances\" as\nresolving any questions that may arise. Please note\nwell as actual conflicts when dealing with others\nthat this memorandum is not designed to cover all\nin or outside of the government.\nsimplies and problems with which you may be\nconfronted; rather it, is only intended to highlight\nFor each area of conduct discussed herein, more\ndetailed information and assistance can be ob-\nin general terms some of the most reoccurring is-\ntained from the OEce of the Counsel to the Presi-\nsues with which you may be confronted.\nThe official regulation governing the standards\ndent. Whenever you have 2 problem or question in\nof conduct for the White House Office is set forth\nthis regard, you should immediately contact that\nOffice for a resolution of the matter.\nin 3 OFR Chapter V, Part 100. This regulation was\nissueri parsuant to Executive Order 11222 which\nprescribes general standards of ethical conduct for\n2. Conflicts of Interest\nall government officers and employees. Copies of\nthe regulation and the Executive Order are at-\nA conflict of interest may exist whenever a mem-\ntached. It is strongly suggested that they be read\nber of the staff has a personal or private interest\nthoroughly as soon as possible, and retained for\nin a matter which is related to his official duties\nyour further reference in addition, you should be\nand responsibilities or the activities of the staff.\nwith the tututes relating\nThe major prohibitions to which you are subject\nto\ndards of conduct and conflicts of interest,\nin order to avoid such situations may be stated\nwhich are also included in the materials provided.\ngenerally as follows:\nAs = general statement of guidance, it might be\n(a) You may 200 participate in your official\nsaid that the statutes and regulations which are ap-\ncapacity in any matter in which you, your\nplicable to you as a member of the staff are directed\nspouse, minor child. outside business associate or\nto insuring the achievement of the following\nperson with whom you are negotiaring for am-\nobjectives:\nployment has 2 financial interest.\n(2) the fair, impartial and equal treatment of\n(b) You may not receive anji salary, or sup-\nthose dealing with the government;\nplementation of your government salary, from\n(4) government decisions\na private source as compensation for your serv-\nan employee's private\nices to the government. You may. however,\ndaterests;\ncontinue to participate in a bona fide pension,\n(c) the maintenance of public confidence in\nretirement, group life. health, or accident in-\nthe integrity of government operations;\nsurance, profit-sharing. stock bonus, or other\n(d) the prevention of use of public office for\nemployee welfare or benefit plan maintained by\nprivate gain; and\na former employer. But such is financial interest\n(e) the prevention of any impediment to the\ndisqualifies you under phragraph :a) in the\neconomy of government business.\nabsence of a waiver.\nAt the outset you should be also aware of one\n(c) You may not. except in the discharge of\nvery apartant factor which is relevant in every\nyour official duties. represent anyone else before\nmatter discussed in this document and which\na government agency 00 1 court in = matter in\nshould always be part of your evaluation of any\nwhich the United States is it party or has an\n,\"U:- encounter: Ic is just as important to\ninterest. This probibition applies kord to paid\n.? appearance of 'L conflict or unethical\nand unpaid representation of another.\nFORD\nac actual Conduct may in short of\nStated another Tax. government personal\ni: 16 levis Line Alc to ques-\nshould 11:30 step 02: of taeis official role and :ICE\nis 3 private capacity to assist privace parties in\nqualifying. However, you should not toly it upon\ndealings with the government, whether for\nyourrelf to make such 2 decision, rather you should\n-nsation 0: not. ,1130. a public official-must\nsubmit the matter to: review.\nin a position of seting for the government\nEach staff member viso is paid # 12:-1 guive-\nwhom his private interests are involved, nor should\nlent to GS-13 or above, is required :-) subject is the\nle receive payments from private sources for the\nCounsel to the President, within 30 days siter his\nperformance of his governmental duties.\nentrance on duty, or promocion, = confidential\nYou will also nota in reading the standards of\nstatement which discloses all his personal employ-\nconduct regulations that there are some specific\nment and Enancial interests and activities as well\nexceptions to these prohibitions. If you feel they\nas those of his spouse, minor children and members\nare applicable to your situation, this should be\nof his immediate family.\nimmediately reviewed with the Counsel to the\nThose filing such statements are required to re-\nPresident.\nport any significant changes, and all ANGE Ela a\nIt should be again stressed that it is of utmost\nsupplementary statement as of June 30 of each\nimportance to the maintenance of public confi-\nyear, even if no changes or addition: have\ndence in the government that you avoid not only\noccurred.\nthese specific prohibitions, but also any conduct or\nThese statements are reviewed by the Col asel\nactivity which would give the appearance of a\nto the President to determine whether , confict,\nconflict or use of your position for the furtherance\nor appearance of conflict, exists between c.ve inter\nof personal goals or interests.\nests of the sceff member and the performance 01\nhis duties, and r:commendations for remedisi ac-\n3. Financial Interasts and Activities\ntions are made where appropriate. These state-\nments are held in confidence and no information\nAs isnoted generally above, a White House staff\ncontained therein may be disclosed except by di-\nmember may not participate in his official capacity\nrection of the President for good cause shown.\nin any decision, recommendation or similar activ-\nIf you are required to file such a statement, the\nity involving any matter in which he has a \"finan-\nappropriate forms should have been supplied to\ncial interest.\" Further, a staff member may not\nyou upon your entrance on duty. Please consult\nhave financial interests which are entered into as\nwith the Counsel to the President if you have any\na result of information obtained through his\nquestions or need specific advice or guidance re-\nemployment.\ngarding the retention of former employee benefits,\nUnder this restriction a \"financial interest\" in-\npossible divesture of holdings, or any problems\ncludes not only that which you may have, but also\nrelated to the establishment of trusts or other\nthat of your spouse, minor child, partner, organi-\nfinancial arrangements which might be necessary\nzation in which you have any significant interest,\nto avoid (e. conflict of interest with your position.\nor any person or organization with whom you are\nPlease nota that the fact that a staff member\nnegotiating or have any arrangement concerning\nmight not be required to file such a statement does\nfuture employment (including, of course, any con-\nnot relieve him of the obligation to refrain from\npany from which you may have a leave of\nparticipation in any matter in which he or his\nabsence).\nIf you have a financial interest which is in-\nimmediate family or business associates may have\na financial interest. Also, although these state-\nvolved or may be affected by a matter on which\nments are a form of notice of a staff member's\nyou are to work, you may not SO participate until\nfinancial and employment interests, this should not\nyou have reviewed the situation with the Counsel\nbe considered to relieve him of the requirement\nto the President and received a written determina-\nto disclose his financial interest in a matter upon\ntion that your interest is not so substantial as to\nwhich he is called to work and to refrain from any\nby in conflict with your performance in that\nfurther participation until the question of possible\nconflict of interest is resolved.\nObviously, most funancial interests are in the\nfocus of ownership of investment property or\n4. Gifts, Loans, Entertainment and Favors\nstocks and bonds, or = directorship or similar posi-\ndon in a company or organization. Quite often,\nFederal statures prohibit your acceptance of i\nsuch interests are not SO signiticant as to be dis-\ngift from a fellow employee receiving less pay thua\nFORD\nGERALD\nLIBRARY\nis\nto law to solicit\nintrinsic value, such 23 pens, pencils, note puls,\nrifts to all employee in a superior\ncalenders, etc. As .- Title of rhumb, gites having\nor to individually give such : gift\na value of 310 or less are considered w be of\n0:\nThese restrictions are designed to\n\"nominal value.\" Please note that if the item is\n22X question that :! person might attempt\nnot of an advertising of promotional nature, it\nto gein favor with a superior by the giving of a\nshould is returned, regardiess of its retus, unless\ngift, and also to resolve that no such gifts are\nthere is another justification for its retencion.\nexpected, and therefore are not interpreted to pre-\nNor do these rules preclude your acceptance of\nchula the exchange nf of nominal value be-\nfood or refreshments of nominal value in the ordi-\nwww.inrs particular office on\nnary course of a luncheon or dinner meeting, or\ntraditional occasions.\nwhile in attendance at 2 function where you are\nMembers of the White Bouse staff may not solicit\notherwise properly in attendance.\n10: accept 2 air favor, administment, loan or any\nLikewise, you are obviously not precluded from\notherthing of imonetary value from any corpora-\naccepting loans from financial institutions on\ntion or person who has or is seeking contractual or\ncustomary terms for use in financing the pur-\nbusiness dealings with any department or agency\nchase of a home, automobile or incurring similar\nin the Executive Branch, or who cond activities\nexpenditures.\nwhich are regulated by any department or agency\nin the Executive Branch, or who has any interests\n5. Reimbursement of Travel, Lodging and Reioted\nwhich be substantially affected by the per-\nExpenses While on Official Business\nformacre of your job. This latter group may in-\nclude persons in the federal government 23 well as\nWhen a staff member is travelling on official\nthose outside the government.\nbusiness, the general rule is that it is not permissi-\nble for him to accept hotel accommodations or\nThere are, of course, some exceptions to these\nreimbursement for transportation or lodging ex-\nprohibitions. You may consider accepting a rea-\npenses from any person or non-governmental\nsonable gift or entertainment from a close per-\norganization. Likewise, it is not permissible to\nist\" tend or relative who lms dealings with the\naccept transportation in private aircraft. There\ngo\nclear that the motivation\nare sicuations, however, in which the staff member\nfor the gift is the personal relationship. However,\nmay, under limited conditions, accept either trans-\nin such it case, due consideration must be given to\nportation reimbursement or accommodations. For\navoiding an appearance of a conflict of interest. If,\nexample, a-statf member could accept an invitation\nfor example, the representative of a company\nto stay at the private residence of his host it, this\nJuving extensive government contracts is a neigh-\nwould be appropriate under the circumstances or\nbor with whom you have been socially close and ex.\nhis visit. In judging the propriety of staying at\nchanged Christmas gifts for years, there would be\nthe private residence of a close personal friend or\nno real conflict in accepting a gift offered. How-\nany other person, the normal rules apply and the\nexer, if the appearance created by receipt of such\nstaff member may accept only when this will not\nin create a problem, then it would be\ncreate u conflict or appearance of conflict with his\nbest-not to accept. ise gift. Again, appearances of\nposition or otherwise be 21. source of embarrass-\nconflict often crente greater problems than true\nment to the President.\nconflicts.\nAny proscribed gift should be returned to the\n6. Gifts, Decorations and Awards From Foreign\ndonor, accompanied by a written explanation of\nGovernments\nthe reasons for its necessary return. It is recom-\nThe Constitution prohibits acceptance from\nused youretain 11 copy of this letter in your\nforeign governments. except with the consent of\nreturn of a gift is not possible\nCongress. of any emoiument, office, or title. Con-\nInr any reason, the gift should be forwarded to the\ngress has provided that a staff member may keep\nOffice of the Counsel to the President with 2 writ-\ncourtesy or souvenir gifts of minimal value and\nten explanation of the infeasibility of its return.\nthat a staff member may accept a gift of more\nThe gift. will then be turned over to charity.\nthan minimal value on behalf of the U.S. Govern-\nY\ne not prechuled from accepting unsolic-\nment, if is concludes that ii would cause offense\ntising or promotional items of IL cominal\nor embarrassment ii) the docor or adversely affect\nFORD\nP.\nLIBRARY\nrelations if refused.-Any such gift which\n(s) National Security Information\ncannos appropriately be refused becomes the prop-\nThe disclosure of classified national security in-\n:: the government and should be submitted\nformation to unauthorized persons is scrietly pro-\nimmediately to the Connsel to the President for\nhibited by Iew. and violators they be prosecuted\ntransmittal to the State Department.\nand discharged. The term \"medional security\ninformation\" refers to defense information classi-\n% Honoraria end Compansation for Speeches,\nToaching and Writing\nfied pursuint to Executive Order 19501 which\nbears the markings \"Confidencial,\" \"Secret\" or\nAs a general policy, a White House staff mem-\n\"Top Secret,\" mistricted data classified under the\nber should not accept an honorarium or compensa-\nAtomic Energy Act of 1054 which bears the mark-\ntion for speeches, lectures, teaching or writing on\ning \"Restricted Data Atomic Energy Act of 1054,\"\n2 subject which is in any way related to his oficial\nand classified crypromaterial which bears mark-\nposition or to the operations or activities of the\nings as authorized by the appropriate agencias,\nWhite House staff or the Executive Office of the\nMaterials classified in this manner invoive in-\nPresident.\nformation concerning national defense, interna-\nThis restriction does not preclude the acceptance\ntional relations and cryptology, the unauthorized\nof an award for a meritorious public contribution\ndisclosures of which could be prejudicial or dam-\nor achievement given by a charitable, professional,\naging to United States security interests.\nreligious, nonprofit, educational, civic or similar\nIt should be noted that the terms designated to\norganization, but you should consult with the\nidentify such classified information (e.g., \"Con-\nCounsel to the President before accepting any such\nfidential,\" \"Sarch\" and \"Top Secret\") should not\naward which entails a monetary grant or which\nbe used on documents which do not fall within\nmay raise a question of conflict of interest.\nthe respective dednitions.\n8. Lobbying\n(b) Confdential Business and Personal Injorma-\nThe direct or indirect use of uppropriated funds\ntion\nfor lobbying activities without express authoriza-\nA number of statutes and regulations restrict\ntion by Congress is prohibited by law. This in-\nthe disclosure by federal officials to unauthorized\ncludes use of appropriated funds to pay for per-\npersons of certain confidential information which\nsonal services, advertisements, communications or\nbusinesses or individuals disclose othicially to \"\ndevices of any kind to influence a Member of Con-\nfederal agency or employee. Such information is\ngress in acting upon legislation. Violators of this\nnot formally classified but still must be treated in\nprohibition may be criminally prosecuted or re-\na confidential manner. Types of this information\nmoved from office. This prohibition obviously is\ninclude trade secrets, business operations and\nnot intended to prevent staff members from com-\nstatistics, personal and business financial data, tax\nmunicating with Members of Congress and provid-\nreturns, investigative reports of law enforcement\ning information about legislation to Members of\nagencies, and personnel and medical information.\nCongress. However, the line between proper infor-\nStaff members are subject to criminal sanctions\nmational publicity in legislative matters and\nif they do not protect this information from use\nimproper lobbying activities should always be kept\nby unauthorized personnel. Care should be exer-\nin mind. Although the sanctions under this law\ncised in passing any such information to make\nhave rarely if ever been used, care should be taken\ncertain that only authorized persons receive it.\nin this regard to avoid criticism by Members of\nCongress and the Comptroller General.\n(c) Administratively Restricted Information\nWhen it is desired to control materials adminis-\n9. Disclosure or Use of Official information\ntratively; i.e., where the contents are not or a\nThere are many types of information to which\nnational security name covered by the deñnitions\nstaff members become privy. With some of this\nfor security classifications, but are to be restricted\nsensitive information, legal and ethical restrie-\nto the view of only certain officials, there are nd-\ntions are imposed upon your disclosure, handling\nministrative classifications which you may use.\nand use of it. The following paragraphs highlight\nThey are \"For Official Use Only,\" \"Administra-\nsome of the problems of which you should be aware\ntively Confidential\" or \"For The Eyes of (partic-\nin this regard.\nular official or officials) Only.\" In certain cases,\n&\nFORD\nGERALD\nLIBRARY\nis\nbe desirable to classify confidential\nWhite House Ofice staff. The principal activities\nersonal information in this manner.\nprohibited by these criminal statutes are:\nT\ninstitutions may also be employed in re-\n(1) Solicitation or receipt of political contri-\nproposed pelicies DE similar sensitive mat-\nbutions by one federal employee from another\nters when it limited dissemination is desired. Each\n(18 USC\nstaff member must use his own discretion in classi-\n(2) The giving or handing over of = political\nfjing information administratively.\ncontribution by one federal employee to another\nInformation\n(18 USC 607).\n(3) Solicitation or receipt of political contri-\nWhite House staff members are prohibited from\nbutions in 2 federal building by any person,\nusing for private gain or personal interest any\nwhether or not 32 employee of the government\ntinformation obtained asm resulting heir osition\n(18 USC 803).\nwhich is Available to the public.\n(4) Solicitation or receipt of anything of\nEach stationfies should establish adequata in-\nvalue, either for personal reward or 23 2 politi-\nternal procedures to assure that classified and\ncal contribution, in return. for the promise to\nsensitive documents and related materials are pro-\nuse, or the use of, influence to secure an appoint-\ntected at all times. A specific person in each office\nive office (18 USC211).\nshould be given this responsibility, but it should be\n(5) Promising employment, compensation or\nmade clear that the last person in an office assumes\nother benefits made possible of act of Congress\nthe responsibility for the security of classified\nas consideration or reward for political activity\nunaterial. Such materials should not be taken from\n(18 USC 600).\nthe White House or EOB except when opera-\n(€) Discrimination by = federal employee in\ntionally necessary, and then only when appropri-\nfavor of or against another officer or employee\nate measures are taken to safeguard it.\non account of political contributions (is USC\nThe Executive Protective Service (EPS) has\n606).\nbee unted TO conduct 2 thorough after-hours\nse\ninspection ff office in the White\n11. Contact With Independent Regulatory Agencies\nHo and EOB on a nightly basis. Their author-\nand Procurement Agencies\nity to inspect extends to all exposed classified or\nsensitive documents, as well as all other related\nYou should also be familiar with the standards\nbeaterials not properly secured. Classified material\nof conduct governing the activities of the White\nnever be left unattended on desks, and when\nHouse staff in its contacts with the regulatory\nan office is closed or vacant, materials should be\nagencies and Executive Branch departments and\nlocked in a secure cabinet. In the event of a serious\nagencies with procurement responsibilities.\nsecurity violation, EPS will file a formal report\nRegulatory Agencies: The cases that come be.\nwith the office concerned.\nfore these agencies are of two general types: rule-\nAll classified and sensitive materials to be de-\nmaking and adjudicative. Both are normally ex-\nstroyed should be separal ed from other office trash\ntremely complicated. extremely important to the\nand raile materials and either destroyed in a\nparties concerned. and involve large amounts of\nishredd PT placed in \"burn bags\" which are col-\nmoney. While there are exceptional occasions\nlected under EPS supervision and are disposed of\nwhen White House staff contact with agency per-\nin the secure macerator located in the EOB.\nsonnel is justified in rule-making proceedings,\nthere i3 no justification for involvement in adjudi-\n10. Political Activities\ncative proceedings. As a general rule, no member\nof the staff should make an es parte contact with\nFederal Haw, primarily through the Hatch Act,\n2 regulatory agency involving any matter pending\nTimits the political activity of federal employees.\nbefore that agency. regardless of whether the pro-\nWhite Frouse Office staff members (i.c., on the\ncredings are deemed 5.) be rule-making or\nWhite House budget payroll) are exempt from ti:e\nadjudicative, when such a contact may imply pref-\nHatch 1.4 prohibitions against engaging in politi-\ncrential treatment or the use of induence on the\ncal\n\"j and management.\ndecision-making process.\nI\n#:3 other federal laws dealing with politi-\nShould you receive inquiries with regard to such\nwhich apply without exception to the\nmatters, you should refer the inquiring party to\ni\nFORD\nGERALD\nLIBRARY\nagency involved, and express 50 opinion on the\n(a) Disquelification in matters\nmise! In short, White Home stati members\nwith former duties or official responsibility\nAnd avoid even tisin mere appearance of interest\nA former stad member is MINI\n0. inthence-and the easiest way to do 50 is w\nfrom acting us 22 egent or naturney 202\navoid discussing matters pending before the inde-\nother than the United States in connection with\npandent regulatory agencies with interested parties\na particular matter in which the United States\nand avoid making ex-parte contacts with agency\nis a party or has an interest and in which he\nbuld 2C occasion arise in the course\nparticipated personally and substacticily for\nof your duties where is appears necessary to dis-\nthe government.\ncass general policy matters with the staff of an\nA former full-time staff member may not for a\nindependent regulatory agency, to avoid any ap-\nperiod of one your after the termination of his\nof impropriaty, you should film consult\ngovernment employment appear personally\nwith the office of the Counsel to the President to\nbefore any court, department or agency as egent\ndetermine whether such contact would be appro-\nor attorney for anyone other than the United\npriate under the circumstances.\nStates in connection with any particular matter\nProcursment Agencies: In recent years the pub-\nin which the United Scates is a party or has a!\nlic has become increasingly sensitive to the allega-\ninterest and which was under the official respon-\ntions of improper influence in the awarding of\nsibility of the former stad member during the\nrecument contracts. Obviously no member of the\nlast year of his government service.\nThis House staff should contact any procurement\n(b) Prohibition against receipt of compansa-\nofficer about a contract in which he has a personal\ntion jor representative services performed before\nfinancial interest or in which 2 relative, friend, or\ngovernment agencies by jormer stap members\nbusiness associate has a financial interest. This is\nor-others during the period of employment 23 a\ntrue not only as to calls or contacts in which in-\nstaff member.\nfluence is directly exerted, but also as to so-called\n1 former staff member as well as a present\ncalls or other communications which\nstaff member is prohibited from receiving or\nmight direct the attention of the procurement of-\nsoliciting any compensation for services ren-\nficer to the fact that the White House starf member\ndered before any department, agency or com-\nhas ail interest.\nmission by himself or uny other person while\nThere are likely to be occasions when the White\nhe was a staff member in relation to a particular\nHouse has a legitimate interest in information\nmatter in which the United States is a party or\nabout procurement matters; in such instances, the\nhas an interest. It should be noted that the :ep-\ncommunication should be made by persons who\nresentative services covered do not include\nhave no direct interest themselves, and whose\nappearances before courts-only agencies, de-\nfriends or associates have no such interests. It is\npartments or commissions.\nadvisable that the lack of such interest be made\nThis prohibition affects the circumstances\ntheir to those receiving the communication so\nunder which n former starf member may join or\nmintended inferences do not arise. To the\nrejoin a firm which is engaged in his particular\nextent that it can be done, information should be\nbusiness. The statute makes it. unlawful fill ::\nobtained after the contracting procedure is com-\nformer employee to share in any fees received by\npleted, or from persons not involved in the deci-\nthe firm for services in relation to a particular\nsion-making process. To avoid the appearance of\nmatter, in which the United States is a party or\nconflict and subsequent embarrassment, White\nhas an interest, performed by the firm at any\nHouse staff members who must contact procure-\ntime during the period of his government ein-\nagencies with regard to pending contracts\nployment. This is so even though the matter was\nshould also first contact the Counsel to the\nnot ever before his particular department or\nPresident.\nagency and did not come to his attention before\nhis separation from the government.\nin Standards for Departing Personnel\nThe new firm member and the firm must make\nan arrangement whereby his share of its income\nAll departing White House staff members are\niз attributed to sources other than iss of the\nof gitterel to observe 1.110 following statutory stand-\nfirm decived from activities covered by this\n2.06 of conduct:\nprohibition.\nis\nFORD\nGERALD\nLIBRARY\n) R4 trictions on partners of former staff\na former staff member from sharing compensa-\nSer:.\ntion with him for certain services rendered inr.\nPartners of former staff members are 25 such\ning his period of government service.\nnot within the scope of the conflict of interest\nIn addition is the foregoing, departing staff\nstatutes discussed in paragraphs (a) and (b).\npersonnel with = legal background who have served\nPartnership with the former staff member does\non the staff in = legal capacity should also famil-\nqualif them ir majures in which\niarize themselves with additional restrictions im-\nthe sixin member is disqualified. however, as in-\nposed by the Code of Professional Responsibility\ndicated above, the law prohibits the partners of\nof the American Bar Association.\nFORD : LIBRARY 07V839\nis\nGERALD\nFORD LIBRARY\nCONFIDENTIAL STATEMENT OF EMPLOYMENT AND FINANCIAL INTERESTS\n(FOR USE BY GOVERNMENT EMPLOYEES)\nissue flast, firse. initial)\n2. TITLE OF POSITION\n:. DATE OF APPOINTMENT IN PRESENT POSITION\n4. AGENCY AND MAJOR ORGANIZA NONAL SEGMENT\nPART 1. EMPLOYMENT AND FINANCIAL INTERESTS. List\nfinancial interests, through a pension or retirement plan, shared\nthe names of all corporations, companies, time, or other business\nincome, or other arrangement as a reault of any current or prior\nenterprises, partnerships, nonprofit organizations, and educational,\nemployment o: business oz professional association; or (c) in\nor other institutions: (a) with which you 319 connected as an\nwhich you have any financial interest through the ownership of\nemployee, officer, owner, director, member, trustee, partner,\nstock, stock options, bonds, securities, or other arrangements\nadviser, or consultant; or (b) in which you have any continuing\nincluding trusts. If none, write NONE\nNAME 8 KIND OF ORGA.\nPOSITION IN ORGANIZATION.\nNATURE OF FINANCIAL\nNIZATION [USI PART 1\nADDRESS\n(usc PART i(a) DESIGNATIONS.\nINTEREST. e.2.. STOCK. PRIOR\nDESIONATIONS WHERE\nIF APPLICABLE.)\nBUSINESS INCOME. lusz PART 1(b)\nAPPLICABLE.1\nto (c) DESIGNATIONS. \" APPLICABLE.\nPART 11. CREDITORS. List the names of your creditors other\nyou may be Indected for current and ordinary household and IIV\nthan those to whoer you may be indebled by reason of a mortgage\ning expenses such as household furnishings, automobile, edual\non property which you occupy as a personal residence cr to whom\ntion, vacation, and similar expenses. If none, write NONE\nCHARACTER OF INDEBTEDNESS, 0.3., PERSONAL\nNAME AND ADDRESS OF CREDITOR\nLOAN, NOTE, SECURITY\nPART III. INTERESTS IN REAL PROPERTY. List your Interest in real property or rights in lands, other than property which yo\noccupy as a personal residence. If none, write NONE\nNATURE OF INTEREST, C.F.\nTYPE OF PROPERTY, e.z.:\nOWNERSHIP. HORTGAGE, LIEN,\nRESIDENCE, HOTEL. APARTMENT,\nADDRESS. (IF RUPAL. GIVE RFD,\nINVESTMENT TRUST\nFARM, UNDEVELOPED LAND\nOP COUNTY AND STATE.)\nPART 1% INFORMATION REQUESTED OF OTHER PERSONS.\nand address of such persons, the date upon which you requeste\nIf any information is to be supplied by other persons, es,\nthat the information be supplied, and the nature of subject mat-\ntrustes, altorney, accountant, relative, please indicate the name\nter Involved. Ii none, write NONE.\nNAME AND ADDRESS\nDATE OF\nREQUEST\nNATURE OF SUBJECT MATTER\nAGENCY MAY INSERT ADDITIONAL INSTRUCTIONS IN THE SPACE BELOW\nI certify that the statements ! have made are ime, complete, and correct to :he best of my knowledge and belie!.\nFORD\nGERALD\nLIBRARY"
}