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Friday, August 13, 2010

Contractor Employees Joining the Government

Today we conclude our five part series on potential ethics issues that contractors may face when working with Government employees. It's important to ensure that your interactions with Government employees don't inadvertently trigger ethics problems for them. Today’s issue involves contractor employees who go to work for the Government.

Ethics questions can arise for contractor employees who enter Government service after working in the private sector.

Many former employees have continuing financial interests in their former employer such as post-retirement benefits, 401k plans invested in company stock, deferred compensation and ESOPs, to name a few. These continuing financial interests might pose a conflict of interest. These conflicts must be somehow resolved. Often times they are resolved by resolved by divestiture, recusal or other measures. Blind trusts are sometimes used for “high level” Government positions.

Even where conflicts are resolved, there is a general rule that prohibits contractor employee from working, for one year after leaving a former employer, on any contract or other Government matter in which his/her former employer is a party (or represents a party), particularly if either he/she or an agency ethics official determines that a reasonable person would question his/her impartiality.

Where to Get Help

The issues that arise when Government and contractor employees interact can be quite complex and no blog is going to give you the comprehensive answers for every question you might have.

Here are a few web links from the United States Office of Government Ethics (OGE) that you might find helpful:

Ethics and Working with Contractors---Questions and Answers

List of agency "Designated Agency Ethics Officials"

Link to Office of Government Ethics Home Page

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