New DOD Restriction Ensures Workers Do Not Violate Conflict of Interest Statute Before, During Or After Employment
If you aren’t sure whether Big Brother is still watching – know that at least at the Department of Defense he is watching its employees before, during and after employment to ensure they do not violate federal “revolving door” statutes.
The Department of Defense recently modified its ethics regulation to ensure DoD personnel, when leaving federal service, do not inadvertently violate federal “revolving door” statutes – the common practice of federal workers leaving government work to take positions with government contractors.
In a memorandum dated Oct. 25, 2004, Deputy Secretary Paul Wolfowitz directed three changes to the departmental ethics regulation, DoD Directive 5500.7-R.
The first change requires senior personnel, including admirals, generals, and senior civilian officials, to certify annually that they are aware of the requirements of three statutes, and have not violated them. The three statutes bar conflicts of interests by procurement officials, all federal employees when negotiating for employment, and all federal employees after they leave the department.
The second change mandates that information on these post-government employment restrictions be included in the annual ethics training program for DoD personnel. This amplifies the current requirements for annual training.
The third element establishes a requirement that all DoD personnel who are leaving federal service receive guidance on the restrictions that will affect them during and after their transition. Many DoD organizations already provide this information as part of the personnel checkout process and briefings.
According the William J. Haynes II, the general counsel and chief ethics officer of the department, “These changes should further strengthen our program of ethics education to help DoD personnel know and appreciate how our ethics laws apply to them.”