![](media/image1.wmf)

***Government Ethics***

#### Instructor Guide

### Federal Emergency Management Agency - Disaster Field Training Organization

### June 2001

+-----------------------------------------------------------------------+
|                                                                       |
+-----------------------------------------------------------------------+
| **COURSE OBJECTIVES**                                                 |
+-----------------------------------------------------------------------+
| > The objectives of this course are to enable participants to:        |
|                                                                       |
| -   Discuss the 14 general principles of ethical conduct              |
|                                                                       |
| -   Identify activities that conflict with Federal employment.        |
|                                                                       |
| -   List the steps to take when confronted with ethical conflicts.    |
+-----------------------------------------------------------------------+
| **TARGET AUDIENCE**                                                   |
+-----------------------------------------------------------------------+
| > The target audience for this training includes all staff assigned   |
| > to Disaster Field Offices. This training can be used also to        |
| > provide the annual ethics briefing for Permanent Full-Time          |
| > employees.                                                          |
+-----------------------------------------------------------------------+
| **APPROXIMATE TIME**                                                  |
+-----------------------------------------------------------------------+
| > 90 minutes                                                          |
+-----------------------------------------------------------------------+
| **CONTENTS**                                                          |
+-----------------------------------------------------------------------+
| > This unit includes the following:                                   |
|                                                                       |
| -   Course Overview                                                   |
|                                                                       |
| -   Course Pre-test                                                   |
|                                                                       |
| -   Ethics Principles                                                 |
|                                                                       |
| ```{=html}                                                            |
| <!-- -->                                                              |
| ```                                                                   |
| -   Reasons for Compliance                                            |
|                                                                       |
| -   Fourteen Principles                                               |
|                                                                       |
| ```{=html}                                                            |
| <!-- -->                                                              |
| ```                                                                   |
| -   Handling Ethical Problems                                         |
|                                                                       |
| ```{=html}                                                            |
| <!-- -->                                                              |
| ```                                                                   |
| -   Activity: Ethics Case Studies                                     |
|                                                                       |
| ```{=html}                                                            |
| <!-- -->                                                              |
| ```                                                                   |
| -   Summary and Course Post-test                                      |
+-----------------------------------------------------------------------+

+-----------------------------------------------------------------------+
| **PREPARING**                                                         |
+-----------------------------------------------------------------------+
| > Use the following checklist to help you prepare for this course:    |
| >                                                                     |
| > **Supplies and Equipment**                                          |
|                                                                       |
| -   *Ethics: Know the Code*, US Office of Government Ethics videotape |
|                                                                       |
| -   VCR and monitors                                                  |
|                                                                       |
| -   Visuals 1 through 24 (Prepare the visuals if necessary. See       |
|     masters at the end of these course materials.)                    |
|                                                                       |
| -   Overhead projector with screen                                    |
|                                                                       |
| -   Chart paper, easels, and markers                                  |
|                                                                       |
| -   Masking tape                                                      |
|                                                                       |
| -   Name cards                                                        |
|                                                                       |
| -   Pens and note paper                                               |
|                                                                       |
| # Handout Materials                                                   |
|                                                                       |
| -   Ethics Supplement (Rules for the Road)                            |
|                                                                       |
| -   FEMA Instruction 1100.1                                           |
|                                                                       |
| -   Ethics Summary for Students                                       |
|                                                                       |
| -   Pre-tests                                                         |
|                                                                       |
| -   Post-tests and answer sheets                                      |
|                                                                       |
| -   Case Studies (See masters at the end of these course materials.)  |
|                                                                       |
| -   Government Ethics End-of-Course Evaluation                        |
+-----------------------------------------------------------------------+
| **NUMBER OF INSTRUCTORS**                                             |
+-----------------------------------------------------------------------+
| > One or two instructors may be used to teach this course.            |
+-----------------------------------------------------------------------+
| **INSTRUCTOR QUALIFICATIONS**                                         |
|                                                                       |
| > Instructors should have training experience, as well as previous    |
| > experience working at a DFO. Instructors without previous disaster  |
| > field experience should not teach this course. If you are           |
| > inexperienced, request an experienced instructor to co-instruct the |
| > first session with you.                                             |
| >                                                                     |
| > You may also want to have a representative from the General Counsel |
| > staff assist in presenting these materials and in answering         |
| > questions. Detailed question may be referred directly to the FEMA   |
| > Ethics Counselor at 202-646-4025.                                   |
+-----------------------------------------------------------------------+

ETHICS COURSE PRE-TEST

1.  You are taking your family to a nice restaurant for your daughter's
    16^th^ birthday. You forgot to make reservations; the greeter takes
    your name, saying you will have a wait time of about 1¼ hours. Since
    you have official Federal identification, you...

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a.  Show your identification and ask the greeter to seat you
    immediately.

b.  Find seating for your family in the waiting area and wait your turn.

c.  Ask to see the manager and request special consideration.

d.  Loudly inform the greeter that you must eat now because of an
    official business appointment.

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2.  You sit on a committee that reviews the bids for the purchase of
    photocopiers for the entire agency. You learn that the new business
    machine company awarded the bid is going to have an Initial Public
    Offering (IPO) on the stock exchange. With this information you...

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a.  Contact a stockbroker and place an order for 1000 shares of the new
    company.

b.  Call your cousin and pass the information to him, suggesting a
    purchase.

c.  Return to your work area and continue the project due at close of
    business today.

d.  Contact the company and ask to be included in the reserved share
    pool for the IPO.

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3.  You have arranged for a motor pool van to take equipment and
    materials to a training course out of town. You are supposed to pick
    up the van Sunday morning for travel to the training site that day.
    Saturday morning your kids have a softball tournament, and others on
    the team do not have transportation. You...

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a.  Make phone calls from home to help the coach find enough
    transportation.

b.  Pick up the van Saturday and transport the whole team to the
    tournament.

c.  Take your own family in the van, and loan your personal car to the
    coach.

d.  Rent a van on your government credit card.

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4.  While driving to work you remember it is your father's birthday, and
    you have not sent a card or gift. You have a cellular phone assigned
    to you by the agency. You...

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a.  Call your father in Arizona with birthday greetings and find out
    what he would like for a gift.

b.  Call your brother and offer to contribute to the mutual purchase of
    a gift for your father.

c.  Call your office number and leave yourself a voice message to
    contact your father later.

d.  Grab a pen and write yourself a reminder on the sticky notes you
    keep in the car.

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5.  A long-time friend and colleague is looking for a new job. You know
    that a State emergency management office has an opening. You...

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a.  Give your friend a copy of the posted job announcement and encourage
    her to apply.

b.  Write a letter of recommendation to the State for your friend on
    agency letterhead.

c.  Call people you work with regularly at the State and ask them to
    consider your friend.

d.  Hand carry the friend's resume to your contacts.

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6.  Your child's class at school is selling candy to raise money for a
    special field trip. The child that sells the most also earns a
    prize. You...

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a.  Bring the candy to the office and go around at your breaks asking
    everyone to buy candy.

b.  Take your child around the neighborhood and to the mall to sell
    candy on the weekend.

c.  Place the candy on your desk while conducting performance reviews
    with your staff members.

d.  Have your spouse and child come to the office to sell candy to all
    your co-workers.

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7.  Your boss is an avid sailor and decorates his office with a sailboat
    theme. You see a beautiful crystal boat that would look great on the
    bookshelf. It costs \$75.00. You...

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a.  Ask co-workers to contribute to the purchase of the gift.

b.  Buy the crystal sailboat and give it to your boss.

c.  Put the item on lay-away and give it for his birthday.

d.  Tell your boss what you saw and where you saw it.

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8.  Your brother is running for elected office in the county where you
    and many co-workers live. He needs some help with his campaign.
    You...

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a.  Invite him to the monthly office brown bag lunch day so he can
    campaign among the staff.

b.  Put a campaign sign in your office window so people passing by can
    see it.

c.  Wear his campaign button to work, and keep extras on your desk for
    others.

d.  Help him with his campaign during your time away from the office.

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```
9.  Your personal credit cards are at their limit and you see "The
    Perfect Gift" for your grandchild. You ...

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```
a.  Wait until the next payday and return to purchase the item.

b.  Use your government credit card to make the purchase.

c.  Borrow money from a co-worker to make the purchase.

d.  Use your government identification to hold the item without
    prepayment.

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10. A contract you supervise is up for renewal. Many potential bidders
    contact you with questions about the contract, the scope of work,
    and the bidding process. One calls repeatedly and engages you in
    personal conversation as well. When they find out you are a
    basketball fan, they send you tickets to the play-off games "just
    because." You...

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a.  Keep the tickets, and call your spouse excitedly.

b.  Return them immediately by way of Procurement, with a firm "no thank
    you."

c.  Send a note to the bidder, offering to pay for the tickets.

d.  Tell the bidder you cannot accept the tickets, but could attend with
    them.

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```
11. You have several personal errands to run at lunchtime, and parking
    in the area is virtually non-existent. You...

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a.  Stop in the Emergency Vehicles Only area placing your agency
    'Official Business' sign on the dashboard.

b.  Use the Loading Zone and flash you identification at a security
    guard asking him to watch the car.

c.  Park in the only spot you can find, run your errands and return late
    to work.

d.  Arrange for some personal leave time to complete your errands.

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12. You observe a co-worker using the office computer to engage in day
    trading on the Internet. This happens frequently throughout the day
    and continually across the week. You...

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```
a.  Report this to the Inspector General's Hotline.

b.  Ignore it, figuring that it is her personal problem.

c.  Ask to learn how to day trade to supplement your salary.

d.  Hold the information for future use with the co-worker or your boss.

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```
13. You have a family crisis and must talk repeatedly with relatives out
    of state. Time zone differences make communication difficult, so
    you...

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a.  Use the office phone to make calls during the crisis.

b.  Take family leave to deal with the crisis from home.

c.  Use your agency cellular phone to call when you can.

d.  Charge tickets on your government credit card to travel.

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```
14. You have an early morning routine staff meeting that you know will
    be boring and repeat what has been said at many other meetings. And
    you stayed up late watching a TV special, so extra sleep is
    appealing. You...

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a.  Go to work and the meeting as scheduled.

b.  Go in late, avoiding the meeting, and pretend you "forgot."

c.  Call in sick, and go skiing.

d.  Go to work and say you have another appointment.

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15. A colleague retires from the agency and starts a consulting company.
    The friend promises to hold a position for you when you retire in
    three more years. You have information and associates that would
    help the new company get contracts. You...

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a.  Provide your friend with information on the associates that are
    potential clients.

b.  Invest in and recommend your friend's company to the agency contract
    specialists.

c.  Accept a finder's fee and work for your friend behind the scenes.

d.  Recuse yourself from proposals involving your friend's company and
    the agency.

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16. Your secretary is going to lunch near the company that does your dry
    cleaning. You have a suit there that you need for a conference
    presentation. You...

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a.  Pick up the suit yourself after work.

b.  Ask your secretary to pick up the suit.

c.  Tell your secretary of the location and hope he offers to get the
    suit.

d.  Suggest to your secretary that personal favors help evaluations.

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17. You have a government vehicle for travel to a conference out of
    state. Your old college roommate lives near the destination (only 45
    miles further) and invites you for dinner and a drink. You...

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a.  Pick your friend up and take him to the restaurant.

b.  Arrange to meet on another occasion when you are not on business.

c.  Drive directly to the restaurant.

d.  Pay for the meal and drinks with your government charge card.

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18. While attending a conference as an agency representative, you see a
    product from a small company that impresses you with its usefulness.
    The company president talks to you extensively and asks you to
    endorse the product. You...

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a.  Agree to endorse the product, and send a statement on agency
    letterhead, with your signature and title.

b.  Ask for financial consideration in providing a product endorsement.

c.  Explain that your personal interest in the product cannot translate
    into your professional life.

d.  Recommend the product as an individual, to many business associates.

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19. You and your fiancé set a wedding date and you tell your co-workers
    of the event. You are starting out with a shaky financial status,
    but figure lots of young couples have done the same and survived,
    with a little help from family and friends. You...

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a.  Hint that you would like a wedding shower at the office.

b.  Suggest that monetary wedding gifts would be welcome.

c.  Invite those in the office with much higher pay grades.

d.  Invite close work friends and tell them not to bring gifts.

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```
20. Personal problems cause a financial crisis in your life. You cannot
    meet all you financial obligations due to emergency expenses that
    exceeded your available savings. Your government credit card bill
    arrives during the worst of the crunch. You...

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```
a.  Ignore it, planning to pay it next month or the month after when
    things improve.

b.  Pay part of it as you do with the other bills you face.

c.  Pay it in full, arranging for credit extensions on your personal
    debts.

d.  Use the government credit card to pay off a personal credit card.

ETHICS COURSE PRE-TEST KEY

1.  b

2.  c

3.  a

4.  d

5.  a

6.  b

7.  d

8.  d

9.  a

10. b

11. d

12. a

13. b

14. a

15. d

16. a

17. b

18. c

19. d

20. c

![](media/image2.png){width="5.333333333333333in"
height="1.6666666666666667in"}

The 14 General Principles - *5 CFR 2635.101(b)(1-14)*

1.  Public service is a public trust requiring employees to place
    loyalty to the Constitution, the laws and ethical principles above
    private gain.

2.  Employees shall not hold financial interests that conflict with the
    conscientious performance of duty.

3.  Employees shall not engage in financial transactions using nonpublic
    Government information or allow the improper use of such
    information.

4.  An employee shall not solicit or accept a gift or other item of
    monetary value from a prohibited source unless authorized to do so.

5.  Employees shall put forth honest effort in the performance of their
    duties.

6.  Employees shall not make unauthorized promises binding the
    Government.

7.  Employees shall not use public office for private gain.

8.  Employees shall act impartially and not give preferential treatment
    to any private organization or individual.

9.  Employees shall protect and use Federal property for authorized
    activities.

10. Employees shall not engage in outside employment or activities that
    conflict with their official Government duties and responsibilities.

11. Employees shall disclose waste, fraud, and abuse to appropriate
    authorities.

12. Employees shall satisfy in good faith their obligations as citizens,
    including all just financial obligations that are imposed by law.

13. Employees shall adhere to legal authorities providing equal
    opportunity for all Americans regardless of race, color, religion,
    sex, age or handicap.

14. Employees shall endeavor to avoid any actions creating the
    appearance that they are violating the law or the ethical standards.

+---------------+------------------------------------------------------+
| **COURSE      |                                                      |
| OVERVIEW**    |                                                      |
|               |                                                      |
| *2 minutes*   |                                                      |
+---------------+------------------------------------------------------+
| ![](media/i   | **Begin** this unit by reviewing the following       |
| mage3.wmf){wi | objectives:                                          |
| dth="2.350694 |                                                      |
| 4444444446in" | ![](media/image5.wmf){width="2.329861111111111in"    |
| height="1.    | height="1.7458333333333333in"}                       |
| 7673611111111 |                                                      |
| 112in"}Visual |                                                      |
| 1 & 2         |                                                      |
|               |                                                      |
| ![](media/i   |                                                      |
| mage4.wmf){wi |                                                      |
| dth="0.614583 |                                                      |
| 3333333334in" |                                                      |
| heig          |                                                      |
| ht="0.7319444 |                                                      |
| 444444444in"} |                                                      |
+---------------+------------------------------------------------------+
| ![](media/i   | **Review the following key points:**                 |
| mage6.wmf){wi |                                                      |
| dth="0.609722 | -   While working for FEMA you are representing the  |
| 2222222223in" |     Federal Government. As a Federal representative, |
| heigh         |     you must ensure that your actions are ethical.   |
| t="0.19791666 |                                                      |
| 666666666in"} | -   You need to make sure that your actions instill  |
|               |     trust and confidence. Any action that may appear |
|               |     unethical (even if it is not breaking any        |
|               |     particular rule) can erode that trust.           |
|               |                                                      |
|               | -   Disaster victims have faced enough personal loss |
|               |     in their lives. We have an obligation to make    |
|               |     sure that they can trust us to deliver fair and  |
|               |     equitable services. Other taxpayers need to be   |
|               |     able to trust that we are spending their tax     |
|               |     dollars wisely and protecting their interests.   |
|               |                                                      |
|               | -   This course is designed to review the ethical    |
|               |     standards that you must uphold as a FEMA         |
|               |     employee.                                        |
+---------------+------------------------------------------------------+
| ##### OPTION  | **Distribute** the course Pre-Test and allow 10      |
|               | minutes for students to complete.                    |
|               |                                                      |
|               | **Collect** the Pre-Test for a co-instructor to      |
|               | score while you continue with the lesson.            |
+---------------+------------------------------------------------------+
| ![](media/i   | **Distribute** the handout titled "Ethics Summary."  |
| mage7.wmf){wi | **Tell** the participants that they can use this     |
| dth="0.524305 | handout to take notes. (A master copy of this        |
| 5555555556in" | handout appears at the end of these course           |
| height        | materials.)                                          |
| ="0.51875in"} |                                                      |
|               |                                                      |
| Ethics        |                                                      |
| Summary       |                                                      |
+---------------+------------------------------------------------------+

+---------------+------------------------------------------------------+
| **ETHICAL     |                                                      |
| PRINCIPLES**  |                                                      |
|               |                                                      |
| *15 minutes*  |                                                      |
+---------------+------------------------------------------------------+
| ![](media/ima | **Prior to Showing the Video**                       |
| ge8.wmf){widt |                                                      |
| h="0.71875in" | 1.  Watch the video excerpt in its entirety.         |
| heig          |                                                      |
| ht="0.6513888 | 2.  Ensure that your video equipment is operating    |
| 888888889in"} |     properly.                                        |
|               |                                                      |
| *"Ethics:     | **Showing the Video**                                |
| Know the      |                                                      |
| Code"*        | 1.  **Tell** the participants they are about to      |
|               |     watch a video on government ethics.              |
| *Video        |                                                      |
| (Running      | 2.  **Ask** students to make note of the elements of |
| Time: 12:37   |     the Code of Ethics on which they may have        |
| minutes)*     |     questions.                                       |
|               |                                                      |
|               | 3.  **Show** the video.                              |
|               |                                                      |
|               | 4.  **Note** that the principles that we will        |
|               |     discuss are based on the simple standards of     |
|               |     right and wrong that we learn as young children. |
|               |                                                      |
|               | **After the Video**                                  |
|               |                                                      |
|               | 1.  **Ask** students if they have any questions.     |
|               |                                                      |
|               | 2.  **Refer** participants to the handout on the     |
|               |     Principles of Ethical Conduct.                   |
|               |                                                      |
|               | 3.  **Note** that this presentation will provide     |
|               |     more detailed information on the principles      |
|               |     introduced in the videotape.                     |
+---------------+------------------------------------------------------+

+---------------+------------------------------------------------------+
| **ETHICAL     |                                                      |
| PRINCIPLES**  |                                                      |
|               |                                                      |
| *3 minutes*   |                                                      |
+---------------+------------------------------------------------------+
| Visual 3      | **Display** the following visual.                    |
|               |                                                      |
| ![](media/i   | ![](media/image9.wmf){width="3.3375in"               |
| mage4.wmf){wi | height="2.501388888888889in"}                        |
| dth="0.614583 |                                                      |
| 3333333334in" |                                                      |
| heig          |                                                      |
| ht="0.7319444 |                                                      |
| 444444444in"} |                                                      |
+---------------+------------------------------------------------------+
| ![](media/i   | **Present the following key points:**                |
| mage6.wmf){wi |                                                      |
| dth="0.609722 | -   Complying with ethics standards helps you keep   |
| 2222222223in" |     your conscience clear and protects your          |
| heigh         |     professional reputation.                         |
| t="0.19791666 |                                                      |
| 666666666in"} | -   Leaders must model compliance with ethical       |
|               |     standards. If you are in a leadership position,  |
|               |     remember to exemplify professional behavior.     |
|               |                                                      |
|               | -   In addition to the loss of public trust, there   |
|               |     are consequences for not complying, including    |
|               |     administrative and criminal sanctions.           |
+---------------+------------------------------------------------------+
| ![](media/im  | What other reasons are there for complying with      |
| age10.wmf){wi | Government ethics standards?                         |
| dth="0.563888 |                                                      |
| 8888888889in" |                                                      |
| height        |                                                      |
| ="0.61875in"} |                                                      |
+---------------+------------------------------------------------------+
|               | **Respond** to the participants' comments. **Note**  |
|               | that the next section will take a closer look at the |
|               | ethics standards that Government employees must      |
|               | follow.                                              |
|               |                                                      |
|               | **Refer** participants to \<www.usoge.gov\> for      |
|               | additional information on government ethics.         |
+---------------+------------------------------------------------------+
| ![](media/i   | **Distribute** copies of FEMA Instruction 1100.1:    |
| mage7.wmf){wi | Standards of Conduct. **Tell** the participants that |
| dth="0.524305 | this Instruction contains the standards of conduct   |
| 5555555556in" | that govern all FEMA employees.                      |
| height        |                                                      |
| ="0.51875in"} |                                                      |
|               |                                                      |
| Handout FEMA  |                                                      |
| 1100.1        |                                                      |
+---------------+------------------------------------------------------+

+---------------+------------------------------------------------------+
| **PRINCIPLES  |                                                      |
| OF ETHICAL    |                                                      |
| CONDUCT**     |                                                      |
|               |                                                      |
| *2 minutes*   |                                                      |
+---------------+------------------------------------------------------+
|               | **Explain** that an Executive Order is a document    |
|               | signed by the President requiring that Government    |
|               | employees or agencies follow certain guidelines.     |
+---------------+------------------------------------------------------+
| Visual 4      | **Display** the visuals and **present** the key      |
|               | points.                                              |
| ![](media/i   |                                                      |
| mage4.wmf){wi | ![](media/image11.wmf){width="3.3375in"              |
| dth="0.614583 | height="2.501388888888889in"}                        |
| 3333333334in" |                                                      |
| heig          |                                                      |
| ht="0.7319444 |                                                      |
| 444444444in"} |                                                      |
+---------------+------------------------------------------------------+
| ![](media/i   | **Present the following key points:**                |
| mage6.wmf){wi |                                                      |
| dth="0.609722 | **The Principles of Ethical Conduct** come directly  |
| 2222222223in" | from Executive Order 12731, which was signed by the  |
| heigh         | President on October 17, 1990.                       |
| t="0.19791666 |                                                      |
| 666666666in"} | Government employees are expected to act in          |
|               | accordance with these principles. The details on the |
|               | expected actions are contained in the Code of        |
|               | Federal Regulations, 5CFR Sec. 2600-2641, and        |
|               | various legislation.                                 |
+---------------+------------------------------------------------------+

+---------------+------------------------------------------------------+
| ###### PRI    |                                                      |
| NCIPLES OF ET |                                                      |
| HICAL CONDUCT |                                                      |
+---------------+------------------------------------------------------+
| #             | ![](media/image12.wmf){width="3.3375in"              |
| #### Visual 5 | height="2.501388888888889in"}                        |
|               |                                                      |
| ![](media/i   |                                                      |
| mage4.wmf){wi |                                                      |
| dth="0.614583 |                                                      |
| 3333333334in" |                                                      |
| heig          |                                                      |
| ht="0.7319444 |                                                      |
| 444444444in"} |                                                      |
+---------------+------------------------------------------------------+
| ![](media/i   | **Present** the following key points after the       |
| mage6.wmf){wi | participants have read through the visual:           |
| dth="0.609722 |                                                      |
| 2222222223in" | Principle 1: You cannot use your FEMA position for   |
| heigh         | your **private gain**.                               |
| t="0.19791666 |                                                      |
| 666666666in"} | For example:                                         |
|               |                                                      |
|               | -   Personal calls on Government phones, including   |
|               |     cell phones.                                     |
|               |                                                      |
|               | -   Using Government vehicles for personal use.      |
|               |                                                      |
|               | ```{=html}                                           |
|               | <!-- -->                                             |
|               | ```                                                  |
|               | -   These are examples of using Federal property for |
|               |     unauthorized activities. The expenses are        |
|               |     shifted to the government and away from you, so  |
|               |     this would be the personal gain.                 |
+---------------+------------------------------------------------------+

+---------------+------------------------------------------------------+
| #             | ![](media/image13.wmf){width="3.3375in"              |
| #### Visual 6 | height="2.501388888888889in"}                        |
|               |                                                      |
| ![](media/i   |                                                      |
| mage4.wmf){wi |                                                      |
| dth="0.614583 |                                                      |
| 3333333334in" |                                                      |
| heig          |                                                      |
| ht="0.7319444 |                                                      |
| 444444444in"} |                                                      |
+---------------+------------------------------------------------------+
| ![](media/i   | **Present** the following key points after the       |
| mage6.wmf){wi | participants have read through the visual:           |
| dth="0.609722 |                                                      |
| 2222222223in" | Principle 2: Do not hold financial interests that    |
| heigh         | conflict with your work.                             |
| t="0.19791666 |                                                      |
| 666666666in"} | -   You must avoid gains in financial interests for  |
|               |     yourself, your spouse, minor children, business  |
|               |     partners, potential employers, members of our    |
|               |     household and other family members.              |
+---------------+------------------------------------------------------+
|               | **Discussion Question:**                             |
|               |                                                      |
|               | What is an example of conflicting financial          |
|               | interests?                                           |
+---------------+------------------------------------------------------+
|               | Possible Answers:                                    |
|               |                                                      |
|               | -   Giving a family member inside information about  |
|               |     potential contracts.                             |
|               |                                                      |
|               | -   Getting paid by the national media for an inside |
|               |     story about FEMA.                                |
|               |                                                      |
|               | -   Asking for future employment with a company that |
|               |     wants to do business with FEMA.                  |
|               |                                                      |
|               | -   Influencing a decision to get a mitigation       |
|               |     project for your neighborhood.                   |
|               |                                                      |
|               | -   Selling photographs or video footage of disaster |
|               |     damage.                                          |
|               |                                                      |
|               | -   Taking valuable gifts from community members for |
|               |     taking time to help them out.                    |
+---------------+------------------------------------------------------+

+---------------+------------------------------------------------------+
| **PRINCIPLES  |                                                      |
| OF ETHICAL    |                                                      |
| CONDUCT**     |                                                      |
+---------------+------------------------------------------------------+
| Visual 7      | ![](media/image14.wmf){width="3.3375in"              |
|               | height="2.501388888888889in"}                        |
| ![](media/i   |                                                      |
| mage4.wmf){wi |                                                      |
| dth="0.614583 |                                                      |
| 3333333334in" |                                                      |
| heig          |                                                      |
| ht="0.7319444 |                                                      |
| 444444444in"} |                                                      |
+---------------+------------------------------------------------------+
| ![](media/i   | After the participants have read through the visual, |
| mage6.wmf){wi | **present** the following **key points:**            |
| dth="0.609722 |                                                      |
| 2222222223in" | Principle 3: Employees shall not engage in financial |
| heigh         | transactions using nonpublic Government information  |
| t="0.19791666 | or allow the improper use of such information.       |
| 666666666in"} |                                                      |
|               | -   This means that you cannot misuse your access to |
|               |     "inside" information.                            |
|               |                                                      |
|               | -   For example, you are a local hire. You find out  |
|               |     that there is going to be a food and ice         |
|               |     distribution center opening in 4 hours. The      |
|               |     Federal Coordinating Officer is waiting to       |
|               |     release the information until the center can be  |
|               |     set up and lines managed. Your family needs food |
|               |     and ice. You **cannot** tell your husband the    |
|               |     location of a food and ice distribution center   |
|               |     until the information is ready for public        |
|               |     release. You cannot use this information to get  |
|               |     your family to the front of the line.            |
+---------------+------------------------------------------------------+
| #             | ![](media/image15.wmf){width="3.3375in"              |
| #### Visual 8 | height="2.501388888888889in"}                        |
|               |                                                      |
| ![](media/i   |                                                      |
| mage4.wmf){wi |                                                      |
| dth="0.614583 |                                                      |
| 3333333334in" |                                                      |
| heig          |                                                      |
| ht="0.7319444 |                                                      |
| 444444444in"} |                                                      |
+---------------+------------------------------------------------------+
| ![](media/i   | **Review the following key points:**                 |
| mage6.wmf){wi |                                                      |
| dth="0.609722 | Principle 4: An employee shall not solicit or accept |
| 2222222223in" | a gift or other item of monetary value from a        |
| heigh         | subordinate or prohibited source unless authorized   |
| t="0.19791666 | to do so.                                            |
| 666666666in"} |                                                      |
|               | -   Giving and receiving gifts can get a little      |
|               |     confusing, so we will look at this rule in more  |
|               |     detail.                                          |
|               |                                                      |
|               | -   We will look at:                                 |
|               |                                                      |
|               | ```{=html}                                           |
|               | <!-- -->                                             |
|               | ```                                                  |
|               | -   Accepting and Giving Gifts                       |
|               |                                                      |
|               | -   Prohibited Sources of Gifts                      |
|               |                                                      |
|               | ```{=html}                                           |
|               | <!-- -->                                             |
|               | ```                                                  |
|               | -   Solicitation of Gifts                            |
+---------------+------------------------------------------------------+
| ### Visual 9  | ![](media/image16.wmf){width="3.3375in"              |
|               | height="2.501388888888889in"}                        |
| ###           |                                                      |
|               |                                                      |
| ### ![]       |                                                      |
| (media/image4 |                                                      |
| .wmf){width=" |                                                      |
| 0.61458333333 |                                                      |
| 33334in" heig |                                                      |
| ht="0.7319444 |                                                      |
| 444444444in"} |                                                      |
|               |                                                      |
| ###           |                                                      |
|               |                                                      |
| ###           |                                                      |
+---------------+------------------------------------------------------+
| ### ![](      | **Review the following key points:**                 |
| media/image6. |                                                      |
| wmf){width="0 | -   You cannot ask others to give our gifts. And     |
| .609722222222 |     never accept a gift if it will appear you are    |
| 2223in" heigh |     violating ethical principles.                    |
| t="0.19791666 |                                                      |
| 666666666in"} | -   Your supervisor cannot ask you for a birthday    |
|               |     gift or a gift for boss's day. Also, you should  |
|               |     not be giving your supervisors gifts except for  |
|               |     special occasions such as births, deaths,        |
|               |     illnesses and weddings. Under these              |
|               |     circumstances, the gift must be completely       |
|               |     voluntary and worth a market value of \$10.00 or |
|               |     less.                                            |
|               |                                                      |
|               | There are exceptions and guidelines to follow when   |
|               | you are hosting officials from other countries. You  |
|               | should ask your supervisor or the General Counsel if |
|               | you are unsure about a particular situation.         |
+---------------+------------------------------------------------------+

+---------------+------------------------------------------------------+
| ##            | ![](media/image17.wmf){width="3.3375in"              |
| ### Visual 10 | height="2.501388888888889in"}                        |
|               |                                                      |
| ![](media/i   |                                                      |
| mage4.wmf){wi |                                                      |
| dth="0.614583 |                                                      |
| 3333333334in" |                                                      |
| heig          |                                                      |
| ht="0.7319444 |                                                      |
| 444444444in"} |                                                      |
+---------------+------------------------------------------------------+
|               |                                                      |
+---------------+------------------------------------------------------+
| ![](media/i   | **Review the following key points:**                 |
| mage6.wmf){wi |                                                      |
| dth="0.609722 | -   You cannot accept a gift from a prohibited       |
| 2222222223in" |     source that is worth more than \$20.00, even if  |
| heigh         |     the gift is unsolicited.                         |
| t="0.19791666 |                                                      |
| 666666666in"} | -   Unsolicited gifts of a one-time nature can be    |
|               |     accepted if the market value of the gift is      |
|               |     \$20.00 or less as long as the gifts do not      |
|               |     exceed \$50.00 per year from the same source.    |
|               |                                                      |
|               | -   A **prohibited source** is defined as someone    |
|               |     that seeks official action by FEMA, does         |
|               |     business with FEMA, has activities that are      |
|               |     regulated by FEMA, or has interests that may be  |
|               |     affected by you when you are doing your job.     |
|               |                                                      |
|               | **Stress** that unsolicited gifts can be declined if |
|               | you think accepting the gift is inappropriate and    |
|               | may create the appearance that you are violating     |
|               | ethical standards.                                   |
+---------------+------------------------------------------------------+
|               | **Discussion Question:**                             |
|               |                                                      |
|               | What are some examples of prohibited sources of      |
|               | gifts that you may encounter in your job?            |
+---------------+------------------------------------------------------+
|               | **Possible Answers:**                                |
|               |                                                      |
|               | \- Seeking action from FEMA: FEMA employee being     |
|               | investigated.                                        |
|               |                                                      |
|               | \- Doing Business with FEMA: Contractors, suppliers, |
|               | local merchants.                                     |
|               |                                                      |
|               | \- Regulated by FEMA: State/local officials.         |
|               |                                                      |
|               | \- Affected by Official Actions: Disaster victims,   |
|               | FEMA staff, contractors                              |
+---------------+------------------------------------------------------+
| #####         | -   And remember that prohibited sources that have   |
|               |     official relationships with you cannot give      |
|               |     gifts to your spouse, children, parents,         |
|               |     siblings, or dependent relatives.                |
|               |                                                      |
|               | -   You cannot suggest to prohibited sources that    |
|               |     they should give gifts to others that you may    |
|               |     know.                                            |
|               |                                                      |
|               | **Ask** the participants if they have any questions  |
|               | about accepting and giving gifts.                    |
+---------------+------------------------------------------------------+
|               |                                                      |
+---------------+------------------------------------------------------+

+---------------+------------------------------------------------------+
| Visual 11     | ![](media/image18.wmf){width="3.3375in"              |
|               | height="2.501388888888889in"}                        |
| ![](media/i   |                                                      |
| mage4.wmf){wi |                                                      |
| dth="0.614583 |                                                      |
| 3333333334in" |                                                      |
| heig          |                                                      |
| ht="0.7319444 |                                                      |
| 444444444in"} |                                                      |
+---------------+------------------------------------------------------+
| ![](media/i   | **Review the following key points:**                 |
| mage6.wmf){wi |                                                      |
| dth="0.609722 | Principle 5: Employees shall put forth an honest     |
| 2222222223in" | effort in the performance of their duties.           |
| heigh         |                                                      |
| t="0.19791666 | -   We were all hired by FEMA to perform a specific  |
| 666666666in"} |     job and we have a responsibility to the          |
|               |     Government and the taxpayers to do what we were  |
|               |     hired to do.                                     |
+---------------+------------------------------------------------------+

+---------------+------------------------------------------------------+
| ##            | ![](media/image19.wmf){width="3.3375in"              |
| ### Visual 12 | height="2.501388888888889in"}                        |
|               |                                                      |
| ![](media/i   |                                                      |
| mage4.wmf){wi |                                                      |
| dth="0.614583 |                                                      |
| 3333333334in" |                                                      |
| heig          |                                                      |
| ht="0.7319444 |                                                      |
| 444444444in"} |                                                      |
+---------------+------------------------------------------------------+
| ![](media/i   | **Review the following key points:**                 |
| mage6.wmf){wi |                                                      |
| dth="0.609722 | Principle 6: Do not exceed your authority or make    |
| 2222222223in" | promises.                                            |
| heigh         |                                                      |
| t="0.19791666 | -   You need to be careful about making promises or  |
| 666666666in"} |     commitments on behalf of the Government. Avoid   |
|               |     making a comment that can be interpreted as a    |
|               |     verbal contract on behalf of the Government.     |
+---------------+------------------------------------------------------+

+---------------+------------------------------------------------------+
| Visual 13     | ![](media/image20.wmf){width="3.3375in"              |
|               | height="2.501388888888889in"}                        |
| ![](media/i   |                                                      |
| mage4.wmf){wi |                                                      |
| dth="0.614583 |                                                      |
| 3333333334in" |                                                      |
| heig          |                                                      |
| ht="0.7319444 |                                                      |
| 444444444in"} |                                                      |
+---------------+------------------------------------------------------+
| ![](media/i   | **Review the following key points:**                 |
| mage6.wmf){wi |                                                      |
| dth="0.609722 | Principle 7: Do not use your public office for       |
| 2222222223in" | private gain.                                        |
| heigh         |                                                      |
| t="0.19791666 | -   You cannot use your position with FEMA for your  |
| 666666666in"} |     private gain or the gain of a friend or family   |
|               |     member.                                          |
|               |                                                      |
|               | -   Do not endorse any product, service or           |
|               |     enterprise with anyone whom you are affiliated   |
|               |     in a non-governmental capacity, including        |
|               |     nonprofit organizations of which you may be an   |
|               |     officer or member.                               |
|               |                                                      |
|               | > Avoiding the appearance of ethical violations is a |
|               | > key phase in the Executive Order establishing the  |
|               | > guidelines for the Principles of Ethical Conduct.  |
+---------------+------------------------------------------------------+

+---------------+------------------------------------------------------+
| Visual 14     | ![](media/image21.wmf){width="3.3375in"              |
|               | height="2.501388888888889in"}                        |
| ![](media/i   |                                                      |
| mage4.wmf){wi |                                                      |
| dth="0.614583 |                                                      |
| 3333333334in" |                                                      |
| heig          |                                                      |
| ht="0.7319444 |                                                      |
| 444444444in"} |                                                      |
+---------------+------------------------------------------------------+
| ![](media/i   | **Present the following key points:**                |
| mage6.wmf){wi |                                                      |
| dth="0.609722 | Principle 8: As a FEMA representative your actions   |
| 2222222223in" | must be impartial and fair. You cannot show          |
| heigh         | **preferential treatment**.                          |
| t="0.19791666 |                                                      |
| 666666666in"} | -   A good test of whether your actions are          |
|               |     impartial is to look at the situation as another |
|               |     person who has all of the knowledge might view   |
|               |     it. If that person would question the            |
|               |     impartiality of your action, then that action    |
|               |     should be avoided.                               |
|               |                                                      |
|               | -   If a situation may appear to be a conflict of    |
|               |     interest where your impartiality may be          |
|               |     questioned, you need to seek prior approval or   |
|               |     authorization. Prior approval or authorization   |
|               |     may help you to avoid the appearance of an       |
|               |     ethical problem.                                 |
|               |                                                      |
|               | -   If impartiality may be questioned, it is         |
|               |     important to have full disclosure of the         |
|               |     situation to all affected parties before taking  |
|               |     any actions.                                     |
|               |                                                      |
|               | For example:                                         |
|               |                                                      |
|               | -   Using your FEMA identification to seek           |
|               |     preferential treatment at a hotel or restaurant. |
|               |                                                      |
|               | -   Influencing a purchase by FEMA from a vendor who |
|               |     is a personal friend.                            |
|               |                                                      |
|               | -   Providing more information to one group of       |
|               |     disaster victims than another group.             |
|               |                                                      |
|               | -   Trying to get expedited processing of a disaster |
|               |     victim's application.                            |
|               |                                                      |
|               | -   Favoring one contractor over another.            |
|               |                                                      |
|               | -   Setting up a Disaster Recovery Center in a       |
|               |     location that favors access by a small group of  |
|               |     disaster victims.                                |
|               |                                                      |
|               | **Ask** if there are any questions about the steps   |
|               | to be taken to ensure that actions will be impartial |
|               | and not misunderstood.                               |
+---------------+------------------------------------------------------+
| ##            | ![](media/image22.wmf){width="3.3375in"              |
| ### Visual 15 | height="2.501388888888889in"}                        |
|               |                                                      |
| ![](media/i   |                                                      |
| mage4.wmf){wi |                                                      |
| dth="0.614583 |                                                      |
| 3333333334in" |                                                      |
| heig          |                                                      |
| ht="0.7319444 |                                                      |
| 444444444in"} |                                                      |
+---------------+------------------------------------------------------+
| ![](media/i   | **Review the following key points:**                 |
| mage6.wmf){wi |                                                      |
| dth="0.609722 | Principle 9: Employees shall **protect and conserve  |
| 2222222223in" | Federal property**.                                  |
| heigh         |                                                      |
| t="0.19791666 | -   Protecting and conserving Government property    |
| 666666666in"} |     applies both to:                                 |
|               |                                                      |
|               | > \- your actions while using government property,   |
|               | > and                                                |
|               | >                                                    |
|               | > \- actions you take if you observe fraud, waste,   |
|               | > and abuse.                                         |
+---------------+------------------------------------------------------+

+---------------+------------------------------------------------------+
| ##            | ![](media/image23.wmf){width="3.3375in"              |
| ### Visual 16 | height="2.501388888888889in"}                        |
|               |                                                      |
| ![](media/i   |                                                      |
| mage4.wmf){wi |                                                      |
| dth="0.614583 |                                                      |
| 3333333334in" |                                                      |
| heig          |                                                      |
| ht="0.7319444 |                                                      |
| 444444444in"} |                                                      |
+---------------+------------------------------------------------------+
|               | ***Note: Interim Agency Policy on Limited Personal   |
|               | Use of Government Equipment, 1/5/00.***              |
|               |                                                      |
|               | -   Supervisors may authorize limited use of         |
|               |     government equipment for personal purposes when  |
|               |     it involved minimal additional expense to the    |
|               |     government; does not interfere with official     |
|               |     business; takes place during non-work hours, and |
|               |     does not support a personal private business.    |
|               |                                                      |
|               | -   **Equipment includes**: personal computers,      |
|               |     related equipment and software; telephones, fax  |
|               |     machines, copiers, Internet connectivity and     |
|               |     e-mail.                                          |
|               |                                                      |
|               | -   **Permitted activities**: making few             |
|               |     photocopies; printing few pages on computer      |
|               |     printer; occasional brief personal phone calls;  |
|               |     infrequently sending or receiving personal       |
|               |     e-mail message; and limited use of the Internet  |
|               |     for personal reasons.                            |
|               |                                                      |
|               | **Inappropriate use**: Transmission of chain         |
|               | letters, mass mailings through e-mail; engaging in   |
|               | fund raising activities; distributing copyrighted    |
|               | material or privacy information; support of illegal, |
|               | offensive or inappropriate activities, downloading   |
|               | or transmitting sexually explicit materials.         |
+---------------+------------------------------------------------------+

+---------------+------------------------------------------------------+
| Visual 17     | ![](media/image24.wmf){width="3.3375in"              |
|               | height="2.501388888888889in"}                        |
| ![](media/i   |                                                      |
| mage4.wmf){wi |                                                      |
| dth="0.614583 |                                                      |
| 3333333334in" |                                                      |
| heig          |                                                      |
| ht="0.7319444 |                                                      |
| 444444444in"} |                                                      |
+---------------+------------------------------------------------------+
| ![](media/i   | **Review the following key points:**                 |
| mage6.wmf){wi |                                                      |
| dth="0.609722 | Principle 10: Employees shall not engage in outside  |
| 2222222223in" | employment or activities that conflict with their    |
| heigh         | official Government duties and responsibilities.     |
| t="0.19791666 |                                                      |
| 666666666in"} | -   In addition, you may not accept compensation     |
|               |     from any source for teaching, speaking, or       |
|               |     writing if the activity is related to official   |
|               |     duties, unless it falls within one of the        |
|               |     exceptions. (5 CFR 2635.807)                     |
|               |                                                      |
|               | -   An employee may accept compensation for teaching |
|               |     a course requiring multiple presentations by the |
|               |     employee if the course is offered as part of the |
|               |     regularly established curriculum of a school or  |
|               |     university, or if it is part of a training       |
|               |     program sponsored and funded by the federal,     |
|               |     State or local government.                       |
|               |                                                      |
|               | **For example**, an attorney employed by the equal   |
|               | Employment Opportunity Commission [could             |
|               | accept]{.underline} compensation for teaching a      |
|               | course at a state college on the subject of Federal  |
|               | employment discrimination law. The attorney [could   |
|               | not accept]{.underline} compensation for teaching    |
|               | the same seminar as part of a continuing education   |
|               | program sponsored by their bar association because   |
|               | the subject of the course is focused on the          |
|               | operations or programs of the EEOC and the sponsor   |
|               | of the course is not an accredited educational       |
|               | institution.                                         |
+---------------+------------------------------------------------------+
|               | **Discussion Question:** What are some outside       |
|               | activities that could conflict with your official    |
|               | Government duties?                                   |
|               |                                                      |
|               | Example: As part of your position, you are required  |
|               | to write regulations dealing with hazardous waste.   |
|               | You would not be permitted to serve as an officer of |
|               | a non-profit environmental organization that         |
|               | routinely submits comments on such regulation. Your  |
|               | service as an officer would require that you         |
|               | disqualify yourself from duties critical to the      |
|               | performance of your official duties on a basis so    |
|               | frequent as to materially impair your ability to     |
|               | perform the duties of your position.                 |
+---------------+------------------------------------------------------+
| ##            | ![](media/image25.wmf){width="3.3375in"              |
| ### Visual 18 | height="2.501388888888889in"}                        |
|               |                                                      |
| ![](media/i   |                                                      |
| mage4.wmf){wi |                                                      |
| dth="0.614583 |                                                      |
| 3333333334in" |                                                      |
| heig          |                                                      |
| ht="0.7319444 |                                                      |
| 444444444in"} |                                                      |
+---------------+------------------------------------------------------+
| ![](media/i   | **Review the following key points:**                 |
| mage6.wmf){wi |                                                      |
| dth="0.609722 | Principle 11: You are required to report fraud,      |
| 2222222223in" | waste and abuse to appropriate authorities.          |
| heigh         |                                                      |
| t="0.19791666 | -   Fraud, waste, and abuse of Government should be  |
| 666666666in"} |     reported to our supervisor, the General Counsel  |
|               |     or to the Inspector General. For your            |
|               |     information, we normally give out the IG         |
|               |     toll-free hotline, 1-800-323-8603.               |
+---------------+------------------------------------------------------+

+---------------+------------------------------------------------------+
| Visual 19     | ![](media/image26.wmf){width="3.3375in"              |
|               | height="2.501388888888889in"}                        |
| ![](media/i   |                                                      |
| mage4.wmf){wi |                                                      |
| dth="0.614583 |                                                      |
| 3333333334in" |                                                      |
| heig          |                                                      |
| ht="0.7319444 |                                                      |
| 444444444in"} |                                                      |
+---------------+------------------------------------------------------+
| ![](media/i   | **Review the following key points:**                 |
| mage6.wmf){wi |                                                      |
| dth="0.609722 | Principle 12: Employees are required to satisfy      |
| 2222222223in" | their obligations as citizens, including all just    |
| heigh         | financial obligations that are imposed by law.       |
| t="0.19791666 |                                                      |
| 666666666in"} | This includes paying your taxes and any financial    |
|               | obligations that you have.                           |
+---------------+------------------------------------------------------+

+---------------+------------------------------------------------------+
| ##            | ![](media/image27.wmf){width="3.3375in"              |
| ### Visual 20 | height="2.501388888888889in"}                        |
|               |                                                      |
| ![](media/i   |                                                      |
| mage4.wmf){wi |                                                      |
| dth="0.614583 |                                                      |
| 3333333334in" |                                                      |
| heig          |                                                      |
| ht="0.7319444 |                                                      |
| 444444444in"} |                                                      |
+---------------+------------------------------------------------------+
| ![](media/i   | **Review the following key points:**                 |
| mage6.wmf){wi |                                                      |
| dth="0.609722 | Principle 13: You are required to adhere to legal    |
| 2222222223in" | authorities providing equal opportunity for all      |
| heigh         | regardless of race, color, religion, sex, age or     |
| t="0.19791666 | handicap.                                            |
| 666666666in"} |                                                      |
+---------------+------------------------------------------------------+

+---------------+------------------------------------------------------+
| ##            | ![](media/image28.wmf){width="3.3375in"              |
| ### Visual 21 | height="2.501388888888889in"}                        |
|               |                                                      |
| ![](media/i   |                                                      |
| mage4.wmf){wi |                                                      |
| dth="0.614583 |                                                      |
| 3333333334in" |                                                      |
| heig          |                                                      |
| ht="0.7319444 |                                                      |
| 444444444in"} |                                                      |
+---------------+------------------------------------------------------+
| ![](media/i   | **Review the following key points:**                 |
| mage6.wmf){wi |                                                      |
| dth="0.609722 | Principle 14: Avoid any actions creating the         |
| 2222222223in" | appearance that you are violating any law or the     |
| heigh         | ethical standards.                                   |
| t="0.19791666 |                                                      |
| 666666666in"} | -   Whether particular circumstances create an       |
|               |     appearance that the law or ethical standards     |
|               |     have been violated shall be determined from the  |
|               |     perspective of a reasonable person with          |
|               |     knowledge of the relevant facts.                 |
|               |                                                      |
|               | **Situation:** You are driving back to the hotel     |
|               | after a long day working in the field. You're tired  |
|               | and hungry. Although you are driving safely, you get |
|               | pulled over for going 20 miles over the posted speed |
|               | limit. The police officer approaches the car and     |
|               | sees that you are wearing a FEMA T-shirt. The        |
|               | officer asks if you are en route to an emergency     |
|               | situation. You already have a few speeding tickets   |
|               | and your insurance costs you a small fortune. You    |
|               | think that the officer might let you off the hook if |
|               | you answer "yes."                                    |
|               |                                                      |
|               | **Ask**: How would you answer the officer?           |
|               |                                                      |
|               | -   If you did say "yes" to the officer, would this  |
|               |     situation be an example of not satisfying your   |
|               |     obligations as a citizen? Not creating the       |
|               |     appearance that you are violating any ethical    |
|               |     standards? Misuse of your position? You cannot   |
|               |     ask others to give you gifts. And never accept a |
|               |     gift if it will appear you are violating ethical |
|               |     principles.                                      |
+---------------+------------------------------------------------------+

+---------------+------------------------------------------------------+
| ##            | ![](media/image29.wmf){width="3.3375in"              |
| ### Visual 22 | height="2.501388888888889in"}                        |
|               |                                                      |
| ![](media/i   |                                                      |
| mage4.wmf){wi |                                                      |
| dth="0.614583 |                                                      |
| 3333333334in" |                                                      |
| heig          |                                                      |
| ht="0.7319444 |                                                      |
| 444444444in"} |                                                      |
+---------------+------------------------------------------------------+
| ![](media/i   | **Review the following key points:**                 |
| mage6.wmf){wi |                                                      |
| dth="0.609722 | While Fundraising is not one of the specific 14      |
| 2222222223in" | Principles of Ethics, we get a lot of questions on   |
| heigh         | when you can and cannot solicit funds.               |
| t="0.19791666 |                                                      |
| 666666666in"} | -   **Personal fundraising**, even for good causes   |
|               |     related to disaster relief, is **prohibited**    |
|               |     within Government offices.                       |
|               |                                                      |
|               | -   You cannot raise funds for a cause by using your |
|               |     FEMA title.                                      |
|               |                                                      |
|               | > For example, you cannot make reference to your     |
|               | > position with FEMA to send out letters asking that |
|               | > people make donations to the American Red Cross    |
|               | > for disaster relief.                               |
|               |                                                      |
|               | -   You cannot raise funds from disaster victims,    |
|               |     local officials or staff that you supervise.     |
|               |                                                      |
|               | -   The only exceptions to these fundraising rules   |
|               |     are the Combined federal Campaign or other       |
|               |     activities approved by the U. S. Office of       |
|               |     Personnel Management (OPM).                      |
|               |                                                      |
|               | -   Rules pertaining to political fundraising are    |
|               |     covered by the Hatch Act.                        |
+---------------+------------------------------------------------------+

+---------------+------------------------------------------------------+
| Visual 23     | ![](media/image30.wmf){width="3.3375in"              |
|               | height="2.501388888888889in"}                        |
| ![](media/i   |                                                      |
| mage4.wmf){wi |                                                      |
| dth="0.614583 |                                                      |
| 3333333334in" |                                                      |
| heig          |                                                      |
| ht="0.7319444 |                                                      |
| 444444444in"} |                                                      |
+---------------+------------------------------------------------------+
| ![](media/im  | **Discussion Question:**                             |
| age10.wmf){wi |                                                      |
| dth="0.563888 | ######## What prevents                               |
| 8888888889in" | people from dealing with potential ethical problems? |
| height        |                                                      |
| ="0.61875in"} |                                                      |
+---------------+------------------------------------------------------+
| ![](media/i   | **Present the following key points**:                |
| mage6.wmf){wi |                                                      |
| dth="0.609722 | 1.  The first step in handling an ethical problem is |
| 2222222223in" |     to be able to identify that there may be an      |
| heigh         |     ethics issue. This means being able to apply the |
| t="0.19791666 |     principles and guidelines covered in this        |
| 666666666in"} |     course. It also means thinking about the         |
|               |     potential consequences of your actions before    |
|               |     you act.                                         |
|               |                                                      |
|               | 2.  Next, you need to know right from wrong. If you  |
|               |     are unsure, you should seek advice from the      |
|               |     Ethics Counselor, General Counsel or your        |
|               |     supervisor.                                      |
|               |                                                      |
|               | 3.  Finally, you need to act on your knowledge of    |
|               |     right and wrong. It is not enough to know what   |
|               |     you should do; you must act.                     |
|               |                                                      |
|               | **Ask** if there are any questions about handling    |
|               | ethical problems.                                    |
+---------------+------------------------------------------------------+

+---------------+------------------------------------------------------+
| **HANDLING    |                                                      |
| ETHICAL       |                                                      |
| PROBLEMS**    |                                                      |
|               |                                                      |
| *5 minutes*   |                                                      |
+---------------+------------------------------------------------------+
| ![](media     | **ACTIVITY: ETHICS CASE STUDIES**                    |
| /image31.emf) |                                                      |
|               | **Conduct** this activity as follows:                |
+---------------+------------------------------------------------------+
|               | 1.  **Divide** the participants into small groups of |
|               |     three to six participants.                       |
|               |                                                      |
|               | 2.  **Assign** one of the following case studies to  |
|               |     each group:                                      |
|               |                                                      |
|               | > Case Study 1: Photo Opportunity                    |
|               | >                                                    |
|               | > Case Study 2: An Honest Day's Work                 |
|               | >                                                    |
|               | > Case Study 3: What's a Few Hours?                  |
|               | >                                                    |
|               | > Case Study 4: This One's on the House              |
|               | >                                                    |
|               | > Case Study 5: Could You Do Me a Favor?             |
+---------------+------------------------------------------------------+
| ![](media/i   | 3.  **Distribute** copies of each assigned handout   |
| mage7.wmf){wi |     to the groups. **Make sure** that everyone in    |
| dth="0.524305 |     the group has a copy of the assigned case study. |
| 5555555556in" |                                                      |
| height        | 4.  **Give** the groups 10 minutes to review the     |
| ="0.51875in"} |     situation and to answer the question(s) that     |
|               |     appear below each case study. **Stress** that    |
| Case Studies  |     the groups should include the reasons for their  |
|               |     answers.                                         |
|               |                                                      |
|               | 5.  **Monitor** the time. **Remind** the             |
|               |     participants when 5 minutes remain.              |
|               |                                                      |
|               | 6.  At the end of 10 minutes, **ask** a spokesperson |
|               |     from each group to read the assigned case study  |
|               |     aloud and present the group's responses.         |
|               |                                                      |
|               | 7.  After each group presentation, **ask** the       |
|               |     remaining participants if they have any          |
|               |     additional comments or questions about the case  |
|               |     study.                                           |
|               |                                                      |
|               | 8.  **Repeat** this process until all of the groups  |
|               |     have presented.                                  |
+---------------+------------------------------------------------------+

+---------------+------------------------------------------------------+
| ![](media     | **FINAL EXAMINATION:** Case Study 6: Dewey the FCO   |
| /image32.emf) |                                                      |
|               | 1.  **Give** everyone the case study on Dewey the    |
|               |     FCO and an answer sheet.                         |
|               |                                                      |
|               | 2.  Have them **write** the violations in the first  |
|               |     column and the principle violated in the second  |
|               |     column.                                          |
|               |                                                      |
|               | 3.  **Collect** the answer sheets.                   |
|               |                                                      |
|               | 4.  **Lead** a discussion on the case, asking        |
|               |     participants to indicate their answers.          |
|               |                                                      |
|               | 5.  **Score** and record the exam results. Each      |
|               |     action/violation identified earns two points and |
|               |     each Principle identified earns two points.      |
|               |     Certificates go to those with 70 point or        |
|               |     higher.                                          |
+---------------+------------------------------------------------------+

+---------------+------------------------------------------------------+
|               | **Before showing slide, summarize** this unit by     |
|               | asking the participants to recall one ethics         |
|               | principle that they will remember from this course.  |
|               |                                                      |
|               | **Provide** the name and telephone numbers of the    |
|               | person(s) to be contacted concerning ethical issues. |
|               |                                                      |
|               | **Recommend** that participants record this          |
|               | information on their handouts.                       |
|               |                                                      |
|               | **Distribute** the pamphlet titled "Rules for the    |
|               | Road." **Tell** the participants that this handout   |
|               | contains information on seeking employment after     |
|               | leaving Government service. (A master copy of this   |
|               | handout appears at the end of these course           |
|               | materials.)                                          |
+---------------+------------------------------------------------------+
| Visual 24     | ![](media/image33.wmf){width="3.3375in"              |
|               | height="2.501388888888889in"}                        |
| ![](media/i   |                                                      |
| mage4.wmf){wi |                                                      |
| dth="0.614583 |                                                      |
| 3333333334in" |                                                      |
| heig          |                                                      |
| ht="0.7319444 |                                                      |
| 444444444in"} |                                                      |
+---------------+------------------------------------------------------+
| ![](media/i   | **Show slide.**                                      |
| mage6.wmf){wi |                                                      |
| dth="0.609722 | **Note:**                                            |
| 2222222223in" |                                                      |
| heigh         | It may be difficult to remember the details of 14    |
| t="0.19791666 | Principles, so at least remember these two core      |
| 666666666in"} | concepts:                                            |
|               |                                                      |
|               | \- Do not use public office for private gain         |
|               |                                                      |
|               | \- Act impartially and without preferential          |
|               | treatment.                                           |
|               |                                                      |
|               | Measure your actions by these concepts.              |
+---------------+------------------------------------------------------+

  ----------------------------------------------------- ------------------------------------------------------
  ![](media/image34.wmf){width="0.6958333333333333in"   **Ask** the participants to complete the course
  height="0.7131944444444445in"}                        evaluation form.

  ![](media/image35.wmf){width="0.7645833333333333in"   **Distribute** the course completion certificates to
  height="0.6548611111111111in"}                        each participant.

  ![](media/image36.wmf){width="0.6423611111111112in"   **Thank** the participants and the instructional
  height="0.6798611111111111in"}                        staff.
  ----------------------------------------------------- ------------------------------------------------------

+---------------+------------------------------------------------------+
| ![](media/i   | > **PHOTO OPPORTUNITY**                              |
| mage7.wmf){wi |                                                      |
| dth="0.524305 |                                                      |
| 5555555556in" |                                                      |
| height        |                                                      |
| ="0.51875in"} |                                                      |
|               |                                                      |
| **Case Study  |                                                      |
| 1**           |                                                      |
+---------------+------------------------------------------------------+

**[Purpose]{.underline}:** The purpose of this activity is to apply the
ethics principles and guidelines to specific situations that may be
encountered at a Disaster Field Office.

**[Instructions]{.underline}:**

1.  Review the situation presented below.

2.  After reviewing the situation, work with your team to answer the
    question that follows the situation.

3.  Select a spokesperson. The spokesperson will read the situation
    aloud and present the group's response.

![](media/image37.wmf){width="0.32013888888888886in" height="0.31875in"}

> You have 10 minutes to complete this assignment.

**[Situation]{.underline}:**

> Chris is a member of the Joint Information Center Staff and an
> excellent photographer. During the past 2 weeks he has been
> photographing the damage and disaster victims' reactions. Chris is so
> excited about the quality of the photos, he sent copies of them to a
> camera manufacturer that he works for as a freelance photographer. The
> photos were taken during his off hours, using camera equipment and
> film that the manufacturer gave to Chris. Many of the photos were
> taken in an area that was closed to the public after the disaster. The
> photos include close-up shots of disaster victims. The camera
> manufacturer asked Chris if they could use his photos and a picture of
> Chris at the disaster site wearing his FEMA hat in their promotional
> materials. Chris told the manufacturer that it would be fine as long
> as he did not accept compensation for the photos.

**[Question]{.underline}:**

Are Chris' actions in compliance with Government ethics principles and
standards? *Explain why or why not.*

*[Instructor Note]{.underline}: Using a photo of Chris with a FEMA hat
would be using his official position to endorse a product. This violates
the ethics standards even if he does not receive any compensation. Chris
may have been compensated indirectly by having accepted a free camera
and film from the manufacturer. Also, Chris had access to restricted
areas to photograph that other non-FEMA photographers did not have
access to. Finally, the disaster victims did not agree to have their
images used in promotional materials. How do you think disaster victims
may feel to see their time of grief being used to sell cameras?*

+---------------+------------------------------------------------------+
| ![](media/i   | > **AN HONEST DAY'S WORK**                           |
| mage7.wmf){wi |                                                      |
| dth="0.524305 |                                                      |
| 5555555556in" |                                                      |
| height        |                                                      |
| ="0.51875in"} |                                                      |
|               |                                                      |
| **Case Study  |                                                      |
| 2**           |                                                      |
+---------------+------------------------------------------------------+

**[Purpose]{.underline}:** The purpose of this activity is to apply the
ethics principles and guidelines to specific situations that may be
encountered at a Disaster Field Office.

**[Instructions]{.underline}:**

1.  Review the situation presented below.

2.  After reviewing the situation, work with your team to answer the
    question that follows the situation.

3.  Select a spokesperson. The spokesperson will read the situation
    aloud and present the group's response.

![](media/image37.wmf){width="0.32013888888888886in" height="0.31875in"}

> You have 10 minutes to complete this assignment.

**[Situation]{.underline}:**

> Rose is a local hire working in Community Relations. People have been
> complaining bitterly to her about price gouging by local contractors.
> Rose has heard many stories of contractors taking down payments and
> failing to show up to do the work when they promised. Rose's brother
> is a builder who lives in a nearby State. Rose knows that her brother
> Joe will bring a crew into the State and do the work at a fair price
> and at high quality levels. However, before Joe goes to the trouble of
> relocating his crew, he needs to know if there will be enough work to
> cover his expenses. Rose tells Joe that she cannot solicit work for
> him but that she will give him a list of names and telephone numbers
> of people she has visited as part of her community relations
> activities. Rose knows that the individuals on her list will be very
> relieved to finally hear from a reputable contractor.

**[Question]{.underline}:**

Are Rose's actions in compliance with Government ethics principles and
standards? *Explain why or why not.*

*[Instructor Note]{.underline}: The release of names and telephone
numbers of disaster victims is a violation of the Privacy Act. Even
though Rose is trying to help the people who are in search of an honest
contractor, her actions could be viewed as using access to nonpublic
information to promote her brother's firm.*

+---------------+------------------------------------------------------+
| ![](media/i   | > **WHAT'S A FEW HOURS?**                            |
| mage7.wmf){wi |                                                      |
| dth="0.524305 |                                                      |
| 5555555556in" |                                                      |
| height        |                                                      |
| ="0.51875in"} |                                                      |
|               |                                                      |
| **Case Study  |                                                      |
| 3**           |                                                      |
+---------------+------------------------------------------------------+

**[Purpose]{.underline}:** The purpose of this activity is to apply the
ethics principles and guidelines to specific situations that may be
encountered at a Disaster Field Office.

**[Instructions]{.underline}:**

1.  Review the situation presented below.

2.  After reviewing the situation, work with your team to answer the
    questions that follow the situation.

3.  Select a spokesperson. The spokesperson will read the situation
    aloud and present the group's responses.

![](media/image37.wmf){width="0.32013888888888886in" height="0.31875in"}

> You have 10 minutes to complete this assignment.

**[Situation]{.underline}:**

> The Disaster Field Office is open from 8:00 a.m. to 8:00 p.m. Jack
> comes in every day at 8:00 a.m. and has been working until 8:00 p.m.
> when the DFO closes. Betty noticed that after 6:00 p.m., Jack never
> seems busy. Jack sits at his desk during this 2-hour block of time.
> Each time the supervisor comes by, Jack finds something to make it
> appear as if he is very busy. As soon as the supervisor is gone, Jack
> sits with his hands folded across his chest. Betty decides to ask Jack
> why he stays until 8:00 when his work seems to be done at 6:00 each
> night. Jack's response is that it would be unfair for him to get less
> hours than everyone else who is working in the DFO. Betty decides not
> to push the issue further and ignores the situation.

**[Questions]{.underline}:**

Are Jack's actions in compliance with Government ethics principles and
standards? *Explain why or why not.*

*[Instructor Note]{.underline}: Jack's actions are a misuse of official
time and constitute a wasteful use of Government resources. His actions
are not ethical.*

Are Betty's actions in compliance with Government ethics principles and
standards? *Explain why or why not.*

*[Instructor Note]{.underline}: Betty has an obligation to report fraud,
waste, and abuse. By ignoring the situation, Betty has also violated her
ethical obligations.*

+---------------+------------------------------------------------------+
| ![](media/i   | > **THIS ONE'S ON THE HOUSE**                        |
| mage7.wmf){wi |                                                      |
| dth="0.524305 |                                                      |
| 5555555556in" |                                                      |
| height        |                                                      |
| ="0.51875in"} |                                                      |
|               |                                                      |
| **Case Study  |                                                      |
| 4**           |                                                      |
+---------------+------------------------------------------------------+

**[Purpose]{.underline}:** The purpose of this activity is to apply the
ethics principles and guidelines to specific situations that may be
encountered at a Disaster Field Office.

**[Instructions]{.underline}:**

1.  Review the situation presented below.

2.  After reviewing the situation, work with your team to answer the
    question that follows the situation.

3.  Select a spokesperson. The spokesperson will read the situation
    aloud and present the group's response.

![](media/image37.wmf){width="0.32013888888888886in" height="0.31875in"}

> You have 10 minutes to complete this assignment.

**[Situation]{.underline}:**

> The DFO is phasing down. Fifteen staff members go to a favorite
> after-work spot near the DFO for a farewell celebration. The pub's
> business has certainly increased since the DFO moved into the
> neighborhood. Everyone orders full dinners and several rounds of
> drinks. When it's time to leave, the group asks for the check. The
> owner of the pub insists that tonight's celebration is on her. She
> says, "It's the least I can do, FEMA has been wonderful to me. Not
> only did you help my business, you gave me a place to live when I
> really needed it." The staff members explain that they appreciate her
> gesture, but that they need to pay something. They ask her if they can
> at least leave a big tip.

**[Question]{.underline}:**

Are staff members' actions in compliance with Government ethics
principles and standards? *Explain why or why not.*

*[Instructor Note]{.underline}: The acceptance of the food and drinks
could be seen as payback for the owner receiving disaster housing
assistance. To avoid the appearance of unethical actions, the group
should pay for their dinners and drinks, not just for the tip.*

+---------------+------------------------------------------------------+
| ![](media/i   | > **COULD YOU DO ME A FAVOR?**                       |
| mage7.wmf){wi |                                                      |
| dth="0.524305 |                                                      |
| 5555555556in" |                                                      |
| height        |                                                      |
| ="0.51875in"} |                                                      |
|               |                                                      |
| **Case Study  |                                                      |
| 5**           |                                                      |
+---------------+------------------------------------------------------+

**[Purpose]{.underline}:** The purpose of this activity is to apply the
ethics principles and guidelines to specific situations that may be
encountered at a Disaster Field Office.

**[Instructions]{.underline}:**

1.  Review the situation presented below.

2.  After reviewing the situation, work with your team to answer the
    question that follows the situation.

3.  Select a spokesperson. The spokesperson will read the situation
    aloud and present the group's responses.

![](media/image37.wmf){width="0.32013888888888886in" height="0.31875in"}

> You have 10 minutes to complete this assignment.

**[Situation]{.underline}:**

> Mary supervises several Infrastructure Support inspectors who are
> conducting damage surveys in the field. Mary's daughter is celebrating
> her thirteenth birthday next week. Mary's daughter has asked that her
> mom send her some Native American craft items. One of the inspector
> teams using a FEMA van will be going within 15 miles of the area where
> the crafts can be purchased. Mary knows that she will not be able to
> leave the DFO during the next week. Mary asks the team if they would
> mind going a little out of their way to pick up a gift for her
> daughter. The team readily agrees to the side trip. Mary tells the
> team members that they will make one teenager very happy on her
> birthday.

**[Question]{.underline}:**

Are Mary's actions in compliance with Government ethics principles and
standards? *Explain why or why not.*

*[Instructor Note]{.underline}: Mary is asking the team to use
Government property (the FEMA van) for personal use. The Government van
and team taking a side trip to go shopping could be seen as misuse of
Government property and of official time.*

+---------------+------------------------------------------------------+
| ![](media/i   | **DEWEY THE FCO**                                    |
| mage7.wmf){wi |                                                      |
| dth="0.524305 | ######### FINAL EXAMINATION                          |
| 5555555556in" |                                                      |
| height        |                                                      |
| ="0.51875in"} |                                                      |
|               |                                                      |
| **Case Study  |                                                      |
| 6**           |                                                      |
+---------------+------------------------------------------------------+
| **[Purpose]{. |                                                      |
| underline}:** |                                                      |
| The purpose   |                                                      |
| of this       |                                                      |
| activity is   |                                                      |
| to apply the  |                                                      |
| ethics        |                                                      |
| principles    |                                                      |
| and           |                                                      |
| guidelines to |                                                      |
| a simulated   |                                                      |
| employee and  |                                                      |
| his actions.  |                                                      |
| This serves   |                                                      |
| as the final  |                                                      |
| examination   |                                                      |
| for the       |                                                      |
| course.       |                                                      |
+---------------+------------------------------------------------------+
| **[In         |                                                      |
| structions]{. |                                                      |
| underline}:** |                                                      |
|               |                                                      |
| 1.  Review    |                                                      |
|     the       |                                                      |
|     situation |                                                      |
|     presented |                                                      |
|     below.    |                                                      |
|               |                                                      |
| 2.  After     |                                                      |
|     reviewing |                                                      |
|     the       |                                                      |
|               |                                                      |
|    situation, |                                                      |
|     find all  |                                                      |
|     the       |                                                      |
|     ethical   |                                                      |
|               |                                                      |
|    violations |                                                      |
|     you can.  |                                                      |
|               |                                                      |
| 3.  Enter     |                                                      |
|     them in   |                                                      |
|     the first |                                                      |
|     column of |                                                      |
|     the       |                                                      |
|     answer    |                                                      |
|     sheet     |                                                      |
|     provided. |                                                      |
|               |                                                      |
| 4.  Use the   |                                                      |
|               |                                                      |
|    Principles |                                                      |
|     of        |                                                      |
|     Ethical   |                                                      |
|     Conduct   |                                                      |
|     and       |                                                      |
|     associate |                                                      |
|     each      |                                                      |
|     violation |                                                      |
|     with one  |                                                      |
|     or more   |                                                      |
|     of the    |                                                      |
|               |                                                      |
|   principles. |                                                      |
|     List the  |                                                      |
|     number of |                                                      |
|     the       |                                                      |
|     principle |                                                      |
|     in the    |                                                      |
|     second    |                                                      |
|     column of |                                                      |
|     the       |                                                      |
|     answer    |                                                      |
|     sheet by  |                                                      |
|     the       |                                                      |
|     violation |                                                      |
|     to which  |                                                      |
|     it        |                                                      |
|     applies.  |                                                      |
|               |                                                      |
| ![](media/ima |                                                      |
| ge37.wmf){wid |                                                      |
| th="0.3201388 |                                                      |
| 8888888886in" |                                                      |
| height        |                                                      |
| ="0.31875in"} |                                                      |
| You have 20   |                                                      |
| minutes to    |                                                      |
| complete this |                                                      |
| assignment.   |                                                      |
+---------------+------------------------------------------------------+
|               |                                                      |
+---------------+------------------------------------------------------+
| After six     |                                                      |
| months in his |                                                      |
| new job as a  |                                                      |
| member of the |                                                      |
| Federal       |                                                      |
| Emergency     |                                                      |
| Management    |                                                      |
| Agency's      |                                                      |
| (FEMA) FCO    |                                                      |
| Cadre, Dewey  |                                                      |
| has finally   |                                                      |
| gotten the    |                                                      |
| hang of his   |                                                      |
| position. Now |                                                      |
| he can relax  |                                                      |
| and enjoy the |                                                      |
| benefits of   |                                                      |
| his           |                                                      |
| appointment.  |                                                      |
|               |                                                      |
| On Monday,    |                                                      |
| August 16,    |                                                      |
| 1999, Dewey   |                                                      |
| decided to    |                                                      |
| sleep in and  |                                                      |
| avoid the     |                                                      |
| traffic and a |                                                      |
| meeting       |                                                      |
| scheduled     |                                                      |
| with the      |                                                      |
| Inspector     |                                                      |
| General.      |                                                      |
| After a       |                                                      |
| leisurely     |                                                      |
| breakfast,    |                                                      |
| Dewey jumped  |                                                      |
| in his FEMA   |                                                      |
| car and       |                                                      |
| headed for    |                                                      |
| work. On the  |                                                      |
| way to the    |                                                      |
| office, he    |                                                      |
| used the      |                                                      |
| car\'s        |                                                      |
| cellular      |                                                      |
| phone to make |                                                      |
| a long        |                                                      |
| distance call |                                                      |
| to his mother |                                                      |
| in Fairbanks, |                                                      |
| Alaska.       |                                                      |
| Although his  |                                                      |
| mother was    |                                                      |
| not in, Dewey |                                                      |
| did talk with |                                                      |
| his brother,  |                                                      |
| Howey, who    |                                                      |
| was running   |                                                      |
| for the U.S.  |                                                      |
| Senate in the |                                                      |
| state of      |                                                      |
| Columbia.     |                                                      |
| Howey and     |                                                      |
| Dewey talked  |                                                      |
| about         |                                                      |
| campaign      |                                                      |
| strategy and  |                                                      |
| Dewey agreed  |                                                      |
| to hold a     |                                                      |
| fundraiser    |                                                      |
| for his       |                                                      |
| brother at    |                                                      |
| the FEMA      |                                                      |
| Headquarters. |                                                      |
| In assuring   |                                                      |
| his brother,  |                                                      |
| Dewey         |                                                      |
| proclaimed,   |                                                      |
| \"I am        |                                                      |
| certain that  |                                                      |
| I can get     |                                                      |
| everyone in   |                                                      |
| my office to  |                                                      |
| contribute to |                                                      |
| your          |                                                      |
| campaign!\"   |                                                      |
|               |                                                      |
| After         |                                                      |
| finishing his |                                                      |
| call to       |                                                      |
| Howey, Dewey  |                                                      |
| called his    |                                                      |
| broker, R.U.  |                                                      |
| Sneakie, to   |                                                      |
| talk about    |                                                      |
| his stock     |                                                      |
| trade.        |                                                      |
| Through his   |                                                      |
| service on    |                                                      |
| the Disaster  |                                                      |
| Review Board  |                                                      |
| (DRB), Dewey  |                                                      |
| was           |                                                      |
| fortunate, to |                                                      |
| learn that    |                                                      |
| FEMA was      |                                                      |
| about to      |                                                      |
| award its     |                                                      |
| largest ADP   |                                                      |
| contract ever |                                                      |
| to Harass     |                                                      |
| Business      |                                                      |
| Machine       |                                                      |
| (HBM). HBM    |                                                      |
| had been      |                                                      |
| struggling    |                                                      |
| for years,    |                                                      |
| and this      |                                                      |
| contract      |                                                      |
| award could   |                                                      |
| turn the      |                                                      |
| company       |                                                      |
| around. Dewey |                                                      |
| wanted to be  |                                                      |
| sure to get   |                                                      |
| on the ground |                                                      |
| floor, so he  |                                                      |
| told his      |                                                      |
| broker to buy |                                                      |
| 1,000 shares  |                                                      |
| at \$10.00    |                                                      |
| per share.    |                                                      |
| R.U. knew     |                                                      |
| Dewey too     |                                                      |
| well and      |                                                      |
| insisted on   |                                                      |
| payment       |                                                      |
| before        |                                                      |
| purchasing    |                                                      |
| the stock.    |                                                      |
| With all      |                                                      |
| credit        |                                                      |
| exhausted and |                                                      |
| in arrears,   |                                                      |
| Dewey gave R. |                                                      |
| U. his U.S.   |                                                      |
| Government    |                                                      |
| VISA card     |                                                      |
| number to     |                                                      |
| purchase the  |                                                      |
| stock. Dewey  |                                                      |
| remained      |                                                      |
| confident     |                                                      |
| that the      |                                                      |
| stock would   |                                                      |
| rise because  |                                                      |
| of this new   |                                                      |
| contract, and |                                                      |
| he would pay  |                                                      |
| VISA when the |                                                      |
| bill arrived, |                                                      |
| or the next   |                                                      |
| month, or     |                                                      |
| certainly the |                                                      |
| month         |                                                      |
| thereafter.   |                                                      |
+---------------+------------------------------------------------------+
| Finishing his |                                                      |
| personal      |                                                      |
| calls, Dewey  |                                                      |
| stopped at    |                                                      |
| Howey\'s      |                                                      |
| campaign      |                                                      |
| headquarters  |                                                      |
| to pick up    |                                                      |
| some campaign |                                                      |
| posters,      |                                                      |
| buttons,      |                                                      |
| pledge cards  |                                                      |
| and bumper    |                                                      |
| stickers to   |                                                      |
| distribute at |                                                      |
| work. Since   |                                                      |
| the campaign  |                                                      |
| headquarters  |                                                      |
| was in front  |                                                      |
| of "No        |                                                      |
| Standing      |                                                      |
| Area\", Dewey |                                                      |
| placed his    |                                                      |
| FEMA          |                                                      |
| [Emergency    |                                                      |
| Vehicle       |                                                      |
| ]{.underline} |                                                      |
| sign on the   |                                                      |
| dash and      |                                                      |
| rushed into   |                                                      |
| the office to |                                                      |
| gather the    |                                                      |
| supplies.     |                                                      |
| Upon his      |                                                      |
| return, Dewey |                                                      |
| could not     |                                                      |
| resist the    |                                                      |
| temptation to |                                                      |
| place a       |                                                      |
| "Howey        |                                                      |
| Cheetham for  |                                                      |
| Senate\"      |                                                      |
| bumper        |                                                      |
| sticker on    |                                                      |
| the car       |                                                      |
| before he     |                                                      |
| drove away.   |                                                      |
+---------------+------------------------------------------------------+
| He arrived at |                                                      |
| his office at |                                                      |
| 10:30 am and  |                                                      |
| was           |                                                      |
| confronted by |                                                      |
| his           |                                                      |
| secretary,    |                                                      |
| Frankly       |                                                      |
| Dutiful, who  |                                                      |
| asked him how |                                                      |
| he wanted his |                                                      |
| leave slip    |                                                      |
| completed.    |                                                      |
| Annoyed at    |                                                      |
| the question, |                                                      |
| Dewey ignored |                                                      |
| Ms. Dutiful   |                                                      |
| and asked her |                                                      |
| about his     |                                                      |
| tuxedo. She   |                                                      |
| explained     |                                                      |
| that it was   |                                                      |
| still at the  |                                                      |
| dry cleaner,  |                                                      |
| "But I plan   |                                                      |
| to pick it up |                                                      |
| when I drive  |                                                      |
| your kids to  |                                                      |
| soccer        |                                                      |
| lessons.\"    |                                                      |
| Dewey         |                                                      |
| responded,    |                                                      |
| \"Just make   |                                                      |
| sure you      |                                                      |
| don\'t        |                                                      |
| wrinkle the   |                                                      |
| tux, and      |                                                      |
| don\'t let    |                                                      |
| the kids eat  |                                                      |
| ice cream in  |                                                      |
| the van. The  |                                                      |
| staff will    |                                                      |
| need it clean |                                                      |
| when they     |                                                      |
| travel to     |                                                      |
| Baltimore for |                                                      |
| the softball  |                                                      |
| finals.\"     |                                                      |
+---------------+------------------------------------------------------+
| Dewey went    |                                                      |
| into his      |                                                      |
| office and    |                                                      |
| started to    |                                                      |
| open his      |                                                      |
| mail. The     |                                                      |
| first letter  |                                                      |
| was from      |                                                      |
| Harass        |                                                      |
| Business      |                                                      |
| Machine (HBM) |                                                      |
| and read:     |                                                      |
|               |                                                      |
| Dear Dewey:   |                                                      |
|               |                                                      |
| Thank you for |                                                      |
| [all          |                                                      |
| ]{.underline} |                                                      |
| your help     |                                                      |
| with the most |                                                      |
| recent FEMA   |                                                      |
| ADP contract. |                                                      |
| Although we   |                                                      |
| believe we    |                                                      |
| offer the     |                                                      |
| best product, |                                                      |
| we also       |                                                      |
| believe that  |                                                      |
| we couldn\'t  |                                                      |
| do it without |                                                      |
| your help and |                                                      |
| support. All  |                                                      |
| of us here at |                                                      |
| HBM are       |                                                      |
| looking       |                                                      |
| forward to    |                                                      |
| you joining   |                                                      |
| us at the end |                                                      |
| of your       |                                                      |
| tenure at     |                                                      |
| FEMA. In      |                                                      |
| gratitude for |                                                      |
| the work you  |                                                      |
| have already  |                                                      |
| done for HBM, |                                                      |
| enclosed are  |                                                      |
| two Super     |                                                      |
| Bowl tickets  |                                                      |
| for you and   |                                                      |
| your wife.    |                                                      |
| Your airline  |                                                      |
| tickets for   |                                                      |
| the game can  |                                                      |
| be picked up  |                                                      |
| at the        |                                                      |
| airport on    |                                                      |
| your way out  |                                                      |
| of town. We   |                                                      |
| look forward  |                                                      |
| to seeing you |                                                      |
| there.        |                                                      |
|               |                                                      |
| Again, thank  |                                                      |
| you for all   |                                                      |
| your good     |                                                      |
| work.         |                                                      |
|               |                                                      |
| Best Regards, |                                                      |
|               |                                                      |
| Will Billu    |                                                      |
|               |                                                      |
| Vice          |                                                      |
| President for |                                                      |
| Business      |                                                      |
| Development   |                                                      |
|               |                                                      |
| Harass        |                                                      |
| Business      |                                                      |
| Machine       |                                                      |
|               |                                                      |
| P.S. I hear   |                                                      |
| that there is |                                                      |
| a new ADP     |                                                      |
| procurement   |                                                      |
| planned for   |                                                      |
| the U.S. Fire |                                                      |
| Ad            |                                                      |
| ministration. |                                                      |
| It would be   |                                                      |
| nice to know  |                                                      |
| what the      |                                                      |
| Agency\'s     |                                                      |
| plans are and |                                                      |
| what the      |                                                      |
| competition   |                                                      |
| is up to.     |                                                      |
| Let\'s        |                                                      |
| discuss.      |                                                      |
|               |                                                      |
| Dewey         |                                                      |
| pocketed the  |                                                      |
| tickets and   |                                                      |
| made a note   |                                                      |
| to follow up. |                                                      |
+---------------+------------------------------------------------------+
| Next Dewey    |                                                      |
| completed a   |                                                      |
| letter of     |                                                      |
| r             |                                                      |
| ecommendation |                                                      |
| to the        |                                                      |
| Columbia      |                                                      |
| Emergency     |                                                      |
| Management    |                                                      |
| Agency (CEMA) |                                                      |
| urging it to  |                                                      |
| hire his old  |                                                      |
| business      |                                                      |
| partner,      |                                                      |
| Needa Job.    |                                                      |
| Dewey wrote,  |                                                      |
| \"I have      |                                                      |
| known Needa a |                                                      |
| long time.    |                                                      |
| She would     |                                                      |
| work well in  |                                                      |
| your          |                                                      |
| organization. |                                                      |
| Please see    |                                                      |
| what you can  |                                                      |
| do.\" The     |                                                      |
| letter was    |                                                      |
| signed, Dewey |                                                      |
| Cheetham FEMA |                                                      |
| Federal       |                                                      |
| Coordinating  |                                                      |
| Officer.      |                                                      |
|               |                                                      |
| Finally,      |                                                      |
| Dewey         |                                                      |
| reviewed a    |                                                      |
| request from  |                                                      |
| Emergency     |                                                      |
| Enterprises,  |                                                      |
| Inc. for      |                                                      |
| endorsement   |                                                      |
| of their new  |                                                      |
| at-home       |                                                      |
| emergency     |                                                      |
| management    |                                                      |
| kit. They ask |                                                      |
| for his       |                                                      |
| support       |                                                      |
| arguing,      |                                                      |
| \"that with   |                                                      |
| your public   |                                                      |
| endorsement   |                                                      |
| we can be     |                                                      |
| certain that  |                                                      |
| our product   |                                                      |
| will be the   |                                                      |
| one that all  |                                                      |
| families      |                                                      |
| would turn to |                                                      |
| when          |                                                      |
| preparing for |                                                      |
| disasters and |                                                      |
| emergencies.  |                                                      |
| Dewey         |                                                      |
| [liked        |                                                      |
| ]{.underline} |                                                      |
| the idea and  |                                                      |
| told Ms.      |                                                      |
| Dutiful to    |                                                      |
| write a       |                                                      |
| letter        |                                                      |
| stating that  |                                                      |
| he would be   |                                                      |
| pleased to    |                                                      |
| endorse their |                                                      |
| commercial    |                                                      |
| product.      |                                                      |
+---------------+------------------------------------------------------+
| It is         |                                                      |
| lunchtime and |                                                      |
| Dewey called  |                                                      |
| Chester to    |                                                      |
| get the town  |                                                      |
| car. On his   |                                                      |
| way out, he   |                                                      |
| saw the       |                                                      |
| Inspector     |                                                      |
| General in    |                                                      |
| the waiting   |                                                      |
| room, but     |                                                      |
| moved on.     |                                                      |
| Chester drove |                                                      |
| Dewey to Café |                                                      |
| C             |                                                      |
| atastrophique |                                                      |
| for lunch     |                                                      |
| with Dewey\'s |                                                      |
| new business  |                                                      |
| partner.      |                                                      |
|               |                                                      |
| At the Café,  |                                                      |
| Dewey met     |                                                      |
| Ollie Milkya. |                                                      |
| However, the  |                                                      |
| reservation   |                                                      |
| was lost.     |                                                      |
| Nonplused,    |                                                      |
| Ollie flipped |                                                      |
| out his FEMA  |                                                      |
| badge and     |                                                      |
| demanded a    |                                                      |
| table         |                                                      |
| immediately.  |                                                      |
| The maitre    |                                                      |
| d\' responded |                                                      |
| accordingly.  |                                                      |
| At the        |                                                      |
| luncheon,     |                                                      |
| Ollie and     |                                                      |
| Dewey         |                                                      |
| discussed an  |                                                      |
| idea for      |                                                      |
| establishing  |                                                      |
| consulting    |                                                      |
| services      |                                                      |
| where states  |                                                      |
| could use     |                                                      |
| their service |                                                      |
| to obtain     |                                                      |
| maximum       |                                                      |
| benefits for  |                                                      |
| PW\'s. Dewey  |                                                      |
| liked the     |                                                      |
| idea because  |                                                      |
| he would be   |                                                      |
| able to       |                                                      |
| continue this |                                                      |
| work, even    |                                                      |
| [after        |                                                      |
| ]{.underline} |                                                      |
| he finished   |                                                      |
| at FEMA. They |                                                      |
| agreed on an  |                                                      |
| arrangement   |                                                      |
| where Ollie   |                                                      |
| would serve   |                                                      |
| as the front  |                                                      |
| for the       |                                                      |
| consulting    |                                                      |
| service and   |                                                      |
| Dewey would   |                                                      |
| provide his   |                                                      |
| legal         |                                                      |
| expertise and |                                                      |
| contacts in   |                                                      |
| the           |                                                      |
| background.   |                                                      |
| They made a   |                                                      |
| pact that no  |                                                      |
| one was to    |                                                      |
| know about    |                                                      |
| this          |                                                      |
| arrangement - |                                                      |
| at least      |                                                      |
| until Dewey   |                                                      |
| left his job  |                                                      |
| as FEMA's     |                                                      |
| Deputy        |                                                      |
| General       |                                                      |
| Counsel. That |                                                      |
| may be sooner |                                                      |
| than Dewey    |                                                      |
| thinks. Just  |                                                      |
| then his      |                                                      |
| pager went    |                                                      |
| off. It read: |                                                      |
|               |                                                      |
| Urgent.       |                                                      |
| Please return |                                                      |
| to office.    |                                                      |
| IG, DEAO,     |                                                      |
| OGE, Special  |                                                      |
| Counsel and   |                                                      |
| GAO           |                                                      |
| Investigators |                                                      |
| are waiting.  |                                                      |
+---------------+------------------------------------------------------+

###### 

+-----------------------------------+-----------------------------------+
| ##### **Action/Violation**        | ##### **Principle Violated**      |
+===================================+===================================+
| 1.  Now he can relax and enjoy    | Principle 7 -- Shall not use      |
|     the benefits of his           | public office for private gain.   |
|     appointment.                  |                                   |
+-----------------------------------+-----------------------------------+
| 2.  On Monday, August 16, 1999,   | Principle 9 -- Shall protect and  |
|     Dewey decided to sleep in and | conserve Federal property and     |
|     avoid the traffic and a       | shall not use it for other than   |
|     meeting scheduled with the    | authorized activities.            |
|     Inspector General. After a    |                                   |
|     leisurely breakfast, Dewey    |                                   |
|     jumped in his FEMA car and    |                                   |
|     headed for work.              |                                   |
+-----------------------------------+-----------------------------------+
| 3.  On the way to the office, he  | Principle 9 -- Shall protect and  |
|     used the car\'s cellular      | conserve Federal property and     |
|     phone to make a long distance | shall not use it for other than   |
|     call to his mother in         | authorized activities.            |
|     Fairbanks, Alaska.            |                                   |
+-----------------------------------+-----------------------------------+
| 4.  Howey and Dewey talked about  | Principle 9 -- Shall protect and  |
|     campaign strategy and Dewey   | conserve Federal property and     |
|     agreed to hold a fundraiser   | shall not use it for other than   |
|     for his brother at the FEMA   | authorized activities.            |
|     Headquarters.                 |                                   |
+-----------------------------------+-----------------------------------+
| 5.  In assuring his brother,      | Principle 4 -- Shall not solicit  |
|     Dewey proclaimed, \"I am      | any item of monetary value from   |
|     certain that I can get        | anyone whose interests may be     |
|     everyone in my office to      | affected by the performance or    |
|     contribute to your            | non-performance to the employee's |
|     campaign!\"                   | duties.                           |
|                                   |                                   |
|                                   | Principle 9 -- Shall protect and  |
|                                   | conserve Federal property and     |
|                                   | shall not use it for other than   |
|                                   | authorized activities.            |
+-----------------------------------+-----------------------------------+
| 6.  After finishing his call to   | Principle 9 -- Shall protect and  |
|     Howey, Dewey called his       | conserve Federal property and     |
|     broker, R.U. Sneakie, to talk | shall not use it for other than   |
|     about his stock trade.        | authorized activities.            |
+-----------------------------------+-----------------------------------+
| 7.  Through his service on the    | Principle 8 -- Shall act          |
|     Disaster Review Board (DRB),  | impartially and not give          |
|     Dewey was fortunate, to learn | preferential treatment to any     |
|     that FEMA was about to award  | private organization or           |
|     its largest ADP contract ever | individual.                       |
|     to Harass Business Machine    |                                   |
|     (HBM).                        |                                   |
+-----------------------------------+-----------------------------------+
| 8.  Dewey wanted to be sure to    | Principle 3 -- Shall not engage   |
|     get on the ground floor       | in financial transactions using   |
|                                   | nonpublic Government information. |
+-----------------------------------+-----------------------------------+
| 9.  so he told his broker to buy  | Principle 3 -- Shall not engage   |
|     1,000 shares at \$10.00 per   | in financial transactions using   |
|     share.                        | nonpublic Government information. |
+-----------------------------------+-----------------------------------+
| 10. Dewey gave R. U. his U.S.     | Principle 12 -- Shall satisfy in  |
|     Government VISA card number   | good faith their obligations as   |
|     to purchase the stock. Dewey  | citizens, including all financial |
|     remained confident that the   | obligations.                      |
|     stock would rise because of   |                                   |
|     this new contract, and he     |                                   |
|     would pay VISA when the bill  |                                   |
|     arrived, or the next month,   |                                   |
|     or certainly the month        |                                   |
|     thereafter.                   |                                   |
+-----------------------------------+-----------------------------------+
| 11. Dewey stopped at Howey\'s     | Principle 9 -- Shall protect and  |
|     campaign headquarters to pick | conserve Federal property and     |
|     up some campaign posters,     | shall not use it for other than   |
|     buttons, pledge cards and     | authorized activities.            |
|     bumper stickers to distribute |                                   |
|     at work.                      |                                   |
+-----------------------------------+-----------------------------------+
| 12. Dewey placed his FEMA         | Principle 14 -- Shall endeavor to |
|     [Emergency                    | avoid actions creating the        |
|     Vehicle]{.underline} sign on  | appearance that they are          |
|     the dash and rushed into the  | violating the law or ethical      |
|     office to gather the          | standards.                        |
|     supplies.                     |                                   |
|                                   | Principle 9 -- Shall protect and  |
|                                   | conserve Federal property and     |
|                                   | shall not use it for other than   |
|                                   | authorized activities.            |
+-----------------------------------+-----------------------------------+
| 13. ...place a "Howey Cheetham    | Principle 9 -- Shall protect and  |
|     for Senate\" bumper sticker   | conserve Federal property and     |
|     on the car before he drove    | shall not use it for other than   |
|     away.                         | authorized activities.            |
+-----------------------------------+-----------------------------------+
| 14. He arrived at his office at   | Principle 11 -- Shall disclose    |
|     10:30 am and was confronted   | waste, fraud, and abuse.          |
|     by his secretary, Frankly     |                                   |
|     Dutiful, who asked him how he |                                   |
|     wanted his leave slip         |                                   |
|     completed.                    |                                   |
+-----------------------------------+-----------------------------------+
| 15. Dewey ignored Ms. Dutiful and | Principle 5 -- Shall put forth    |
|     asked her about his tuxedo.   | honest effort in the performance  |
|                                   | of their duties.                  |
+-----------------------------------+-----------------------------------+
| 16. still at the dry cleaner,     | Principle 4 -- Shall not solicit  |
|     "But I plan to pick it up     | any item of monetary value from   |
|     when I drive your kids to     | anyone whose interests may be     |
|     soccer lessons.\"             | affected by the performance or    |
|                                   | non-performance to the employee's |
|                                   | duties                            |
+-----------------------------------+-----------------------------------+
| 17. don\'t let the kids eat ice   | Principle 9 -- Shall protect and  |
|     cream in the van. The staff   | conserve Federal property and     |
|     will need it clean when they  | shall not use it for other than   |
|     travel to Baltimore for the   | authorized activities.            |
|     softball finals.\"            |                                   |
+-----------------------------------+-----------------------------------+
| 18. Dewey pocketed the tickets    | Principle 4 -- Shall not solicit  |
|     and made a note to follow up. | or accept any item of monetary    |
|                                   | value from anyone whose interests |
|                                   | may be affected by the            |
|                                   | performance or non-performance to |
|                                   | the employee's duties.            |
+-----------------------------------+-----------------------------------+
| 19. Next Dewey completed a letter | Principle 13 -- Shall adhere to   |
|     of recommendation to the      | all laws and regulations that     |
|     Columbia Emergency Management | provide equal opportunity.        |
|     Agency (CEMA) urging it to    |                                   |
|     hire his old business         | Principle 8 -- Shall not give     |
|     partner, Needa Job.           | preferential treatment to any     |
|                                   | individual.                       |
+-----------------------------------+-----------------------------------+
| 20. Please see what you can do.\" | Principle 6 -- Shall make no      |
|     The letter was signed, Dewey  | unauthorized commitments or       |
|     Cheetham FEMA Federal         | promises of any kind purporting   |
|     Coordinating Officer.         | to bind the government.           |
+-----------------------------------+-----------------------------------+
| 21. told Ms. Dutiful to write a   | Principle 6 -- Shall make no      |
|     letter stating that he would  | unauthorized commitments or       |
|     be pleased to endorse their   | promises of any kind purporting   |
|     commercial product.           | to bind the government.           |
+-----------------------------------+-----------------------------------+
| 22. It is lunchtime and Dewey     | Principle 9 -- Shall protect and  |
|     called Chester to get the     | conserve Federal property and     |
|     town car. On his way out, he  | shall not use it for other than   |
|     saw the Inspector General in  | authorized activities.            |
|     the waiting room, but moved   |                                   |
|     on. Chester drove Dewey to    |                                   |
|     Café Catastrophique for lunch |                                   |
|     with Dewey\'s new business    |                                   |
|     partner.                      |                                   |
+-----------------------------------+-----------------------------------+
| 23. flipped out his FEMA badge    | Principle 7 -- Shall not use      |
|     and demanded a table          | public office for private gain.   |
|     immediately.                  |                                   |
+-----------------------------------+-----------------------------------+
| 24. discussed an idea for         | Principle 2 -- Shall not hold     |
|     establishing consulting       | financial interests that conflict |
|     services where states could   | with the conscientious            |
|     use their service to obtain   | performance of duty.              |
|     maximum benefits for PW\'s.   |                                   |
|     Dewey liked the idea because  | Principle 3 -- Shall not engage   |
|     he would be able to continue  | in financial transactions using   |
|     this work, even               | nonpublic Government information. |
|     [after]{.underline} he        |                                   |
|     finished at FEMA.             |                                   |
+-----------------------------------+-----------------------------------+
| 25. Ollie would serve as the      | Principle 10 -- Shall not engage  |
|     front for the consulting      | in outside employment or          |
|     service and Dewey would       | activities, including seeking or  |
|     provide his legal expertise   | negotiating for employment, that  |
|     and contacts in the           | conflicts with official           |
|     background.                   | Government duties.                |
+-----------------------------------+-----------------------------------+

**DEWEY THE FCO ANSWER SHEET**

+-----------------------------------+-----------------------------------+
| ##### **Action/Violation**        | ##### **Principle Violated**      |
+-----------------------------------+-----------------------------------+
| 1.                                |                                   |
+-----------------------------------+-----------------------------------+
| 2.                                |                                   |
+-----------------------------------+-----------------------------------+
| 3.                                |                                   |
+-----------------------------------+-----------------------------------+
| 4.                                |                                   |
+-----------------------------------+-----------------------------------+
| 5.                                |                                   |
+-----------------------------------+-----------------------------------+
| 6.                                |                                   |
+-----------------------------------+-----------------------------------+
| 7.                                |                                   |
+-----------------------------------+-----------------------------------+
| 8.                                |                                   |
+-----------------------------------+-----------------------------------+
| 9.                                |                                   |
+-----------------------------------+-----------------------------------+
| 10.                               |                                   |
+-----------------------------------+-----------------------------------+
| 11.                               |                                   |
+-----------------------------------+-----------------------------------+
| 12.                               |                                   |
+-----------------------------------+-----------------------------------+
| 13.                               |                                   |
+-----------------------------------+-----------------------------------+
| 14.                               |                                   |
+-----------------------------------+-----------------------------------+
| 15.                               |                                   |
+-----------------------------------+-----------------------------------+
| 16.                               |                                   |
+-----------------------------------+-----------------------------------+
| 17.                               |                                   |
+-----------------------------------+-----------------------------------+
| 18.                               |                                   |
+-----------------------------------+-----------------------------------+
| 19.                               |                                   |
+-----------------------------------+-----------------------------------+
| 20.                               |                                   |
+-----------------------------------+-----------------------------------+
| 21.                               |                                   |
+-----------------------------------+-----------------------------------+
| 22.                               |                                   |
+-----------------------------------+-----------------------------------+
| 23.                               |                                   |
+-----------------------------------+-----------------------------------+
| 24.                               |                                   |
+-----------------------------------+-----------------------------------+
| 25.                               |                                   |
+-----------------------------------+-----------------------------------+
| 26.                               |                                   |
+-----------------------------------+-----------------------------------+
| 27.                               |                                   |
+-----------------------------------+-----------------------------------+
| 28.                               |                                   |
+-----------------------------------+-----------------------------------+
| 29.                               |                                   |
+-----------------------------------+-----------------------------------+
| 30.                               |                                   |
+-----------------------------------+-----------------------------------+