Defense Logistics Agency 

Employees’ Guide to the 

Standards of Conduct 

DLA General Counsel 

8725 John J. Kingman Rd. 

Fort Belvoir, VA 22060 

(571) 767-6060
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Table of Contents 

Page

Whom to Call for Advice ................................................................................ ii

General Principles of Public Service ................................................................ 1

Gifts ................................................................................................................ 2

Gifts From Outside Sources ................................................................... 2 

 What’s a Prohibited Source? ......................................................... 2

 What’s a Gift?............................................................................... 2

 What’s Not a Gift? ........................................................................ 3

 Gifts That You May Keep ............................................................. 3

 Disposition of Improper Gifts ........................................................ 5

Gifts Between Employees...................................................................... 5

Conflicts of Interest ......................................................................................... 6

Conflicting Financial Interests ............................................................... 6

Bribery and Graft .................................................................................. 6

Commercial Dealings Between DLA Employees ................................... 7 

Representation of Others in Matters Affecting Government ................... 7

Supplementation of Federal Salary ........................................................ 7

Impartiality in Performing Official Duties ........................................................ 8

Misuse of Position ........................................................................................... 8

Use of Government Resources...................................................... 9

Fundraising...................................................................................................... 9

Teaching, Speaking, and Writing ..................................................................... 9 

Outside Activities...................................................................... 10

Political Activities ........................................................................................... 10

Employment Issues............................................................................................11

Official Travel Benefits ................................................................................... 12

Sources of Further Information ........................................................................ 13
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Whom to Call for Advice

The DLA General Counsel is the Designated Agency Ethics Official (DAEO) for 

DLA employees, both civilian and military.

Please direct your ethics and standards of conduct questions to:

DLA General Counsel Telephone

8725 John J. Kingman Rd. (571) 767-6089/6060

Fort Belvoir, VA 22060

email: claes.lewenhaupt@dla.mil

DLA General Counsel- Europe and Africa DSN (324) 206-9759

DLA General Counsel- Indo/Pacific (808) 786-2395/2257

DLA Counsel- Aviation (804) 279-1422/2778

DLA Counsel- Disposition Services (269) 961-7326/5694

DLA Counsel- Distribution (717) 770-4260/5238

DLA Counsel- Document Services (717) 770-8585

DLA Counsel- Energy (571) 767-5003/5020

DLA Counsel- Land and Maritime (614) 692-1915/3284

DLA Counsel- Troop Support (215) 737-5182/2630

IMPORTANT ADVICE

If you’re not positive that what you’re about to do is appropriate, ask your

ethics official. Contact one of the offices listed above and ask for an ethics 

official. One mission of the DLA Office of the General Counsel is to advise DLA 

personnel and assist them to accomplish their goals without violating the standards 

of conduct. 

This Handbook provides a general summary of the rules. It does not include 

every exception, every requirement, or all the factors that must be considered in 

making certain decisions. If you are unsure of your actions, call your ethics 

official before you act.
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GENERAL PRINCIPLES OF 

PUBLIC SERVICE

Do’s

Place loyalty to the Constitution, the 

laws, and ethical principles above 

private gain

Act impartially to all groups, persons, 

and organizations

Give an honest effort in the 

performance of your duties

Protect and conserve Federal 

property

Disclose waste, fraud, abuse, 

and corruption to appropriate 

authorities

Fulfill in good faith your obligations 

as a citizen, and pay your Federal, 

State, and local taxes

Comply with all laws providing equal 

opportunity to all persons, regardless 

of their race, color, religion, sex, 

national origin, age, or handicap

Don’ts

Don’t use nonpublic information to 

benefit yourself or anyone else

Don’t solicit or accept gifts from 

persons or parties that do business 

with or seek official action from DoD

(unless permitted by an exception)

Don’t make unauthorized 

commitments or promises that bind 

the Government

Don’t use Federal property for 

unauthorized purposes

Don’t take jobs or hold financial 

interests that conflict with your 

Government responsibilities

Don’t take actions that give the 

appearance that they are illegal or 

unethical

Remember: Violating ethics principles may result in disciplinary or

corrective action, including criminal prosecution. Protect yourself from 

disciplinary action by seeking the advice of your agency ethics official.
2

GIFTS

Gifts From Outside Sources 

Rule: You may not accept a gift given: 

Because of your official position, or 

By a prohibited source

Regardless of any exceptions that allow accepting gifts, it is 

always impermissible to: 

Accept a gift in return for being influenced in the 

performance of an official act. This is a bribe! 

Solicit or coerce the offering of a gift 

Accept gifts from the same or different sources so 

frequently that a reasonable person would think 

you’re using your office for private gain 

Accept a gift in violation of a statute 

What’s a Prohibited Source?

A prohibited source is any person who is, or any organization 

a majority of whose members are: 

 

Seeking official action by DLA

Doing or seeking to do business with DLA

Regulated by DLA, or 

Substantially affected by the performance of your

official duties 

What’s a Gift?

Anything of monetary value. 

Patty, a DLA employee, 

meets informally every 

week with representatives 

of defense contractors, 

who customarily treat her 

to a small breakfast. 

Although an exception 

might permit acceptance 

of these small breakfasts, 

Patty’s recurring practice 

of accepting them is 

improper.

Joe, a Computer.Com 

representative, is seeking to 

do business with DLA. He 

invites DLA Acquisition 

employees to a golf 

tournament, which his 

company will pay for. The 

DLA employees cannot 

accept the gift of free golf 

greens fees unless an 

exception to the gift rule 

applies, because 

Computer.Com, by seeking 

to do business with DLA, is 

a prohibited source. 
3

What’s Not a Gift?

Here are examples of items that are not defined as “gifts”:

Modest items of food and refreshments (like coffee and 

donuts) when not served as a meal 

Prizes in contests open to the public 

Greeting cards and items with little intrinsic value, such 

as plaques, certificates, and trophies, intended only for 

presentation 

Commercial discounts available to the public or to all 

Government civilian or military personnel 

Anything the Government acquires by contract or 

otherwise legally accepts 

Anything for which you pay market value

Gifts That You May Keep 

Remember, you don’t have to accept a gift. It may be smart, 

depending on the circumstances, to decline a gift, even when it 

is allowed by the exceptions below. 

Gifts valued at $20 or less, but

not cash or investment interests 

not more than $50 in total from one source in a year 

Gifts motivated by personal relationships 

Certain discounts and similar benefits offered 

by professional organizations 

to groups unrelated to Government employment (such 

as AARP) 

to groups in which membership is related to 

Government employment, if the same benefits are 

available to other, similar organizations. (e.g.: 

discounted loans to Gov’t. credit union members.)

by a non-prohibited source to any group as long as not 

discriminatory on basis of rank, type of responsibility, 

or pay. 

Gifts resulting from your or your spouse’s outside business 

activities

You may accept cups of coffee 

offered by a contractor at no charge.

If you enter your business card in a 

drawing sponsored by a DLA

contractor that is open to the public, 

you may keep the prize.

On each of his quarterly visits, a 

sales representative of Overpriced 

Computers Inc. gave Bonnie, a DLA

employee, a company T-shirt, valued 

at $10 each. During that period, 

Bonnie’s brother Steve, who also 

works for Overpriced Computers 

Inc., purchased for her a birthday 

present valued at $60. Bonnie may 

keep all of the gifts given to her. The 

T-shirts don’t exceed the $50 annual

limit from one source, and the gift

from her brother Steve is the result

of a personal, not business,

relationship.

Tom was offered two tickets valued 

at $30 a piece to a baseball game 

from an employee of a defense 

contractor. Since the price of each 

ticket exceeds the $20 limit, Tom 

may only accept the tickets if he 

pays the contractor $60, the full 

market value of the tickets. (Paying 

only $40 is not permissible.)
4

Free attendance provided by a state, local government, or 

tax exempt civic organization when there is a community 

relations interest 

Gifts accepted under specific statutory authority, such as 

certain gifts from a foreign government 

Certain educational scholarships and grants (consult a 

DLA ethics official) 

Free attendance, food, and entertainment (not travel) when 

provided by a sponsor:

of an event on the day that you are speaking or 

presenting information, or

of a widely attended gathering, provided that your 

supervisor determines that your attendance is in the 

agency’s interest. (If the sponsor has interests that 

may be affected by you, an additional conflict of 

interest determination is required.) 

Free attendance, food, and entertainment (not travel) 

provided by a person other than the sponsor of a widely 

attended gathering, if: 

the market value of the gift of free attendance is $390

or less and more than 100 persons are expected to 

attend, and

your supervisor determines that your attendance is in 

the agency’s interest. (If the person has interests that 

may be affected by the employee, an additional conflict 

of interest determination is required.) 

Meals, lodging, transportation, and other benefits in 

connection with employment discussions 

Awards for meritorious public service or achievement, and 

honorary degrees – see your ethics counselor 

Travel benefits and free attendance from political 

organizations in connection with certain political activities 

• Food and entertainment (not travel and lodging), at social

events, if: (1) the invitation is not from a prohibited source,

and (2) the event is free to all attendees.

On account of his DLA position, an 

arms trade association invites Jared, 

a DLA senior manager, to an 

industry-wide, one-day seminar 

sponsored by the association, a $200 

value. He is also invited to dinner, 

which costs $100, at a restaurant 

after the seminar with several 

industry executives. Jared may 

accept the seminar invitation, 

provided that his supervisor 

determines that his attendance 

furthers DoD’s interests. Jared may 

not accept the free dinner invitation, 

which is not part of the seminar and 

is closed to other interested 

participants.

An annual dinner is held by a 

veterans’ service organization that 

costs $125 per person. 

Representatives from veterans’ 

groups, Congress, and the media will 

attend. Several DLA employees are 

given free tickets by Big Guns, Inc. 

At the dinner, a veteran will be 

honored. Since it is a widely 

attended gathering, the DLA

employee may be able to accept the 

free tickets if his or her ethics official 

determines more than 100 persons 

are expected to attend the event, and 

there is an agency interest in the 

DLA employee’s attendance.
5

Gifts of food and entertainment (not to exceed the per 

diem rate) at meetings or events attended in an official 

capacity in foreign areas, when (1) not provided by a 

foreign government and (2) non-U.S. citizens participate 

in the meeting or event 

Foreign Gifts 

Rule: Federal employees may accept gifts from foreign 

governments if the gift is below the “minimal value” which 

is currently $390. Check with your ethics counselor about

appraising the gift or what the current threshold is. 

Disposition of Improper Gifts 

Rule: If you are offered a gift that you cannot accept, you 

should: 

Decline the gift 

Return the gift, or

Pay the donor the gift’s market value

Subsequent reciprocity is not a solution

Gifts Between Employees 

Rule: You may not accept a gift from an employee who 

earns less than you (unless you have a personal relationship 

with the employee, and you are not in the chain of command) 

Rule: You may not give, make a donation toward, or solicit 

a gift for someone superior to you in the chain of command. 

Exceptions to the Rule

1. On an occasional basis, such as holidays or birthdays,

you may give to a superior or receive from a subordinate:

Non-monetary gifts of up to $10

Personal hospitality provided at a 

Bill asks his 4 coworkers each to pitch 

in $20 to purchase a $100 golf putter 

for Doreen, their boss, for Christmas. 

Doreen invites the office to a New 

Year’s party, serving meals valued at 

$25. Bill brings a $20 bottle of wine. 

Bill may not solicit, and he and his 

coworkers may not give, their boss 

a group gift or individual gifts at 

Christmas that exceed $10.

The dinner and the wine are

 both appropriate.

Under certain circumstances, 

perishable items may be:

donated to charity

destroyed

shared within the office

(check with your ethics official)
6

residence (or an appropriate host/hostess gift),

Food or refreshments shared in the office 

2. On special, infrequent occasions,

of personal significance, such as marriage, illness, or 

birth or adoption of a child 

that terminate the chain of command, such as 

retirement, resignation, or transfer you may 

solicit voluntary contributions up to $10/person for a 

group gift 

give an appropriate gift to a superior 

accept appropriate gifts and group gifts that do not 

exceed $300 from subordinates (See your ethics 

counselor for exceptions.) 

CONFLICTS OF INTEREST

Conflicting Financial Interests 

Criminal Rule: You may not do government work on a 

particular matter that will affect the financial interest of: 

You 

Your spouse 

Your minor children 

Your general partner 

Organizations with which you’re negotiating or have 

arrangements for future employment, or

Any organization for which you serve as an employee, 

officer, director, trustee, or general partner 

If you think you may have a conflicting financial interest, 

consult your DLA ethics official immediately to determine the 

appropriate remedy. 

Doreen decides to retire. Bill, who 

works for Doreen, gives her a $20 

book and again solicits for a goingaway gift. He would like to get her 

a golf-related desk set that costs 

about $50.

Bill may give the $20 book, as it 

is an appropriate gift

Bill may also solicit for a gift

 and contribute toward the

 group gift

Bill has learned his lesson 

 and does not suggest an 

 amount to contribute

Bryan, a DLA procurement officer, 

is about to award a contract for 

new computers. His wife, Deanna, 

owns a computer sales business, 

which has bid on the contract. 

Bryan may not participate in the 

contract award decision, since the 

decision will affect his wife’s 

financial interests.
7

Bribery and Graft 

Rule: You may not seek or accept anything of value, other 

than your salary, for being influenced in your official duties. 

Commercial Dealings Between DLA Employees 

Rule: You may not knowingly solicit or make solicited sales 

to personnel who are junior in rank, grade, or position (or their 

families). This includes insurance, stocks, real estate, 

cosmetics, household supplies, and other such goods and 

services. 

Representation of Others in Matters Affecting 

Government 

Rule: You generally may not represent anyone outside the 

Government before a Federal agency or court, or share in any 

compensation for such representations made by anybody else, 

if the Government is involved in the particular matter. 

• There are limited exceptions.

There are special exceptions for consultants.

Check with your ethics official.

Supplementation of Federal Salary 

Rule: You may not accept compensation from any source 

except the Government for your services as a Government 

employee. 

This rule does not apply, if: 

you are a “special Government employee” – i.e., a 

consultant, or 

you serve without compensation, or 

your supplementation is a result of a public service 

award 

Sue operates a cosmetics sales 

business out of her home after 

hours. During the day she is a 

supervisor at DLA. She may not 

make solicited sales to her DLA

subordinates or the job or after 

work by calling them at home.
8

IMPARTIALITY IN PERFORMING 

OFFICIAL DUTIES

Rule: Maintain your impartiality. Don’t participate in any 

particular DLA matter if: 

the matter is likely to affect the financial interest of 

a member of your household, or a person with 

whom you have a “covered relationship” is 

involved in the matter, and

a reasonable person with knowledge of the relevant 

facts could question your impartiality. 

Who may be in a “covered relationship”?

A member of your household or a relative with 

whom you’re close,

Someone with whom you have or seek to have a 

business relationship, other than a routine 

consumer transaction, 

An organization (other than a political party) in 

which you actively participate, 

Someone with whom you had, within the last year, 

a close business relationship, such as partnership or 

employment, or

Someone with whom your spouse, parent, or 

dependent child has (or seeks to have) a close 

business relationship, such as partnership or 

employment. 

MISUSE OF POSITION

Rule: You may not use, or permit the use of, your 

Government position, title, or any authority associated with 

your office: 

To induce or coerce another person to provide any 

benefit to you or anyone with whom you are 

affiliated

A senior VP from Blatz Corp. 

recently resigned from Blatz to 

become a senior official in DLA. 

Shortly after his arrival, the 

official’s office is tasked to decide 

whether or not to renew Blatz’s 

contract with DLA. Because the 

senior official was employed by 

Blatz within the last year, he may 

not make the decision 

The General Counsel has been 

asked by his college to serve on the 

Alumni Association. He may serve 

in his personal capacity, but may 

not allow his position as General 

Counsel to be used on the college 

letterhead or other promotional 

literature.
9

To imply that DLA, DoD, or the Government 

endorses personal activities 

To endorse any product, service, or enterprise, 

except as provided by statute or regulation 

USE OF GOVERNMENT RESOURCES

Rule: Use Federal Government equipment and property, 

including communications systems, only for official purposes 

or authorized purposes as approved by your supervisor. 

Rule: Use official time in an honest effort to perform official 

duties, and don’t ask subordinates to perform tasks outside 

their official duties. 

FUNDRAISING

Rule: You may raise funds for organizations in your personal 

capacity, but you may not use your official title, position, or 

authority to fundraise, nor may you solicit subordinates or 

prohibited sources. 

TEACHING, SPEAKING, AND 

WRITING

Rule: You may accept payment for teaching, speaking, or 

writing that is unrelated to your official duties and that was not 

prepared on official time. 

If your employment by DLA is identified, you must 

make a disclaimer. 

Oscar, who is the deputy director 

of a DLA office, is in charge of 

raising funds for his son’s Little 

League team. Oscar may not ask 

his subordinates to contribute. 

Stu, an ethics attorney at DLA, has 

been offered $1500 to teach a 1-day 

course on Federal ethics to 

employees at Big Contractor, Inc. 

Because the topic relates to his 

official duties, he may not accept 

the compensation. 
10

OUTSIDE ACTIVITIES

Rule: If you file a financial disclosure 

report, you need your supervisor’s prior 

written approval before you engage in 

business activity or employment with a 

DLA “prohibited source” (see page 2). 

Presidential appointees and certain noncareer employees have additional 

restrictions – consult your ethics 

counselor. 

Rule: You may not have outside employment or activities 

that would materially impair your ability to perform your 

duties. 

POLITICAL ACTIVITIES

Most Federal civilian employees may actively participate in political campaigns and other 

partisan activities. However, they may not engage in such activities on duty, or in any Federal 

workplace, vehicle, or while in uniform. Further, they may not use their official title, position or 

authority when engaging in partisan political activities.

While the Hatch Act loosened restrictions on political activity for most Federal civilian 

employees, Federal laws still limit the political activities of military personnel, law enforcement, 

national security, and career SES employees. Certain political appointees are subject to 

additional restrictions by DoD policy, i.e., they may not engage in any activity that could be

interpreted as associating DoD with any partisan cause or issue. 

If you plan to engage in any partisan political activity, you should consult your ethics counselor. 

Jill, who tests new 

computers for the office, 

wants to work on 

weekends for the vendor 

of those computers. Since 

her outside employment 

would cause a conflict of 

interest with her 

Government duties, she 

should not accept the job. 
11

EMPLOYMENT ISSUES

Seeking Employment 

Rule: If you are seeking non-Federal employment (e.g., sending 

resumes to select employers), you may not do Government work 

on a particular matter that will affect the financial interests of any 

of your prospective employers. You must give a written 

disqualification statement to your supervisor. 

Post-Government Employment 

Rule: Always consult your ethics counselor before separating from the Government. He or she 

will advise you on the restrictions that will apply to your activities in the private sector in light of 

your specific duties and level of responsibility as a Government employee. 

OFFICIAL TRAVEL BENEFITS

You may keep promotional items such as frequent flyer miles that are awarded for official 

travel. 

You may also keep promotional items given to compensate you for being voluntarily bumped 

from a flight. You may voluntarily surrender your seat ONLY if doing so does not adversely 

affect the performance of your official duties and does not result in additional cost to the 

Government. 

You may not keep promotional items given to compensate you for being involuntarily bumped 

from a flight.

Janelle, a procurement specialist, is 

doing work as a Government 

employee on a contract worth 

$500,000. She is offered an 

interview for a job by the 

contractor. Janelle must disqualify 

or recuse herself and inform her 

supervisor and ethics official. 
12

SOURCES OF FURTHER INFORMATION

If you have further questions, consult a DLA ethics counselor listed on page ii. 

 Additional information is available in: 

1. Standards of Conduct for Employees of the Executive Branch

The U.S. Office of Government Ethics has developed a comprehensive set of regulations to

assist Federal employees with their ethics questions. This is a primary source of guidance on

ethics and standards of conduct. It may be found on the Office of Government Ethics

website: www.usoge.gov.

2. DoD 5500.7-R, the Joint Ethics Regulation (“JER”)

The JER contains supplemental regulations for DoD employees.