National Aeronautics and
Space Administration

Mary W. Jackson Building NASA Headquarters
Washington, DC 20546-0001

March 16, 2022

Reply to Attn of: General Law Practice Group
TO: Distribution
FROM: Alternate Designated Agency Ethics Official

SUBJECT: Determination Regarding Attendance by NASA Employees at SpaceX
Axiom Space-1 Axiom Mission-1 Launch Events hosted by Axiom Space
on or around March 30, 2022

Axiom Space is scheduled to launch the SpaceX Axiom Space-1 Axiom Mission-1 on a
Falcon 9 Crew Dragon Endeavour launch vehicle from NASA’s Launch Complex 39A at
Kennedy Space Center, Florida, currently scheduled for approximately March 30,

2022. The event includes food and beverages at the launch viewing site in OSB II.

Approximately 250 guests have been invited to attend. Invitees include members of the
legislative branch, state and local government officials, foreign government diplomatic
personnel, industry representatives, academia, personnel from other Federal agencies, and
media. The value of the event, which includes all food and refreshments, will be
approximately $100 per person. I find that this event meets the requirements of a “widely
attended gathering” as defined in 5 C.F.R. § 2635.204(g)(2).

I further determine that free attendance at the above mentioned event is in the interest of the
agency because it will further agency programs and operations. Attendance at this event
will allow NASA attendees to exchange information regarding various NASA programs.
Accordingly, NASA employees (subject to the exceptions noted below) who have been
invited to attend may accept free attendance for themselves and a guest to this event.

However, NASA employees whose duties may substantially affect an event sponsor, such as
by way of contracting duties, should seek an individual determination pursuant to 5 C.F.R.

§ 2635.204(g)(3)(i), regarding participation in this event from their local ethics counselor.
Moreover, NASA employees who are in non-career positions in which Executive Order
13989 requires signing an ethics pledge may only accept the food and beverages, if they
reimburse the sponsor the value of the event! and any gift items accepted for themselves and
their guest.

' Employees may accept free attendance at an event in which they are scheduled speakers pursuant to 5 C.F.R.
§ 2635.203(b)(8)(i).


Attendees are reminded of the $20 gift exception at 5 C.F.R. § 2635.204(a), which provides
that employees may accept gifts valued at no more than $20 per occasion (and no more than
$50 from one source in a calendar year). We understand that Axiom Space will be
distributing a gift bag which contains an Axiom t-shirt ($13.42), mask ($5.75), Axiom
sticker, hat ($19.50), duffle bag ($14.20), Axoim patch, SpaceX shirt ($28.00), keychain
($3.50), and additional stickers, the total value of which under the gift rules is $84.37.
NASA employees may only accept the gift bag and its contents if they reimburse the
sponsor the market value of the gift. NASA employees, other than non-career NASA
employees who sign the Executive Order 13989 ethics pledge, may accept gifts of the above
items from Axiom or SpaceX not totaling more than $20 per entity, and not exceeding
aggregate gifts from that entity of $50 in 2022, if they are separately distributed. All NASA
employees may accept a gift of the stickers and patches if they are separately distributed.
Attendees are reminded to exercise any COVID-19 precautions appropriate to their
individual situation.

BALA

Adam F. Greenstone