National Aeronautics and Space Administration

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

December 22, 2021
Reply to Attn of: General Law Practice Group

TO: Distribution
FROM: Alternate Designated Agency Ethics Official

SUBJECT: Determination Regarding Attendance by NASA employees at the Reception
and Dinner Related to the James Webb Space Telescope (JWST) Launch in
Kourou, French Guiana, on or about December 24, 2021

Representatives from NASA have been invited to attend a series of events in conjunction
with the spell the James Webb Space Telescope (JWST) Launch in Kourou, French Guiana.
The JWST is intended to enable representatives from the space industry, space users, space
policy makers, students, young professionals, researchers and academicians to meet and
exchange experiences, ideas and views pertaining to NASA’s policies and operations, and to
develop world-wide cooperation programs. Arianespace, Inc, a registered lobbying
organization, and the European Space Agency (ESA), an international organization based in
Paris, France that is a governmental authority for purposes of the Foreign Gifts and
Decorations Act, are in control of the planning, organizing, and hosting the following events
on launch day, currently anticipated to be on or around December 25, 2021:

1. The launch delay Brunch: The ESA will host a brunch at the launch site in Kourou,
French Guiana at 5:30 a.m. to 9:00 a.m. Approximately 120 people are expected to
attend, including from the U.S. legislative branch, international partner governments,
industrial partners, and other dignitaries in the space exploration community. The
breakfast will include food and beverages valued at approximately $79 per person.

2. Post-Launch Dinner Reception: The ESA will host a dinner reception at the launch
site in Kourou, French Guiana at 7:00 p.m. to 10:00 p.m. Approximately 120 people
are expected to attend the dinner. Expected attendees include individuals from the
U.S. legislative branch, international partner governments, industrial partners, and
other dignitaries in the space exploration community. The dinner reception will
include food and beverages valued at approximately $113 per person.

In accordance with 5 C.F.R. § 2635.204(g), and 14 C.F.R. § 1207.103, I find that the events
listed above meet the definition of a “widely attended gathering.” | further find that there is
an agency interest in having NASA employees attend the events, as they will have the
opportunity to further agency programs and operations through the exchange of views and


information with other attendees. Accordingly, NASA employees who have been invited to
attend may accept free attendance.

However, NASA employees who are in non-career positions for which they are required to
sign an ethics pledge under Executive Order 13989 may only attend these events if they
reimburse the hosts the value of the events they attend.!

NASA employees who have a significant role in any pending matter affecting the host of an
event in this determination, such as procurement duties, program management, or negotiating
or administering a Space Act Agreement, should seek a separate determination from their
local ethics counselor as to whether they may accept an invitation of free attendance.

Attendees are reminded to exercise any COVID-19 precautions appropriate to their
individual situation.

ZAL-

Adam F. Greenstone

' Regardless, NASA employees including employees subject to the ethics pledge may accept free attendance at
both launch events without reimbursing the hosts if they are speaking at either event.