National Aeronautics and

Space Administration

Mary W. Jackson Building NASA Headquarters

Washington, DC 20546-0001

 February 27, 2024

Reply to Attn of: General Law Practice Group

TO: Distribution

FROM: Agency Counsel for Ethics 

SUBJECT: Determination Regarding Attendance by NASA Employees at the Embassy of 

Australia, the Australian Space Agency, and Space Foundation Reception on 

February 29, 2024. 

On February 29, 2024, the Embassy of Australia, the Australian Space Agency, and the 

Space Foundation, a nonprofit organization under 501(c)(3) of the Internal Revenue Code 

will hold a joint reception at the Embassy of Australia, 1601 Massachusetts Ave., NW,

Washington, DC, from 6:00 p.m. to 8:00 p.m. The purpose of the reception is to provide a 

venue for industry, government, international partners, academia, and other stakeholders to 

discuss topics of interest related to international cooperation in space. The Embassy of 

Australia, the Australian Space Agency and Space Foundation are jointly in control of the 

planning, organizing, and issuing invitations for this event (Blue Halo is co-sponsoring the 

event and is contributing financial support, but not coordination any event logistics). 

Approximately 750 people are expected to attend the event. Attendees will have a diversity 

of views or interests and will include personnel from congressional staffers, state and local 

officials, academia, industry representatives, administration personnel, spouses and plus 

ones. The estimated cost of the event, including all food and beverages, is approximately 

$50 per person (drink tickets can be provided upon request, with inclusion of drink tickets, 

the cost of food and beverage is approximately $35 per person). Attendance at this event 

will allow NASA attendees to exchange information regarding various NASA programs. I 

find that the event meets the requirements of a “widely attended gathering” as defined in 5 

C.F.R. § 2635.204(g)(2). 

I further determine that there is an Agency interest in having NASA personnel attend the 

event because it will provide an opportunity for the invited persons to exchange ideas and 

views pertaining to NASA’s policies, programs and operations. NASA employees, 

including NASA employees subject to the ethics pledge of executive order 13989, who do 

not have a significant role in a matter affecting the interests of Space Foundation may 

accept an invitation for free attendance for themselves and a guest to attend the event. In 

those circumstances, I find that the Agency’s interest in attendance outweighs any concern 
2

that the individual may be, or may appear to be, improperly influenced in the performance 

of their duties.1

In addition, NASA employees who have a significant role in any pending matter affecting 

the interests of the Space Foundation, 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 the invitation.

Adam F. Greenstone

1 To the extent that the gift of attendance is provided by entities of the government of Australia, acceptance is 

authorized under the Foreign Gifts and Decorations Act.