National Aeronautics and Space Administration

John F. Kennedy Space Center

Kennedy Space Center, FL 32899

April 4, 2024

Reply to Attn of: CC

TO: Distribution

FROM: CC/Acting Chief Counsel

SUBJECT: Determination Regarding Attendance by NASA Employees at the 2024 Space 

Heroes and Legends Awards Dinner at Kennedy Space Center Visitor Center on 

April 19, 2024

On April 19, 2024, the National Space Club Florida Committee, will host a reception and 

dinner at the Kennedy Space Center Visitor Center in Merritt Island, Florida. The event is 

celebrating the 2024 Space Heroes and Legends Awardee. 

 

The hosts have invited over 230 persons to attend. Attendees will have a diversity of views 

or interests and will include local aerospace companies, elected officials, industry leaders, 

USAF, and NASA. The estimated cost of the event, including all food and beverages, is $120 

per person. ASRC Federal, Axient, Boeing, Chenega Infinity, Delaware North, Leidos, 

Jacobs, Lockheed Martin, and ULA are sponsors for the event. 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 who do not have a significant role in a matter affecting the interests of the 

sponsors may accept an invitation for free attendance for themselves and a guest to the event. 

In those circumstances, I find that the Agency's interest in attendance outweighs any concern 

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

his or her duties. However, NASA employees in non-career positions who are required to 

sign the ethics pledge under Executive Order 13989 may attend the event only if they 

reimburse the sponsor the value of the event. 

 

 
2

NASA employees who have a significant role in any pending matter affecting the interests of 

ASRC Federal, Axient, Boeing, Chenega Infinity, Delaware North, Leidos, Jacobs, Lockheed 

Martin, and ULA, 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. 

You 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 for each occasion (and no more than 

$50 from one source in a calendar year). We understand that Axiom Space will be offering a 

gift bag valued at approximately $30. Employees may accept any item(s) that are under or at 

the $20 gift exception rule. NASA employees in non-career positions who have signed the 

ethics pledge may only accept a gift item if they reimburse the sponsor.

Thomas M. Browder III 

Agency Designee

Digitally signed by Thomas 

Browder

Date: 2024.04.08 12:58:40 -04'00'