National Aeronautics and 

Space Administration

Mary W. Jackson Building NASA Headquarters

Washington, DC 20546-0001

 

March 22, 2023 

Reply to Attn of: General Law Practice Group

TO: Distribution

FROM: Agency Counsel for Ethics 

SUBJECT: Determination Regarding Attendance by NASA Employees at the events in 

conjunction with the 2023 Space Launch System/Orion/Exploration Ground 

Systems Gateway Suppliers Conference on March 27–28, 2023 

The Aerojet Rocketdyne, Boeing, Lockheed Martin, Jacobs, Northrop Grumman, and 

Maxar (the “companies”), will hold the 2023 Gateway Suppliers Conference on March 27 

and 28, 2023 at the Capitol Hill Washington Hilton in Washington, DC, from 5:30 p.m. to 

7:30 p.m. on March 27 and 7:00 a.m. to 11 a.m. on March 28. The companies are jointly in 

control of the planning, organizing, and issuing invitations for this event. The invitation 

includes all day coffee, water, beverages, and an evening Day 1 reception (typically NASA 

and USG attendees do not participate in the breakfast or lunch). 

Day 1: 

Conference with U.S Government and Industry panels; evening reception with the public, 

NASA industry and congress. 

Day 2: 

Congressional Meetings (does not involve NASA). 

Suppliers to go to the “Hill” and they will be escorted by lobbyists (no lobbying on Day 1 

with NASA attendees).

Approximately 300 people are expected to attend the event. Attendees will have a diversity 

of views or interests and will include members of Congress, Executive Office of the 

President staff, trade association representatives, personnel from other federal agencies, 

members of the legislative branch, and representatives from media, and industry. The 

estimated cost of the event, including all food and beverages, is approximately $75 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 who do 
2

not have a significant role in a matter affecting the interests of the sponsors may accept an 

invitation for free attendance 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 their duties. However, NASA employees 

in non-career positions who are required to sign an ethics pledge under Executive Order 

13989 may only attend if they reimburse the sponsors the value of the event.1

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

the interests of the sponsors, 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 

you 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 Space Launch System will be 

distributing company marketing swag and playing cards (most of the swag or give aways 

are for the suppliers and Hill meeting on Day 2) which NASA attendees, including NASA 

employees in non-career positions who have signed the ethics pledge, may accept. An 

honor basket will be provided to reimburse for other gifts. 

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

individual situation.

Adam F. Greenstone

1 NASA Employees may accept free attendance to the events on the day they are speaking or participating in a 

panel discussion pursuant to 5 C.F.R. 2635.203(b)(8)(i).