We investigated allegations that a senior political employee of the U.S. Department of the Interior (DOI) violated their Federal ethics pledge by communicating with a former employer during the required 2-year recusal period following the employee’s Federal appointment in the spring of 2017.
We found that the employee notified the DOI’s Departmental Ethics Office (DEO) three times between the summer of 2017 and the summer of 2018 about planned interactions with individuals or entities connected to their previous employer. In one instance, the employee declined to meet with an individual because DEO guidance was not received; in the other two instances, the DEO advised the employee that it was permissible to interact with the entities because they were not directly related to the former employer. We determined that the employee’s actions in these instances were proper and accorded with DEO guidance.
We did find, however, that the employee did not seek ethics guidance before contacting a scientist who worked for the former employer in late 2017 and later meeting with that scientist. We determined that these contacts violated the employee’s ethics pledge, but the evidence indicates that the employee interacted with the scientist under the mistaken belief that these communications were permissible because they involved sharing scientific data. We found no evidence that these contacts were used for the benefit of the employee or for the benefit of the former employer or the scientist.
We provided our report to the Chief of Staff for the Office of the Secretary for any action deemed appropriate.