Investigation of David Hayes

At the request of U.S. Department of the Interior (DOI) Chief of Staff Tommy Beaudreau, we investigated concerns that David Hayes, Vice-Chair of the White House Advisory Council on Wildlife Trafficking (WHAC) and a former Deputy Secretary of the Interior, may have violated ethics rules related to his involvement in the WHAC. Specifically, we examined potential conflicts of interest with Hayes’ creation of the U.S. Wildlife Trafficking Alliance (a coalition of private companies and nongovernmental organizations formed to help combat wildlife trafficking) and any relationship between the Alliance and the WHAC. We were also asked to determine whether Hayes used his position as the WHAC vice-chair to further his personal financial interests by having the students in a class he taught at Stanford Law School develop recommendations for fighting wildlife trafficking and present them to the WHAC. 

 

We found that Hayes formed the Alliance as part of his duties and responsibilities as the vice chair of the WHAC to further the WHAC’s mission, and that he was an unpaid Special Government Employee. We found no evidence to suggest that Hayes received financial compensation for his involvement with the Alliance, or that either he or Stanford Law School benefited financially from his students’ presentation to the WHAC.

 

During our investigation, we found that DOI’s Office of the Solicitor did not conduct an ethics review of a June 2015 letter sent from the Office of the Secretary of the Interior to Hayes in support of the Alliance. Although not specifically required for correspondence generated by the Secretary’s Office, an ethics review may have identified and addressed potential conflicts of interest.