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Federal HR Policies Affecting Cooperative Extension Organizations

Conduct and Conflicts of Interest

Introduction

The nature of Cooperative Extension work requires considerable public contact. The Cooperative Extension System is proud of the contributions it is making. The impression of the Cooperative Extension System is in the hands of each Cooperative Extension employee. Courteous, efficient and effective interaction with the public is important in gaining trust and support. It is also important that Cooperative Extension employees represent the best of their abilities and tap other valuable resources as appropriate. It is hoped that Cooperative Extension employees will take pride in their contributions as well as in the contributions of other extension employees to the system and that they will share their knowledge, skills and enthusiasm with the clientele it serves.

The public views Cooperative Extension staff and volunteers as educators who represent the outreach component of their land-grant college/university. Cooperative Extension systems should avoid situations which question its public trust and those that create a conflict of interest.

Resources

Title 18 U. S. Code, Crimes and Criminal Procedure
Section 4 (a), Smith Lever Act - Conflict of Interest Policy
Privacy Act of 1974
Freedom of Information Act
State and University Conduct and Conflict of Interest Policies

Policy

CES Directors and Administrators should review their conflict of interest policies annually and make sure that all employees are aware of the employing agency conduct and conflict of interest policies. The USDA HRD CES Team maintains a file for each CES offices' Conflict of Interest Policies and a revised copy of the university/college CES Conflict of Interest policy must be forwarded to the USDA HRD CES Team whenever changes are made to such policies. The USDA HRD may request updates as needed to respond to inquiries from Department officials.

Confidential Information

Confidential information encountered in the course of cooperative extension work should not be discussed with others unless it is absolutely necessary to share the information in order to effectively carry out ones responsibilities or the information is detrimental to the system. It is essential not to violate the trust of others by unnecessarily sharing confidential information.

Code of Conduct

Extension educators are expected to avoid any action which might give the appearance of:

  • using one's position for private gain,
  • using public funds to lobby for or against legislation or appropriations (Title 18 U.S. Code, sec. 1913),
  • giving preferential treatment to any individual or group,
  • impeding governmental efficiency or economy,
  • making a decision outside of official channels,
  • effecting adversely the confidences of the public and the integrity of the Cooperative Extension System.

State and local laws should be reviewed to ensure that other conflict standards are addressed.

Political Activity

While Cooperative Extension employees are not covered by the political activity restrictions of the Hatch Political Activities Act, (Title 5 U.S. Code sec. 7323) they are subject to certain criminal constraints of the Federal legislation prohibiting:

It is the responsibility of the Director/Administrator of the Cooperative Extension organization to determine whether or not a political activity will interfere with the execution of the employee's Cooperative Extension responsibilities or create a situation that may be in conflict. To avoid a conflict of interest, employees should receive prior approval before participating in a political activity.

Areas which could be perceived as conflicts of interest include:

Outside Consulting

  • Any consulting should be outside of the responsibilities of the Cooperative Extension system.
  • Consulting should be done as a private citizen on one's own time and should not impede on Cooperative Extension responsibilities.
  • The Cooperative Extension system should not be identified with the project nor should any Cooperative Extension resources be used.
  • An exception for the consulting work should be obtained from the State Director/ Administrator of Cooperative Extension prior to committing to the consulting project.

Products and Services

The appearance of endorsing or promoting brand name products or services should be avoided. When dealing with controversial public issues every effort should be made to remain neutral and only to present known scientific facts. If pressed for a response, every effort should be made to present various sides of the issue with equal merit.

Owning a Business

The ownership of a business should not, as a result of the person's Cooperative Extension position, compete unfairly with similar businesses. Buying, selling or trading commodities should not be engaged in if holding a Cooperative Extension position gives an unfair advantage. If there is no advantage, these activities must be carried out on one's own time and not take away from the employee's Cooperative Extension responsibilities.

Holding an Elected or Appointed Office

Federal legislation no longer prohibits Cooperative Extension educators from participating in partisan politics. However, partisan and non-partisan political activities should be conducted on one's own time, with one's own resources, and should not use, associate or imply the name of Cooperative Extension with it. Participation in these activities should be reviewed by the Director/Administrator of the State Cooperative Extension system to assure that a conflict in responsibilities does not exist.

Providing Expert Testimony

Care should be taken to avoid situations in which testimony is judgmental or appears partial. Providing expert testimony in court which may be construed as a consulting service should also be avoided. Whenever possible, suggestions for alternative expert testimony should be offered.

When subpoenaed to appear in court as a factual witness, it is compelling to appear. When subpoenaed, it should be made clear to the court that as a Cooperative Extension employee it is important to remain impartial due to their Cooperative Extension duties and responsibilities. If a Cooperative Extension employee is required to appear as a witness, it should be stated to the court that as a Cooperative Extension employee they should remain impartial due to their duties and responsibilities and that they should limit their remarks to scientific facts. The State Cooperative Extension Director should be notified of the situation whenever a Cooperative Extension educator is called to testify.

All Cooperative Extension employees are expected to devote their efforts and abilities to the Cooperative Extension system. Flexibility should be implemented whenever possible when and where there is not a conflict of interest. Cooperative Extension employees should consider the effects of any paid or unpaid work outside of Cooperative Extension on the Cooperative Extension system and their ability to effectively carry out the responsibilities of their Cooperative Extension work.

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