Hello, my name is Jordan Murphy and I’m here to give you some insight into what is
permitted and prohibited regarding endorsements within the ethics rules.
This set of rules discuss use of public office for private gain.
Private gain does not just include your gain, but also includes a business’, a corporation’s,
a borrower’s, a family member’s, a friend’s…. virtually anyone!
These rules can be found in the Standards of Conduct in 5 CFR 2635.702.
The first section prohibits inducement or coercion of benefits to you or anyone else.
The second section limits the appearance of government sanction.
This part is most commonly referenced when discussing letters of recommendation for employment
or character reference letters.
Let’s dig a bit deeper here-- Are you looking to use your official title
and USDA letterhead for a letter of recommendation or character reference?
There are some restrictions you should be aware of.
Let’s work through this.
Please refer to this handy chart as I discuss.
Have you worked with this individual in your professional capacity?
If so, you may write them a recommendation using your official title and USDA letterhead.
If you have not worked with the individual in your official capacity - are you recommending
them for federal employment?
If so, you may write them a recommendation using both your official title and USDA letterhead.
If you’re not writing them a recommendation or referral for Federal employment, and instead
you just know them from your personal life, you may still write them a recommendation;
however, you may not use your official title and USDA letterhead.
Remember, you may always write a letter of recommendation in your personal capacity.
The last section prohibits endorsements.
As government employees, we cannot use our government position to endorse any product,
service or enterprise, except in certain situations.
For instance, if your agency has statutory authority, or if you are simply confirming
that an organization or outside entity has complied with government regulations or requirements.
This would be a matter of fact statement, not a rave review.
Let’s go over some of our most common questions related to this topic.
A partner has asked me to write a letter to include in its grant application package.
We plan to work with this group on this particular project if they are awarded the grant.
May I write the letter?
Yes - If a group asks for a letter of intent or collaboration, an employee might be able
to provide one, if the Agency has committed to working on the project AND if the letter
states only facts.
The letter may not contain any opinions of the validity or value of the project or in
any other way endorse the outside organization.
Let’s move to example #2.
A partner has asked us to write a letter to bolster their grant application package.
We aren’t specifically collaborating with them, but we do think their work is valuable
to our mission.
May I write the letter?
No, you may not write the letter.
If the Agency is not going to collaborate on the project, the only purpose of this letter
is to endorse the partner and its work, which is prohibited.
On to our last example.
#3.
A partner has asked us to write a letter to add to their grant application package.
They’ve asked us to provide details on previous work we’ve done together, but we have no
plans to collaborate on this specific project.
May I write the letter?
You may be able to do so.
The Agency may write a letter of fact stating details, not opinions, of previous collaborations.
The letter should not add value to the partner or its work.
However, it is rare for a grantor to request this type of letter.
It is more likely the applicant really is asking for letters #1 or #2.
Remember, this isn’t an exhaustive or comprehensive list.
Situations vary and require their own analysis.
You should always reach out to the office of ethics.
That concludes this brief training on endorsements.
I hope you’ve found it useful!
Remember, if you have any ethics questions, please reach out to your designated ethics
specialist.
Thanks for watching!