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Green Book - Booz Allen Hamilton

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5. Post-Government<br />

Employment<br />

<strong>Booz</strong> <strong>Allen</strong> employees must comply<br />

with safeguards implemented by<br />

the firm to avoid violating postgovernment<br />

employment rules when<br />

(1) recruiting or having employmentrelated<br />

discussions with any current<br />

government employee, (2) hiring<br />

any current or former government<br />

employee, or (3) deploying any<br />

employee who used to work for<br />

the Government.<br />

Understanding the Rules Current<br />

government employees are subject<br />

to various legal restrictions when<br />

seeking employment in the private<br />

sector. Once employed in the private<br />

sector, former government employees<br />

may face limitations regarding<br />

their work activities. The intent of<br />

these legal requirements is to avoid<br />

creating the appearance of a conflict<br />

of interest or undue influence. How<br />

each rule related to recruiting, hiring,<br />

and deploying individuals subject<br />

to post-government employment<br />

restrictions is applied to a particular<br />

situation is highly fact dependent;<br />

often, seemingly small details can<br />

have a large impact.<br />

Safeguarding Against Violations<br />

Our Post-Government Employment<br />

Policy uses various safeguards<br />

to avoid possible violations. Each<br />

of us must be familiar with its<br />

requirements before having any<br />

employment-related discussions with<br />

a current government employee. For<br />

government employees with whom<br />

the firm has a “business relationship”<br />

(as described in our policy), special<br />

restrictions apply.<br />

Before hiring a current or former<br />

government employee, we may<br />

require that the individual obtain<br />

an ethics opinion (known as a<br />

Designated Agency Ethics Official<br />

[DAEO] letter in the US Government)<br />

as a condition of hiring so that we<br />

can evaluate whether the candidate<br />

can fulfill his or her intended role.<br />

As an individual moves through<br />

assignments, follow-up guidance may<br />

be required to ensure compliance<br />

with the rules.<br />

Understanding Your Restrictions and<br />

Those of Staff You Manage If you are<br />

a former government employee, you<br />

must understand the restrictions<br />

that apply to you and seek guidance<br />

before accepting any work that may<br />

be restricted. For most former US<br />

Government employees, this will<br />

restrict certain activities regarding<br />

matters on which you worked or<br />

were under your official responsibility<br />

when working for the Government.<br />

If you manage former government<br />

employees, familiarize yourself with<br />

their restrictions and seek guidance<br />

before assigning them to work to<br />

which a restriction might apply.<br />

Key policies related to this Code<br />

section:<br />

oo<br />

Post-Government Employment<br />

6. Use of the Firm<br />

Name/Marks<br />

The goodwill associated with <strong>Booz</strong><br />

<strong>Allen</strong>’s name is one of the firm’s most<br />

valuable assets. To protect this asset<br />

and avoid even the appearance of<br />

compromised objectivity, all uses of<br />

the firm’s name or marks must be<br />

appropriately authorized. Employees<br />

may not use the firm’s name or their<br />

affiliation with it for personal gain or<br />

in connection with non-firm activities<br />

(e.g., charitable or volunteer work<br />

not sponsored by the firm under its<br />

community partnerships programs).<br />

Authorizing Use by a Third-Party<br />

Generally, any use of the firm’s name<br />

by a third-party must be defined<br />

in a contract. We limit use of our<br />

name by a teaming partner to the<br />

particular teaming effort under<br />

approved contract terms. Similarly,<br />

we limit use by service providers to<br />

delivering the contracted services.<br />

When you represent the firm at an<br />

event, the event organizer may use<br />

the firm’s name solely in connection<br />

with your role at the event. All other<br />

uses of our name by a third-party<br />

must be approved by Marketing and<br />

Communications.<br />

40<br />

THE GREEN BOOK | The <strong>Booz</strong> <strong>Allen</strong> <strong>Hamilton</strong> Code of Business Ethics and Conduct

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