Green Book - Booz Allen Hamilton
Green Book - Booz Allen Hamilton
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