relations with non-federal entities - United States Department of ...

are supporting a non-Federal entity event in their personal capacity, theymay use their official titles, positions, or organization names only as partof their biographical details, provided they have the same prominence asother important details. (5 C.F.R. 2635.807(b))(5) Disclaimer: Personnel in either an official or personal capacity who use orpermit the use of their official titles, positions, or organization names inassociation with their speaking or other participation must make adisclaimer at the beginning of the speech if the subject of their speechdeals with agency policies, operations, or programs and they have notbeen authorized by appropriate DoD authority to present the speech asDoD’s position. (JER 2-207)(a) The disclaimer must expressly state that the views presented are thoseof the speaker and do not necessarily represent the views of DoD orits components.(b) Official policy speeches that present an official DoD position and areso authorized do not require the disclaimer. See 2-207 and 3-211.c.of the JER.b. Use of DoD seals/emblems/logos: An event sponsored by an NFE is not anofficial event, so the NFE may not use official seals or emblems in connectionwith the event, even if DoD personnel are speaking.c. Restricted Access, especially to senior DoD officials:(1) DoD personnel may attend non-training NFE-sponsored events or separatemeetings at such events if they are widely attended, but they may notattend special events with a restricted audience, especially if the NFEpromotes attendance of the overall event by featuring special access tosenior DoD officials or if they charge higher rates for such special access.This includes meals or events in which only major contributors are invitedto meet DoD officials. DoD officials may not participate in private, oneon-onemeetings at such events.(2) DoD personnel should not support meetings or events when they arelimited to persons from only one entity (such as the annual meeting of theleadership of a large corporation). Because the audience is limited, thereare concerns regarding preferential treatment, disclosure of nonpublicinformation, the appearance that the business has special access to seniorDoD officials, and potential overburdening of senior officials withspeaking engagements. Since some of these meetings take place at poshresorts, there may be the appearance that the DoD officials are acceptingextravagant accommodations and travel. While it is generally in DoD’sinterests to consult with suppliers, the preferred venue is meetings orconferences open to all members of the industry.25Relations with Non-Federal Entities10th Ethics Counselor's Course