United States Department of the Interior                                        FISH AND WILDLIFE SERVICE                                                     Washington, D.C. 20240

Memorandum

To:             All Employees

From:         Director

Subject:      Relations with Private Organizations

Many Fish and Wildlife Service employees express their personal commitment to wildlife conservation through membership in private organizations that also support this goal. Conflicts, however, may easily arise when Federal employees represent both private organizations and the government in common matters.

Service employees acting as members of private organizations, including nonprofit groups and associations, act solely as private individuals. It is important to avoid even the appearance of representing the government or of using any aspect of Federal employment (including official time, government property, and access to information) to benefit an outside group or promote its views.

Federal ethics regulations specifically prohibit Federal employees from using their official positions or titles in any way that could be construed as implying that the Federal government sanctions or endorses their activities or those of others. Employees acting as members of outside organizations or communicating on behalf of such groups should not use their official titles. This practice may create the appearance that the individuals involved are acting in an official capacity and may be interpreted as implying Service endorsement of the activities or views expressed.

Federal employees may not use unpublished information gained through their official positions to further their own or other private interests - including the interests of nonprofit organizations. When they write, speak, or communicate as private individuals on matters related to their official duties, they may use only government information that has been published or that would be made available to the public upon request.

Federal employees are prohibited from using appropriated funds to lobby a Member of Congress. This includes matters of concern to any outside organization of which they are a member. Individuals are required to refrain from using their official position to further their personal views by engaging in lobbying campaigns or participating in events designed to support or oppose legislation.

Employees are not prevented from communicating with any Member of Congress on any official matter in their official capacity when responding on behalf of the Department and accurately representing the views of the Administration and Department. Under these circumstances, they will be expressing the position of the Department, which may or may not be the same as their own position.

Employees are also prohibited from using official time and government property on behalf of outside groups.

Service employees can make important contributions by working with conservation organizations, professional associations, and other groups as private individuals. These activities can play an important role in promoting wildlife conservation and facilitating official Service outreach and partnership efforts. Following the guidelines outlined above should allow Service employees to work effectively within such organizations without compromising their integrity as public servants or creating confusion regarding the Federal government's policies and views.
 

                                                                                                /s/ JAMIE RAPPAPORT CLARK