Office of Ethics
United States Department of Agriculture

Frequently Asked Questions

V. Subpart E — Impartiality in Performing Official Duties.

a.    Personal and business relationships (Section 2635.502).

Question Two months ago, I left employment with a firm competing for a contract with my Agency. I have completely severed my ties with the company. I transferred my 401k to my own broker. My duties include recommending the winner of the contract. Will I have a problem if I recommend the winner of the contract?
 
Answer

An employee has a "covered relationship" with an employer he/she has left within the last year. Even though you have completely severed your relationship with the company, you may not recommend the contract winner. A reasonable person with knowledge of these facts could question your impartiality. Your Agency head or other ethics official with appropriate delegated ethics authority may, however, authorize you to participate in the matter if deemed necessary. The criteria for the authorization is set forth in this section of the Standards.