Values Based Ethics
12/21/2015
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In the Beginning: Standards of Conduct
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Common Ethics Advice Topics:
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Frequently Applied Conflict Laws:
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Gifts
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18 USC 208: Personal Conflict
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Use of Government Property / Time
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18 USC 201: Bribery of Officials
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Conflicts of Interest
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18 USC 203 + 205: Representing Another
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Financial Disclosure
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Awards
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18 USC 207: Post FBI Employment
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Outside Employment
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18 USC 209: Salary Supplement
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Involvement in Non-Federal Entities
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Political Activities
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Misuse of Position
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Endorsement and Preferential Treatment
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Fundraising in the Federal Workplace
Before Government – Paid / Free
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Bad Things Still Happen to Good People…
Department of Justice Inspector General’s
Report – National Security Letter
Mismanagement
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Catalyst for Integrity and
Compliance Program
In May 2007, the Director established an
Integrity and Compliance program
• Created the FBI Office and Compliance
(OIC) within the Director’s Office
• Program Scope – address all FBI
programs and activities
• Merged Ethics Function with Compliance
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Federal Sentencing
Guidelines
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Management Buy-In
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Organizational Structure
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Risk Reduction Methodology
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Two Way Communications / Training
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Process for Receiving Compliance
Concerns
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HR Policies that Encourage Compliance
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Documentation
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Objective
Promote an organizational culture that
encourages ethical conduct and
commitment to compliance with the law
(Values Based Culture)
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Three Pillars to the Program
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Shaping the Culture
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Core Values
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Strategy
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Policy
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Organizational Structure / Integration
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Training
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HR Policies
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Communication
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Core Values:
Own them, Live Them
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Rigorous Obedience to the Constitution •
Respect •
Compassion •
Fairness •
Integrity •
Accountability •
Leadership •
Diversity 9
Top Down and Bottom Up
Compliance Council
Branch Compliance Committees Division Compliance Committees
OIC
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Career Long Involvement
• Director
• DD and EADs
• ADs
• Section Chiefs
• ASACs
• 1st Line Supervisors
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Policy
• Review
• DIOG
• Core Values, Roles and
Responsibilities
• Obligation to Report NonCompliance
• Non-Retaliation
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Training
• Onboarding
• Agent & Analyst
• MLK Memorial
• Holocaust Museum
• SOC Training
• Teachable Moments / E‐Brief
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HR Policies
• I&C Elements in
• Executive PARs
• Employee PARs
• Leadership Climate Survey
• Awards
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Communication
• Posters
• E-Brief
• Teachable Moments
• Talk ‘Em Up
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