Page 12 - E3 Employee Handbook

The mere existence of a relationship with outside firms does not necessarily create a conflict of interest. However,
if you have any influence on transactions involving purchases, contracts, or leases, it is imperative that you
(immediately) disclose in writing to E3 Human Resources as soon as the actual, possible, or potential conflict of
interest is identified or otherwise becomes known so that safeguards may be established to protect all parties.

Note: In addition to personal conflicts of interest, employees must also seek to avoid organizational conflicts of
interest. OCI may occur in any of the following circumstances:

 E3 is unable or potentially unable to render impartial assistance or advice to the US Government
 E3’s objectivity in performing work for the US Government is or might otherwise be impaired.
 E3 has an unfair competitive advantage; example – Access to source selection information.

Questions with regards to OCI should be addressed to your program/project manager or to the E3 Sr. Vice President
of Contracts.

2.4 Gifts and Gratuities
You shall not solicit or accept for personal use, or for the use of others, any gift, favor, loan, gratuity, reward, promise
of future employment, or any other thing of monetary value that might create a conflict or appear to create a conflict
of interest, or that might influence or appear to influence your judgment or conduct in the performance of your job.

As a federal contractor, the Federal Acquisition Regulation (FAR), prohibits giving a government official any gift with
an aggregate market value of more than $20 (per occasion), provided that the market value of multiple gifts to the
same official does not exceed $50 in a calendar year. These regulations ban government employees from seeking or
accepting gifts from a “prohibited source”. A prohibited source includes a contractor or contractor personnel. “Gift”
is broadly defined to include “any gratuity, favor, discount, entertainment, hospitality, loan, forbearance or other
item having monetary value.”

Example: Your Contracting Officer’s Representative (COR) adopts a child, has a child who graduates from college,
gets married, purchases a new home, experiences the death of a close family member. You want to recognize this
life event with a gift.
A) Can you give a gift?
a. Yes, however, the value of the gift cannot exceed $20 per occasion.
B) $20 is a rather pithy amount. To provide a more expensive gift, can several employees each donate
$20?
a. No, doing so would be a violation of applicable regulations.
C) How does E3 recommend employees respond to these types of situations?
a. We recommend having a card signed by the group be presented to the government official in
lieu of any other “gifts.” Not only does this ensure E3 will not inadvertently exceed the $50
gift maximum per federal employee per year but it also avoids potentially putting the federal
employee in an uncomfortable situation, as most are trained not to accept gifts of any amount,
except those of small, intrinsic value or meet the exceptions provided in the regulations.

If you are uncertain as to the applicability of this policy to your work, you are responsible for seeking guidance from
your E3 Manager, E3’s Sr. Vice President of Contracts or E3’s Human Resources Director.

2.5 Maintaining Your Personnel Records
To keep necessary records up to date, it is extremely important that you notify E3 Human Resources of any changes
in:
 Name and/or marital status;
 Address and/or telephone number;
 # of eligible dependents;
 W-4 and state tax deductions; and/or

Information in this document is proprietary to E3 and should not be discussed with third parties without consent.
Printed copies are uncontrolled and for reference only.