Summary: An evaluation of the standards of conduct for Environmental Protection Agency (EPA) employees indicated that the following issues were not being adequately addressed: outside employment, acceptance of an honorarium, negotiations for employment, and acceptance of gifts. The standards reviewed were conflict of interest matters of a financial nature, non-Government employment situations, and other dealings with parties outside EPA.
Standards of conduct were not effectively implemented at EPA. It was found that employees were not always aware of their responsibilities. Employees were provided with inconsistent advice on questions of ethics because deputy counselors interpret and apply the standards independently. The system for implementing standards of conduct at EPA results in inconsistencies because the standards are interpreted by 49 deputy counselors with only minimal central guidance or review. Sources of information that can be used to evaluate the adequacy of EPA standards of conduct were available, but had not been used for this purpose. These databases could be tabulated in a usable format and, through analysis by the EPA counselor or under his direction, could be used to determine the needed changes to the standards of conduct or to determine additional guidance needed because of specific problems confronting EPA employees.
