VA - 18-06501-158 - 6

The Acting VA General Counsel confers with VA’s Designated Agency Ethics Official to revise its November 8, 2019 memorandum. The revision should at a minimum (a) emphasize all criminal conflict of interest statutes relevant to outside employment, (b) ensure appropriate time for supervisory review of confidential financial disclosure reports to identify potential conflicts or other issues, (c) identify the official responsible for ensuring that the annual risk assessment focused on outside activities is completed on an annual basis to assist Chief Counsel in identifying employees with outside employment, (d) engage employees with outside employment in formal discussions regarding applicable ethical rules and the consequences of noncompliance, and (e) document the annual meetings and formal discussions they have with employees.