Outside Business Activities and Conflict of Interest
On occasion, individuals may find themselves in ethical dilemmas when making decisions about getting involved in activities that may create or appear to create a conflict with their work responsibilities and the interests of the Laboratory.
Outside activities are not precluded when you work at the Lab. Consulting for others and other moonlighting work can often be beneficial for the individual's growth and can add value for the Lab. Conflicts may occur though, when outside activities or interests interfere with effective job performance or alter the judgment or ability of individuals to act in the best interests of the Lab. In all business dealings, one must exercise prudent judgment to avoid situations where one's loyalties may be questioned, particularly in situations involving sensitive procurement, intellectual property, personnel decisions, or outside employment activities leveraged with one's association with the Lab. So, in all dealings, Lab staff must be mindful of the potential for conflict of interest and conform to established standards of professional conduct and integrity. Even activities that appear unrelated to the Lab's mission may present a conflict of interest question.
Lab policy requires the disclosure of outside business activities ahead of time, which allows any appearance of conflict to be resolved upfront. If circumstances are unclear as to the propriety, consult with your supervisor, knowledgeable staff members such as our in-house legal counsel, Rhonda Scales (ext 7384), or the Employee Relations Manager, Cassandra Andrews (ext 7068). It opens up a line of communication for discussion of any ethical issues or impropriety that may arise in the course of the activity. To initiate a request to engage in outside business activity, be it employment, consulting, or establishing a comparable business activity, complete GEN101, Standards of Conduct Training. The form will appear at the end of the course. One of the values of the submittal is that it may help the Lab identify potential conflicts that are unknown to the person submitting the request. Requests must be resubmitted annually for review and approval.
Summarized below are some of the Lab's components of conflict of interest.
- Competing and conflicting professional interests between the individual staff member and the Laboratory will be resolved in favor of the Laboratory.
- Preferential treatment resulting or arising from employment must be avoided; therefore, even when there is not a real conflict, the appearance of one must also be avoided.
- Any work done for JSA, the Lab or Department of Energy is the same, and no additional payments may be accepted for such work. Any outside work which does not conflict with the Lab must be done on the staff member's own time.
- The Laboratory's resources such as equipment, machinery, computers, stationery, clerical support, may not be used for outside interests.
Conflict of interest could involve such things as accepting gifts, trips, or personal discounts. It also could include situations where the staff member has a business interest in an organization which does business with or is seeking to do business with the Laboratory, or which engages in similar work under contract to DOE. In addition, it is prudent for individual staff members to refrain from using their positions at the Lab to endorse products and services, or represent personal opinions as those of the Laboratory. For more information related to this topic, please consult your supervisor, our Legal Services staff or Employee Relations.