Ethics in Action: What is the Policy on Volunteering?
This occasional column features the advice of HHS ethics attorneys to help guide employees on how to deal with issues that arise in the workplace. We'd like to hear what you'd like to see the column address and if you think it's covering the right issues. Send an email to the Ethics in Action team.
I'm considering a volunteer opportunity with a non-profit that provides in-school literacy programs. The sessions take place during the school day from 10 a.m. to noon, three days a week. The organization also advocates for education related policy issues. Because my work experience, they've asked me to lead their advocacy efforts. This is solely voluntary and on my own time. Do I need to visit with my manager before moving forward?
This is a thoughtful question, and the answer is yes. Community volunteerism is an important part of good citizenship, but the Texas Government Code requires state employees avoid conflicts of interest between the public interest and their private interests. The HHS Ethics Policy and Human Resources Manual state, "Agency policy requires employees to consult with their managers when an outside agency activity has the potential to create a conflict of interest or possible appearance of impropriety."
According to HR policy, employees must submit HR Form 0302: Request for Clearance of Non-Agency Employment or Activity to their supervisor for approval in advance. This form helps you and your manager identify any conflict of interest or appearance of impropriety. In this situation, the activity would take place during the workday for two hours a day, three days a week for a total of six hours away from work each week — not including travel time. You and your manager might consider whether you can still perform the essential tasks of your job if you are away for six or more hours each week.
You might also consider whether your work duties intersect with the organization's advocacy activities. For example, would you be expected to use your work contacts or share HHS confidential information? If so, there could be a potential conflict of interest between your activities on behalf of the organization and the public interest associated with your work for the agency.
Exploring these issues with your manager will benefit you and the agency. You might even find an alternative way to get involved that will avoid potential conflicts and any appearance of impropriety. In this case, you might take vacation time and volunteer for one day instead of three. Or, you might discover that the organization's advocacy issues have nothing to do with agency business or your job.
If you have questions about outside volunteer activity and potential conflicts or appearances of impropriety, contact the HHS Ethics Office.
For ethics questions contact:
DFPS and DADS
David Reisman, Chief Ethics Officer
HHSC and DSHS
Toya Bell, Deputy Chief Ethics Officer
Anonymous Helpline 512-424-6630
You can also email questions to the Ethics in Action mailbox.