MEMORANDUM FOR DIRECTOR OF: CENTRAL INTELLIGENCE AGENCY FROM: DONALD RUMSFELD

• Document Type: CREST
• Collection: General CIA Records
• Document Number (FOIA) /ESDN (CREST): CIA-RDP80M01009A003100020030-8
• Release Decision: RIPPUB
• Original Classification: K
• Document Page Count: 8
• Document Creation Date: January 4, 2017
• Document Release Date: March 5, 2008
• Sequence Number: 30
• Publication Date: October 28, 1974
• Content Type: MF

I Execwive R,.yistry
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`.r
October 28, 1974
MEMORANDUM FOR DIRECTORS OF:
CENTRAL INTELLIGENCE AGENCY
COUNCIL OF ECONOMIC ADVISERS
COUNCIL ON ENVIRONMENTAL QUALITY
COUNCIL ON INTERNATIONAL ECONOMIC
POLICY
NATIONAL SECURITY COUNCIL
OFFICE OF ECONOMIC OPPORTUNITY
OFFICE OF MANAGEMENT AND BUDGET
OFFICE OF THE SPECIAL REPRESENTATIVE
FOR TRADE NEGOTIATIONS
OFFICE OF TELECOMMUNICATIONS POLICY
SPECIAL ACTION OFFICE FOR DRUG ABUSE
PREVENTION
FROM: DONALD RUMSFELD I i .T(
Attached are two memos and a packet of informatiin which
has been distributed to members of the White House staff and
other executive office staffs whose reporting mechanisms are
combined with the White House staff. Your office is considered
a separate office within the Executive Office of the President
and under present regulations as head of the Office, your confidential
1 Statement of Employment and Financial Interests is filed with the
Chairman of the Civil Service Commission. The President has
directed that all members of the Executive Branch be in compliance
with the regulations concerning conflicts of interests and the filing
of the financial statements.
In the event your own filing with the Chairman of the Civil.
: rv_ce Commission is not current, please take immediate steps
o Update it and bring it into compliance. In addition, you are
a requested to take all necessary steps to be certain that your staff
,) members who are required to file the Statement of Employment and
Financial Interests have done so and that they have been properly
evaluated by those on your staff entrusted with this responsibility.
It will also be appreciated if you will advise the staff secretary
by November 30, 1974 on the status of your of ice's compliance with
these requirements.
NSC review completed.
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THE WHITE HOUSE
WASHINGTON
October 28, 1974
MEMORANDUM FOR: WHITE HOUSE OFFICE
VICE PRESIDENT'S OFFICE
DOMESTIC COUNCIL
FROM: DONALD RUMSFELD j Ll 1
Assistant to the President
Standards of Conduct/ Confidential
Statement of Employment and
Financial Interests
The attached manual on standards of conduct for the White House
staff is being distributed at President Ford's direction to remind
and acquaint each employee with the high standards of conduct
which are expected of each employee as members of this
Administration. It contains important information which will
assist you in avoiding any conflict of interest or conduct which,
although proper in fact, could appear otherwise.
The President has emphasized that each of us is to be governed by
the rules of truthfulness and personal and professional integrity.
This places a special obligation on all personnel to recognize that
his or her actions reflect on the Office of the Presidency, and to
carefully weigh actions against the highest standards and criteria
for conduct in public office.
The attached memo from the Counsel to the President explains in
more detail some of the main problem areas of which each employee
should be aware. Please read the material carefully and where
appropriate, promptly prepare the required reports. If there are
any questions at any time during the course of employment, they
should be discussed with the Counsel to the President or a member
of his staff.
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October 28, 1974
MEMORANDUM FOR: ALL EMPLOYEES OF THE WHITE HOUSE
OFFICE, THE DOMESTIC COUNCIL
AND THE VICE PRESIDENT'S OFFICE
FROM: Philip W. Buchen e -.~
Counsel to the President JJ~dJ
SUBJECT: Standards of Conduct/ Confidential Statement
of Employment and Financial Interests
In accordance with the President's directive, this is to advise you
of the stringent legal requirements governing the standards of
conduct and conflicts of interest applicable. to each of you.
Additionally, all recipients who are employees (government
employees) paid at a level equivalent to GS-13 ($21, 816) and above,
or are consultants (special government employees) regardless of
grade or salary, are required by law to file certain employment
and financial information.
While the employees of the Vice President's office would not normally
fall under the responsibility of the Counsel to the President in this
respect, they are included in this distribution in order to assist
during the transitional period.
Statements of Employment
and Financial Interests
As noted above, if you are an employee paid at an annual rate in excess
of $21, 816 or a consultant, regardless of salary, you are required to
complete and file certain forms calling for employment and financial
information. If you are a newly-incoming employee and are subject
to this requirement, you are to complete the attached forms which
should be filed not later than thirty (30) days after entrance on duty.
In order to insure that our records are complete, all present personnel
(full-time and consultants) subject to the reporting requirement who
have not filed a statement since August 9, 1974, must file the attached
statement by November 8. Additionally, to assist this office in
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evaluating your statement, and to provide you with any necessary
guidance, you are also requested to complete and return the attached
job description form along with your statement. If you have filed a
statement since August 9, 1974, you now need file only the job
description form.
Should you have any questions or require any assistance in completing
these forms, please contact Mr. Kenneth Lazarus, Associate Counsel
to the President, at Ext. 6297.
Subsequent to this initial reporting, you will be notified of the need'
for a refiling in June of each year. Notification of any interim changes
in financial interests or job description as set forth in the forms will
be required at your initiative.
For your convenience, if you have submitted comparable information
in the past to this or any other office, you may simply provide a copy
of that submission and note any changes. It is recommended that you
keep a copy of the information you provide this office for future
reference. Please send your data to Mr. Kenneth Lazarus, Room. 106,
OEOB.
Personnel at the White House on detail should look to their respective
agencies for any relevant reporting requirements. However, such
personnel are subject to the White House Standards of Conduct.
Standards of Conduct
The Standards of Conduct to which you are subject and which are
considered at length in attachments may be briefly summarized as
follows:
a. Authorities. Each of you is subject to Regulations
(3 CFR, Part 100) issued under the authority of
Executive Order '11222 (May 8, 1965), governing
your conduct. Copies of these Regulations, the
Executive Order, and relevant Federal criminal
statutes (P. L. 87-949, Title 18, U. S. C. Secs.
201, et seq.) are included in the attached materials.
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As you are responsible for conforming your
conduct to the standards required by these
authorities, I strongly urge you to study the
enclosed materials at once and to retain them
for your future reference.
b. Conflicts in General. A "conflict of interest"
refers to any situation in which a government
official has an actual or apparent personal
interest in the outcome of a matter which he or
she is in a position to influence through decision,
recommendation, advice or other formal or
informal action. A violation of law does not.
require an intent to favor one's personal interest,
and cannot be overcome by a showing of the
absence of such an intent. Participation, by
itself, in a matter in which you have an interest
is unlawful. Whenever you perceive even the
possible appearance of a conflict you should
disclose this fact to your superior and to the
Counsel to the President to obtain guidance as
to how the matter should be handled. Financial
interests most typically giving rise to conflict
problems are stocks, bonds, outside employment
(including any continuing interest in or income
from a prior employment or partnership rela-
tionship). Real estate held as an investment
also counts, as do any unusual debt obligations.
The interests of all members of your family
living within your household are regarded as
your own.
c. Illustrative Prohibitions. In order to develop an
awareness of our Standards of Conduct and
potential conflicts which may confront you, a
number of illustrations of prohibited conduct may
be considered. However, you should be cautioned
that these illustrations are not exhaustive in terms
of potential problem areas or their treatment
of the issue.
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1. Regulatory Agencies. Executive Office personnel
should be especially careful about contacts with
regulatory agencies, and by directive from the
President, should clear in advance any contacts
with such agencies or with litigating divisions of
the Department of Justice through the office of
the Counsel to the President.
2. Lobbying. If carried on with appropriated funds,
lobbying is expressly prohibited by law.
3. Political Activity. Political activity by White
House personnel is, of course, subject to re-
strictions. For example, no political campaign
activity, and especially no solicitation, receipt,
expenditure or possession of campaign funds
may occur on the premises of any Federal building.
4. Misuse of Information. Disclosure of classified
or other confidential information is, of course,
prohibited. Equally important is to avoid the
fact and appearance of using information obtained
from your official duties for private gain,
especially through investments or speculations.
Because of the inevitable appearance of impropriety,
White House personnel should avoid engaging in
speculative activities of any kind.
5. Gifts. Receipt of gifts, payment of travel,
lodging, entertainment and other expenses, or
the receipt of speaking honoraria are generally
prohibited except in the limited circumstances
described in the attached materials. Gifts to
superiors within the White House are also illegal.
6. Appearance of Impropriety. Finally, employees
must be ever sensitive to avoid the appearance of
acting on behalf of some private interest or of
a conflict or other impropriety which can be fully
as damaging as the real thing. You should not,
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for example, be found in constant or suggestive
contact with persons having important stakes
in government actions for which you have some
responsibility.
Closing Note
I trust that this material will be of assistance to you and that we will
have your cooperation in meeting our responsibilities in this area.
The office of the Counsel to the President stands ready to assist
you as needed.
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EXECUTIVE SECRETARIAT
Routing Slip
TO:
ACTION
INFO
DATE
INITIAL
1
DCI
2
DDCI
3
S/MC
4
DDS&T
5
DDI
6
DD
7
DDO
8
D/DCI/IC
9
D/DCI/NIO
10
OGC
11
OLC
12
IG
13
Compt
14
D/Pers
15
D/S
16
DTR
17
Asst/ DCI
18
AO/ DCI
19
20
21
22
To General Counsel: Please get together with
DDA and assure Agency compliance with the attached.
10/30/74
Dote
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