General Rule on Fundraising
Unless permitted by law, regulation or special authority, Department
employees may not engage in any form of fundraising activities. This includes
but is not limited to conducting raffles, lotteries, bake sales, carnivals
athletic events, etc. for charitable organizations. Department
employees may engage in charitable organizations sanctioned by the U.S.
Office of Personnel Management (OPM). This includes the Combined Federal
Campaign, Federal agency day care centers and relief organizations assisting the
victims of the September 11, 2001 terrorists attacks.
During the Combined Federal Campaign, it is acceptable for employees to conduct
games and contests (e.g.
door decorating contests, quizzes such as trivial pursuit, guessing games (how many jelly beans in a
jar)), provided there is no requirement that a donation be made as a condition of participating and the
contest prizes are legitimately obtained. A container for donations may be prominently displayed in
proximity to where the contest is taking place, as long as it is clearly communicated that donations
are voluntary. No suggested amount of an appropriate donation may be made.
Raffles, lotteries, and any other games of chance where employees pay
money in exchange for the opportunity to win a prize may not be conducted in
association with any OPM permitted fundraising activity. Accordingly an employee may not be offered a chance to
buy anything of value if the offer is based on a monetary contribution in the form of a donation. This
applies whether or not there is a predetermined donation amount.
According to 5 CFR 950.102(d), solicitation of employees conducted by
organizations composed of civilian employees for benefit of employees among
their own members for organizational support or for the benefit of welfare funds
for their members is permitted (with agency approval). This would include
the Interior Department Recreation Association, the Indian Arts and Crafts
Store, and the Department Daycare centers.
As a result of the September 11, 2001 terrorists attacks, the U.S. Office of
Personnel Management has authorized all Executive Department and Agency heads to
allow a special solicitation of Federal employees at the workplace. This
special solicitation will allow Federal employees to assist the ongoing relief
efforts in New York City and the National Capital Area with a one time cash or
check donation, outside the normal Combined Federal Campaign procedures. See
Additional guidance on acceptable activities for Department employees is
Ethics Rule: Federal employees may not
solicit donations from entities outside the Federal government.
Department employees may not solicit merchandise from local businesses as an incentive to increase
contributions to the CFC. Such gifts to Federal employees are prohibited.
This rule does not extend to representatives of Principal Combined Fund Organizations (PCFO),
which are local organizations that run the local CFCs on behalf of the designated charities. These
representatives are not federal employees and thus are not bound by statutory and regulatory
restrictions. PCFO representatives may not offer gifts to CFC key workers to be used as prizes in
kickoff ceremonies and other events. OPM is supposed to have advised the PCFOs of this
Ethics Rule: It is permissible to hold
bake sales, silent auctions, or similar events where items are purchased by
employees and proceeds donated to the CFC. It is also allowable for items
donated by Federal employees to be given as door prizes.
The bake sale or silent auction items to be sold must be voluntarily donated by the
employee. Management must take no action to pressure employees to donate goods, set official or
unofficial levels of organizational participation or accountability, or use the incentive awards program
as a quid pro quo to reward employees who are enthusiastic donors and/or purchasers.
Ethics Rule: Appropriated funds may
not be used to purchase prizes for CFC events.
The Department of Justice provided a written opinion to an inquiry from its own Human
Resources Director on this matter. The Director had asked if appropriated funds could be used to
purchase "trinkets" (e.g. pens, mugs, caps, tee shirts, etc.). The general conclusion was that there
is not a legal prohibition allowing the agency to use funds to purchase items of such negligible value,
given that the items would be used as incentives or awards for CFC key workers and coordinators.
However, DOJ went on to say it considered such expenditures imprudent and subject to scrutiny that
could put the agency in an embarrassing position for using appropriated money for non-mission