LIMITATION OF EMPLOYMENT DUTIES OF FORMER EMPLOYEES OF GOVERNMENT AGENCIES HAVING REGULATORY AUTHORITY OVER TVA

WHAT

Post-employment conflict of interest laws place limits on the activities of former Federal Government employees who leave Federal employment to pursue work in the private sector. In order to prevent both actual and apparent conflicts of interest, TVA applies similar restrictions, as a matter of policy, on the TVA duties of individuals who have previously been employed by another Federal agency which has regulatory authority over TVA.

WHO

TVA employees who are former employees of a Federal agency having regulatory authority over TVA

WHY

TVA is committed to:

Preventing actual and perceived conflicts of interest and maintaining public confidence in the integrity of TVA programs and activities.

HOW

Any TVA employee who is a former employee of a Federal agency having regulatory authority over TVA shall be subject to the following limitations on his or her duties for TVA:

Such employees shall not represent TVA to his or her former agency, with the intent to influence that agency, on any particular matter involving TVA and their former agency if the employee was personally and substantially involved in the particular TVA/agency matter while working for their former agency.
For two years after termination of employment with their former agency, such employees shall not represent TVA to their former agency, with the intent to influence that agency, or any particular matter involving TVA and their former agency if the employee knows or reasonably should know the particular TVA/agency matter was actually pending under the employee's official responsibility within one year before termination of employment with their former agency.
For one year after leaving their former agency, such employees designated by their former agency as one of its “Senior Employees” for purposes of 18 U.S.C. sec. 207 may not represent TVA to their former agency, with the intent to influence that agency, on any matter.

For the purpose of applying this policy, “particular matter” means specific rulings, requests, determinations, contracts, issues or disputes that involve TVA and the former agency. It does not include generic issues that had not specifically involved TVA during the employee's former agency tenure.

Exceptions to this practice must be approved in writing by the Chief Executive Officer.

ROLES

Employees

Responsible for ensuring that limitation of duties requirements are met and for avoiding potential and/or actual conflicts of interest.

Supervisors

Responsible for ensuring that limitation of duties requirements for employees under their supervision are met and for avoiding potential and/or actual conflicts of interest.

Human Resource Representatives

Answer questions from employees related to employment of former employees of government agencies having regulatory authority over TVA.
Ensure employees and hiring supervisors are aware of these requirements during the hiring process.

Human Resources Information Services

Provides advice to Human Resource Representatives on employment issues in consultation with the Designated Agency Ethics Official staff of the Office of the General Counsel, as appropriate.

Chief Executive Officer

Approves any exception to this practice.

RESOURCES

Human Resources Information Services
Human Resource Representatives

EMPLOYMENT PRACTICE 9

Limitation of Employment Duties of Former Employees of Government Agencies Having Regulatory Authority over TVA

Last Revised 1/2007