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thorities set out in other statutes. We haven't been as successful in achieving the results even with the tripled staff in enforcement in the regular civil service area.

Now the direction that we have been going in is first having agencies strengthen their own internal investigative and evaluative capacities, and that they exercise this authority because there are serious questions of jurisdiction of our capacity to do so.

Now a law could be written. I don't think an Executive Order could be because I think that certain statutory responsibilities might conflict with the Executive Order. I think that in order to strengthen the enforcement aspects of the ethics program that the first responsibility belongs on those people who are closest to the problem, and that's the agency head or whoever he delegates the authority to. I think that if we had an authority to review that action for its effectiveness and could recommend alternate courses of action, this might be the best way to do it, or the other way is for CSC to have the investigative authority and recommend remedial actions but still leave it up to the agency head under authority vested in him in the law to take the final action. This would involve a resource implication which I have found very difficult to get when it comes to strengthening evaluation and investigation.

Mr. JOHNSON. You say there are 70 agencies. Have they all, under this Executive Order, filed a set of regulations with you that they have adopted internally within the agency?

Mr. HAMPTON. To the best of my knowledge, they have all filed with the office of the general counsel a regulation. That's the newly established agencies. I don't think there are any

Mr. GOODMAN. I don't know of any that have not. Not each agency has its own regulations. The smaller agencies are permitted to adopt wholesale Part 735 of those Federal regulations as their agency regulations after coming to the Commission and requesting that, but I don't know of any agencies that have not filed with us.

Mr. JOHNSON. I think I have time for one more question. Mr. Goodman, I notice you mention the fact that NASA has addressed themselves to this situation where all of us are invited to the receptions given by nationwide associations. Right now, starting right away in Washington, every congressional office is just swamped with invitations to attend these lovely receptions given by national associations. We try to go to some of them because some of the heads of these organizations are friends that you have met over the period and they love to have Members of Congress attend these receptions.

Do you take the attitude that perhaps even a Member of Congress attending one of these national receptions that will be given between now and July 1 is an impropriety, let's say, or did NASA properly address it and say, you can attend, providing it is a national association

Mr. GOODMAN. I wouldn't want to presume to indicate what Members of Congress should or should not do in this area. I think that the NASA regulations do allow certain attendance where you have these functions sponsored by the national association and not by a particular company. I think the problem is viewed as one of dealing with a particular company rather than the overall association. With the overall association I guess you still have the competitive aspects. If you have the particular company I think that's where the problem arises. I take it that's why the NASA regulations deal with it in the manner that they do.

Mr. JOHNSON. Would you say that same regulation prevails in all the other 70 agencies, that it's all right for personnel to attend receptions of national associations?

Mr. GOODMAN. I don't think the same regulations apply in all the other agencies. In fact, the regulations that do apply in the other agencies are probably somewhat broader and more liberal than the NASA regulations. The NASA regulations were just recently amended to narrow the scope of attendance.

Mr. JOHNSON. Thank you. My time is up.
Senator PROXMIRE. Senator Sparkman.

Senator SPARKMAN. Mr. Chairman, let me say that I have enjoyed very much hearing the statements of both of these gentlemen. It seems to me that there must be quite a tangled affair trying to keep up with these regulations where the services issue these regulations and then each department or agency can issue regulations. It seems to me that inevitably you would run into a conflict of regulations even among the various agencies. Why could not the Civil Service Commission issue regulations that would be applicable to all Government agencies and departments across the board?

Mr. HAMPTON. Senator Sparkman, right now we couldn't because we don't have the authority to. The Executive Order spelled out that each agency would issue its regulations under general guidance that we give-I would say that it would be possible to have a central government regulation in this area and one of the purposes of 11222 was to achieve a certain degree of consistency on what was perceived to be the major issues, and the agencies then could reguÎate in terms of their specific requirements. But the way I see situations developing in our country, they are much different than they were in 1965, and I think all for the good, and it may be possible and certainly through the kind of regulatory process that we go through in issuing regulations we normally would make a draft of a regulation; we would consult with all interested parties and get their input; and then we analyze what these various parties have to say and then come out with a final regulation. I think it would be a possibility, but under the present Executive Order we have no authority to do it.

Mr. GOODMAN. Let me note that the chairman is right. Under the present Executive Order the agencies are specifically directed to issue regulations. This is a kind of historical situation. Under the Executive Order that you had in 1961 there was in fact no central coordinator at all. That created problems almost immediately in terms of what agencies were doing and in that regard the Civil Service Commission attempted to get together with various agencies to try and coordinate what was going on.

One of the purposes of Executive Order 11222 was to try and centralize in one place at least the reviewing function for the regulations so that we wouldn't have that inconsistency. But the Executive Order is quite clear in leaving in the agencies responsibility to issue regulations and I think one of the reasons for that was a feeling that there might be different concerns depending upon the agency that you're involved with. For example, if you have one agency which is a major defense contracting agency, you might have different concerns in terms of the types of regulations you would have than you would have if you had an agency that was not a regulator or a major contractor. I think that's why it was left with the agencies. But, of course, it would be possible to have one set of regulations that would apply government-wide.

Senator SPARKMAN. Your agency's work, then, is primarily advisory?

Mr. GOODMAN. Advisory. We have approval authority in the sense that if an agency sends us regulations which we feel are out of line with the Executive Order pre will not permit them to make those modifications and changes. Basically, it's an advisory role except when you get to the financial statements parts of the program. There, the role is substantially more than advisory. We can, in fact, go to the White House. Our role is also a bit of a cajoling role. We give advice. Most of the time our advice is accepted. So it's an advisory role. We like to think that sometimes our advice is heeded and I think it is.

Senator SPARKMAN. Thank you, Mr. Chairman.
Senator PROXMIRE. Congresswoman Sullivan.
Mrs. SULLIVAN. Thank you, Mr. Chairman.

I have two very brief questions that I would like to ask either the counsel or you, Mr. Hampton, to follow up on Senator Proxmire's first comment.

Since the Executive Order was first issued as far back, I believe, as 1961, has there been any action or any discussion of the regulations to the various agencies by the Civil Service Commission in regard to standards of conduct regulations prior to last fall's hunting lodge disclosures

Mr. GOODMAN. I think the answer to that is yes. Let me note, Mrs. Sullivan, that the original Executive Order was issued in 1961. The Civil Service Commission was in fact, as I guess you would say, the instigator, if you will, of the amendments to the Executive Order which then became Executive Order 11222. But approximately, a year ago we hired a full-time attorney to act as ethics counselor in my office. We began at that point to have contacts with the various agencies involved and to try and get a dialog going between the ethics counselors at the agencies and ourselves as to modifications, changes that might be required in the ethics area. So I think the answer to the question would be, yes, there were discussions before last fall.

Mrs. SULLIVAN. And you, as counselor, have advised the counsels of these other agencies as to procedures?

Mr. GOODMAN. I have met with them. The ethics counselor of our agency has met with them. We have an ongoing relationshin with them. We are hopeful that that relationship has not only heightened their awareness of the ethics program but has also resulted in feedback both ways as to perhaps ways of strengthening the program.

Mrs. SULLIVAN. Was there any discussion at those times about invitations to people who have the responsibility of letting contracts?

Mr. GOODMAN. If my recollection is correct, that is not the sort of problem that we have encountered. There was discussion about the question of accepting payments from various organizations, companies, and so forth for people from agencies to go and speak to those organizations and agencies and the question of conflicts of interest involved in that sort of program. There were discussions of that.

Mrs. SULLIVAN. And, Mr. Hampton, if accepting hunting lodge invitations does not violate standards of conduct, what does? What else would be assumed to violate proper standards?

Mr. HAMPTON. Well, I think that it depends all on the circumstances of each individual case. I think in many cases because that's what a conflict is, and it would be hard to generalize and I know Dr. Low in NASA talked to me about their internal investigation and all the difficulties that they were having in ascertaining in each individual case was there a conflict. If there was a conflict, was it a gross conflict or an error of judgment or what? And I think that it really boils down to the application of what is in the rules and regulations in each individual case.

Mrs. SULLIVAN. Is it a question mostly of appearance, rather than of integrity? Is it a form of flattery to agency officials to have been invited to attend such things, feeling that they are only being invited because of themselves, not because of what they represent or the jobs they hold? This has been going on for a long, long time.

Mr. HAMPTON. Would you phrase that question again? Is it a matter of flattery?

Mrs. SULLIVAN. Yes. If agency officials are invited to spend a week or a weekend at a hunting lodge and are entertained lavishly and so forth, would they generally accept this as a flattering idea that they are being invited for their own congenial company and for their own entertainment and not for what that individual represents to the company doing the inviting? That's put rather clumsily, but I think you get the idea.

Mr. HAMPTON. I think it would all depend on the individual and the circumstances and the reasons why they were invited. I think that's a question which should be addressed to those who made the invitation.

Mrs. SULLIVAN. I think any of us who have been up here no more than a year would know that we are not always being sought after just for our personalities.

Mr. HAMPTON. Oh, I agree with that very much. I see that in the numerous invitations that come that I never knew who the person was or what it was about or anything and I know that when you accept an invitation to a dinner and someone stands up to be introduced you wonder then. But I learned that when I was in the White House staff many years ago and I told my wife, I said: "Don't let any invitations go to your head, because the only reason you're being invited is the job that I'm in, and not because of who

you are.

Mrs. SULLIVAN. I think we all know that. One last question : How would you judge your own conduct, Mr. Hampton?

Mr. HAMPTON. Well in the first place, the person who asked me to go hunting was a friend of mine long before North American Aviation ever leased the hunting rights to Wye Island. In fact, we have our own hunting group which rents our own place to hunt. We build our own blinds. We do all of our own work and when my friend's company leased the hunting rights there he asked me and other members of our hunting club to go over there. It was a very personalized thing and I had nothing to do or no way could I help his company and if there had been the slightest hint of that I wouldn't go. I have probably two of the largest contracts in the Government in terms of the insurance industry and I have never even had a cup of coffee with those people.

Mrs. SULLIVAN. Thank you very much.
Senator PROXMIRE. Senator Tower?
Senator TOWER. No questions.

Senator PROXMIRE. Well, thank you very much, gentlemen. We appreciate your testimony.

Our next witness is Mr. Robert Anderson, president of Rockwell International Corp.

Mr. Anderson, we are happy to have you. If you would identify the gentleman who is with you for the record and proceed with your statement. Before you do that, let me go through the formality that is a matter of policy here. Will you rise, gentlemen and raise your right hand!

Mr. Roscia. I am here as counsel but I would be glad to do it. I wasn't appearing as a witness.

Senator PROXMIRE. Will you gentlemen promise to tell the truth, the whole truth, and nothing but the truth, so help you God?

Mr. ANDERSON. Yes, sir.
Mr. ROSCIA. Yes.
Senator PROXMIRE. Go right ahead with your statement.



Mr. ANDERSON. My name is Robert Anderson. I am president and Chief Executive Officer of Rockwell International Corp

Rockwell is a major multi-industry company engaged in automotive, consumer, electronics, industrial and aerospace operations. The company was formed through the merger of North American Aviation, Inc., and Rockwell-Standard Corp. in 1967.

Rockwell's total sales last year were approximately $5 billion, of which about 38 percent were to the Government. This may

be contrasted with total sales of about $2.4 billion, of which about 74 percent were to the Government at the time of the merger.

The company employs about 123,000 people throughout the United States and abroad, of which about 45,000 are engaged in work for the Government.

I am appearing in response to a request from the vice chairman to express our views on certain issues which the Joint Committee is examining. These are corporate policies regarding entertainment and gratuities and contractor hiring of former Federal officials, the

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