Case Study: Sitting Duck

t sure was great getting together with Tucker Arnold again. After all, they'd spent 16 years in the same agency, sometimes at adjoining desks. Before Tucker retired, they had spent two years as assistant directors of the Business Support Bureau. They had weathered many reorganizations, special projects and other crises side by side.

Charlie Grimm's best memories after his move east to head up a bureau division in Washington were of skiing vacations with Tucker and his family, and hunting and fishing expeditions, just the two of them.

And now Arnold had moved on, taking an early retirement from the downsizing bureau to join the New York headquarters of Walker-Reese Enterprises as director of business analysis. Grimm missed Arnold. The latest reorganization had left him supervising the remnants of Arnold's last fiefdom in addition to his own work, and the staff didn't exactly exude camaraderie. Off the job, Grimm couldn't persuade any of his friends to join in the pleasures of rising early for a bumpy ride to stalk game.

So it was a pure delight to hear from Arnold when he called to say he was coming to Washington on business. They met for lunch and brought each other up to date on their diverging executive lives. Grimm was most interested to hear about Arnold's adjustment to New York and the demands of corporate-level management in the private sector. He was glad to learn that his friend's responsibilities would likely bring him to the nation's capital several times a year for contacts with federal agencies and trade organizations, although neither of them could envision any reason he would deal with the bureau.

It wasn't more than two weeks later that Arnold called again with really good news.

"So you thought your hunting and fishing career was over? Well, I just found out that Walker-Reese has a hunting lodge on the Eastern Shore," Arnold said. "Execs are invited for the opening of the duck season next month, and we can each bring a friend. Are you game, old buddy?"

It was too good to be true. Arnold's ethics training sent up an initial red flag about benefits from an industrial or commercial organization. But the bureau's workforce was almost exclusively civil service, the agency had no major contractors, and the few modest service contracts it had were not likely to be of interest to manufacturing and trading giant Walker-Reese. Moreover, Arnold recalled the ethics rules made allowances for benefits clearly arising from a family or personal, rather than business, relationship. His friendship with Tucker Arnold was certainly well known.

So, in no more time than it took to make that analysis and to check his calendar, Grimm enthusiastically accepted the invitation. Counting down the days, he could practically feel the chill of the duck blind. And then came the tiniest suggestion of a potential spoiler. A brief item in the business section of the newspaper said Millennium Business Systems, his organization's service contractor, was being acquired by-of all conglomerates-Walker-Reese Enterprises.

He knew Tucker Arnold well enough to be sure that his friend had nothing to do with the acquisition. He calculated the distance between the corporate director of business analysis in New York and a small subsidiary in the Washington suburbs. Then, too, Grimm was not a source selection official, but he supposed he would have something to say about the contractor's payments and contract renewals.

Everyone knew of his friendship with Arnold. But would that help or hurt? Could Arnold recuse himself from any future considerations of Millennium's services or would a suspicion of impropriety linger once he had enjoyed the hospitality of their corporate owner? Should he cancel his hunting trip? Maybe Frank Edwards, the agency ethics official, could give him a quick response.

Editor's Note: Government Executive asked three commentors whether Grimm needs the advice of the ethics officer on the impact of the Millennium acquisition on his hunting date; whether he needs to assure himself that Arnold is unconnected to the acquisition and Millennium's future success; and what he should do about future dealings with Millennium. Their responses are listed in the left-hand column of this page.

David Hornestay, a Washington-area consultant, served in government for more than 30 years, primarily in human resources and institutional management. He also writes for FPMI Inc.