, . LO I NATIONAL SCIENCE FOUNDATION 11 OFFICE OF INSPECTOR GENERAL OFFICE OF INVESTIGATIONS CLOSEOUT MEMORANDUM I Case Number: I03110046 Page 1 of 1 I: On 29 October 2003, an NSF employee1contacted NSF's Designated Agency Ethics official2 (DAEO) to discuss a possible conflict of interests. The employee explained that she was serving on a Technical Review panel for a contract. When filling out the annual financial disclosure form she became aware that her husband held stock in one of the companies bidding for the contract. The company's stock is not publicly traded, and her husband's stock was worth approximately $120,000. \ The DAEO advised the employee that she did indeed have a conflict and should recuse herself fiom the panel. The DAEO promptly notified OIG of the possible criminal violation of 18 U.S.C. § 208. We interviewed the employee. She stated that during the course of filling out her annual financial disclosure form she realized that she needed to also include any stock/shares held in any retirement fund. She stated that her husband was a former employee of a privately held companyY3 which had submitted a bid for the contract. She had been aware that he used to work for the company but had been unaware that his retirement account with the company consisted of company stock. She stated that she followed the DAEO's advice and recused herself from the panel and returned all documents. We concluded that because the employee (1) was unaware of her husband's financial interest when she participated in the panel, and (2) followed the DAEO's advice and recused herself from the panel and returned all documents, there is no violation. Accordingly, this case is closed. ' footnote redated footnote redacted footnote redacted NSF OIG Form 2 (1 1/02)
Published by the National Science Foundation, Office of Inspector General on 2003-11-13.
Below is a raw (and likely hideous) rendition of the original report. (PDF)