Before detailing this event, it would appropriate to review a couple of previous discussions in this blog. First, the USEPA is a government agency and as you may recall doing business with the government, the contracting firm must have an ethics program in place which among other things meets the guidelines termed the Federal Sentencing Guidelines. These seven guidelines are detailed in this blog and also can be reviewed in the Federal Acquisition Guidelines.
In this report from the USEPA it was noted that during the tenure of Lisa Jackson as the presidential appointed leader maintained a separate email account under the name of Richard Windsor to be used by environmental activists and Obama administration officials. To be sure, senior managers in large organizations use multiple email accounts for various reasons; however, very rarely using a fictitious name.
Lisa Jackson then created completed certification courses for the fictitious Mr. Windsor, perhaps to maintain the email account. Basically, a nonexistent employee completed courses and examinations including management of email records for an account belonging to Lisa Jackson.
Lisa Jackson publicly defended her position blaming it on her anger with the way politics are played.
USEPA is a federal agency and those who do business with it must have a code of ethical conduct. This code must meet the following metrics:
1. Does the program have compliance standards and procedures in place that can reasonably reduce the prospect of criminal conduct?
2. Does the program assign high level personnel to oversee compliance?
3. Does the program avoid placing people in responsible positions that they know or should have known have a propensity to engage in illegal activities?
4. Does the program communicate the standards and procedures through training and other mechanisms?
5. Has the program established monitoring, auditing, and reporting systems where employees can report criminal conduct without fear of retribution?
6. Does the program enforce the standards including discipline of individuals for failure to detect and report offenses?
7. Does the program have appropriate responses in place to respond and prevent future occurrences and modifies existing standards and procedures accordingly?
How many of these requirements are violated in the events detailed above? Unethical conduct in high places fosters lack of respect for rules in the workplace - federal as well as private sector - and the hypocrisy in demanding high standards while failing to adhere to them has a very negative multiplying effect.
“The government is the potent omnipresent teacher. For good or ill it teaches the whole people by its example. Crime is contagious. If the government becomes a lawbreaker, it breeds contempt for law; it invites every man to become a law unto himself; it invites anarchy. To declare that the end justifies the means -- to declare that the government may commit crimes -- would bring terrible retribution.” Louis Brandeis
Before you write all this off as “anger with the way politics are played” consider the following, Lisa Jackson now is the environmental and compliance director at Apple computer reporting directly to Tim Cook.