time attention, and as I said before, there have been long periods where I have not paid any attention to the firm's affairs. However, that does not mean to say that I want to claim that I am not paying any attention to the affairs because I am. Mr. MALETZ. I see. But do you state now that you have relinquished all active participation in the management of Strobel & Salzman? Mr. STROBEL. I would say so, yes, sir, because Mr. MALETZ. In spite of the various activities which you have indicated you performed on behalf of Strobel & Salzman? Mr. STROBEL. Well, that is a question of opinion. Mr. MALETZ. Very well. Mr. STROBEL. But the active management of the office, like that, concerning Mr. MALETZ. You are referring, then, I would assume, to the active day-to-day management of Strobel & Salzman? Mr. STROBEL. There are so many phases of work that Mr. MALETZ. Yes. Mr. STROBEL. I possibly could not pay the least attention to, and that, for instance, would be the daily production and the quality of work as it is turned out. There are great responsibilities tied in with the type of work that we are doing. We must be licensed to do that type of work, and we have responsibility for corrections. So the active management deals with quality performance of engineering work, and then also to get production so that the office makes money. The CHAIRMAN. Would you call the prosecution of a claim for Strobel & Salzman before the Corps of Engineers participation in work of Strobel & Salzman? Mr. STROBEL. I suppose it could be classified as such; yes, sir. Mr. MALETZ. Now, Mr. Strobel, are you familiar with the standards of conduct statement which is required to be signed and certified to by all GSA employees? Mr. STROBEL. Right. Mr. MALETZ. You are familiar with that? Mr. STROBEL. Yes. Mr. MALETZ. Now, Mr. Strobel, I read from the preamble of the standards of conduct statement: When an individual accepts employment with the Government, he assumes responsibilities over and above efficient and loyal performance of his assigned duties. In the eyes of the public, his general conduct, both at work and at home, becomes a part of the reputation of the Government itself. Accordingly, it is the policy of the General Services Administration that its employees shall be required, as a condition of their employment, to comply with the standards of conduct set forth below. 1. Ethics. In all their dealings, employees shall so conduct themselves as to permit no possible basis for suspicion of unethical business practices. The obligation to protect fully the interests of the Government demands the avoidance of circumstances which invite conflict between self-interest and integrity. I take it you agree with these general statements? Mr. STROBEL. Right. Mr. MALETZ. Is that right? Mr. STROBEL. Correct. Mr. MALETZ. Now, Mr. Strobel, section 4 of the standards of conduct reads as follows: The Director of Personnel in the central office and regional directors in regional offices are authorized to approve or disapprove requests to engage in outside employment. Except upon prior written approval of such official, or other official to whom approving authority has been redelegated, employees shall not engage in any outside employment or business activity, and in no instance shall approval be granted where such employment will involve conflict with Government interests. You are familiar with that statement, I take it? Mr. STROBEL. Right. Mr. MALETZ. Now, did you secure approval from anyone in GSA to engage in outside business activity? Mr. STROBEL. As I mentioned before, the Administrator was familiar with my interest in Strobel & Salzman. Mr. MALETZ. Did you secure the specific approval of the Administrator to engage in outside activity? Mr. STROBEL. No; no, not if you refer to a specific item. Mr. MALETZ. Now, is it not true that you first declined to sign this standards of conduct statement? Mr. STROBEL. No, I did not decline. I had that conduct statement form on my desk for quite some time, because I could not sign the statement just as it is, and part of which you have read. I did sign it December 27, 1954, but I made reservations to my signature. Mr. MALETZ. Do you recall The CHAIRMAN. What was the last, Mr. Strobel? Mr. STROBEL. I beg your pardon. I made reservations to the signature. The CHAIRMAN. You made reservations? Mr. STROBEL. And I attached a memorandum pointing out the fact that I wanted it understood that I do have private interests outside of Government. Mr. KEATING. Do you have a copy of that memorandum? Mr. STROBEL. Yes, sir. Mr. ROBB. Yes, sir. Mr. MALETZ. May I suggest that it be put in the record. Mr. KEATING. Yes. I think it would be helpful to have it. Mr. MALETZ. While Mr. Robb is checking for the statement, may I ask you this: Did you have a discussion with Mr. John Strawser, administrative officer of the Public Buildings Service, concerning the signing of this standards-of-conduct statement on or about December 20, 1954? Mr. STROBEL. I do not recall. It is possible that he might have talked to me about it. The CHAIRMAN. Just a minute. Mr. Robb has that statement? Mr. ROBB. I have here that paper. The CHAIRMAN. Do you mind if we put that in the record? Mr. ROBB. I think it would be helpful, Mr. Chairman. Make sure that it is the one Mr. Strobel is talking about. Mr. STROBEL. That is the one, with my note here. The CHAIRMAN. What were the reservations that you put in here? Mr. STROBEL. I beg your pardon? The CHAIRMAN. What are the reservations you made? Mr. STROBEL. At the bottom I said, "See memorandum re paragraphs 4 and 6." And then I attach this memorandum, which is to the director of personnel: STANDARDS OF CONDUCT On December 27, 1954, I signed the standards-of-conduct certification with the following note: "See memorandum re paragraphs 4 and 6." As a matter of record, I want it understood that I have outside interests in the firm of Strobel & Salzman, consulting engineers (partnership), of New York City, as well as real estate and farm investments. Strobel & Salzman will not directly or indirectly do any Government work connected with the functions of the General Services Administration. It is also a matter of record that I have relinquished active management of the firm of Strobel & Salzman. That is dated December 29, 1954. (The standards-of-conduct statement and memorandum referred to are as follows:) Director of Personnel, MP. Commissioner of Public Buildings. Standards of conduct. DECEMBER 29, 1954. On December 27, 1954, I signed the standards-of-conduct certification with the following note: "See memorandum re paragraphs 4 and 6." As a matter of record, I want it understood that I have outside interests in the firm of Strobel & Salzman, consulting engineers (partnership), of New York City, as well as real estate and farm investments. Strobel & Salzman will not directly or indirectly do any Government work connected with the functions of the General Services Administration. It is also a matter of record that I have relinquished active management of the firm of Strobel & Salzman. (Signed) P. A. STROBEL. 69220--55--3 GENERAL SERVICES ADMINISTRATION STANDARDS OF CONDUCT [ When an individual accepts employment with the Government, he assumes responsibilities over and above efficient and loyal performence of his assigned duties. In the eyes of the public, his personal conduct, both at work and at home, becomes a part of the reputation of the Government itself. Accordingly, it is the policy of the General Services Administration that its employees shell be required, as a condition of their employment, to comply with the standards of conduct set forth below. 1. ETHICS. In all their dealings, employees shell so conduct themselves as to permit no possible nasis for suspicion of um athical business practices. The obligation to protect fully the Interests of the Government demands the avoidance of circumstances which invite conflict between self-interest and integrity. 2. SAFEGUARDING INFORMATION. Adequate machinery has been established for the proper dissemination of timely infermation to all interested parties in a fair and equitable manner. The unauthorized or premature disclosure of information or confirmation of publicly stated opinion relating to the operations of this Administration is prohibited. The use of information acquired es an incident to employment with this Administration for the purpose of furthering any nongovernmental interest also is prohibited. 3. PLACE OF BUSINESS. Unless expressly authorized by his superior, an employee shell not conduct any Government business, discussions, or negotiations, relating to matters of comcern to this Administration, except on Government premises, er, when necessary, at other proper places of business. 4. OUTSIDE EMPLOYMENT. The Director of Personnel in the Central Office and Regional Directors in regional offices are authorized to prove or disapprove requests to engage in outside employment. Except upon prior written approval of such official, or other official to whom approving authority has been redelegated, employees shall not engage in any outside employment or business activity, and in no instance shall approval be granted where such employment will involve conflict with Government interests. Employees shall not accept remuneration in any form from nongovernmental sources for the performance of official duties whether the time expended is a part of the nermal working period, overtime, or off-duty hours. 5. FAVORITISM Preferential treatment shall not be accorded any person, firm, corporation, or other entity, in the conduct of official business. ✓ & OUTSIDE CONNECTIONS. Each employee shall submit to his Immediate superior a report of outside connections, listing all 7. GRATUITIES. GSA employees shall not accept any gratuity or faver of any nature whatsoever, directly or indirectly, from any person, firm, corporation, or other entity, which has done, is doing, or proposes to do business with this Administration. Tentative or firm offers of money or other considerations, such es offers of future employment, which are made to influence official action, would, of course, constituté attempted bribary, ● Federal criminal offense. & FORMER EMPLOYEES. All transections with this Administre tion in which any former employee of GSA or any of its predecessor agencies or components is involved, in the capacity of principal, agent, representative, trustee, or attorney, shell be referred to the Director of Compliance in the Central Office or to the Compliance Division representative in a regional office. 9. GSA-EMPLOYEE TRANSACTIONS. Employees shall not participate in business transactions with this Administration, either directly or indirectly, as principal, agent, trustee, representative, or attorney. This prohibition includes, but is not limited to, purchases of personal and real property, leeschelde, and procurement contracts. 10. REPORTING OF IRREGULARITIES. It is the obligation of each employee to repert Immediately any apparent or suspected imegu arity coming re his attention in connection with any operation of this Administration. Such report shall be made to the Director of Compliance, Central Office, or to the Compliance Division representative in the regional affice. 11. INTERMEDIARIES. In all relations with the public, employees are prohibited from recommending or suggesting the use of any nongovernmental Intermediary (individual, firm, corporation, or other entity) offering any service as consultent, agent, representative, attorney, expeditor, or specialist, for the purpose of assisting in any negotiations, transections, or other business with this Administration. 12. MEETING FINANCIAL OBLIGATIONS. All employees of the Administration are expected to meet their just obligations. GSA employees are required, as a condition of continuing omployment, to make prompt payment of Federal Income tax. 13. MONEY LENDING. The making of loans to a fellow Government employee or to anyone else on Government promises, at any rate of interest, renders GSA employees subject to dismis sal. This prohibition does not apply to those employees of the Administration assisting in the regular operations of the GSA Credit Union. 14. GAMBLING. Gambling in any form on Government promises is prohibited. 15. USE OF INTOXICANTS. Intoxicants shell not be used or com sumed on leased or Government-owned premises under GSA supervision. Any employee found using or under the Influence of intoxicants while at work will be subject to disciplinery ection. 16 REFUSAL TO TESTIFY. Refusal on the part of a GSA on ployee to testify before a congressional committee on the ` of possible self-incrimination, or testifying but invoking constitutional privilege during such testimony, constitutes a basis for dismissal. CERTIFICATION I hereby certify that I have read the complete text of the General Services Administration Standards of Conduct, and that I am familiar with the provisions contained therein. See memo 50 H-3078 Ons. GSA FORM 1179 JULY 1954 Mr. RODINO. And when did you become Commissioner? Mr. MALETZ. You do not recall a meeting with Mr. Strawser in which you were asked to sign the standards-of-conduct statement? Mr. STROBEL. No. As I said before, it is possible, that he had been talking to me. He generally talks to me several times a day, right along. So I can't say that I remember that specific conversation. Mr. MALETZ. Do you recall Mr. Strawser telling the Office of Compliance of GSA that you gave no reason whatsoever as to why you would not sign the standards-of-conduct statement? Mr. STROBEL. It never occurred to me that I would not sign it. I could not sign it without the reservations as I have now made them of record. Mr. MALETZ. Have you ever specifically obtained approval from anybody in GSA to engage in these outside activities? Mr. STROBEL. There are no written documents stating just that. Mr. RODINO. Did you make that reservation as a result of conversation with some person in the Administration? Mr. STROBEL. No, sir. Mr. RODINO. Was it as a result of some counsel by your attorney? Mr. STROBEL. Are you referring to this reservation? Mr. RODINO. This reservation on the standards of conduct. Mr. STROBEL. No. That reservation was dictated by me because they wanted the certificate signed, and I consulted nobody on that item. Mr. RODINO. In other words, you consulted with no one but just concluded that you might add the reservation? Mr. STROBEL. That is right. Mr. RODINO. And if it were acceptable, O. K.? Mr. STROBEL. That was exclusively my own idea of establishing that particular reservation. Mr. FINE. You were asked a moment ago whether or not you had any approval of the GSA to continue your outside business, and your answer was that there was no written document. Mr. STROBEL. That is right. Mr. FINE. But you did indicate earlier, I believe, that you did speak to Mr. Mansure Mr. STROBEL. I beg your pardon? Mr. FINE. That you did tell Mr. Mansure orally Mr. STROBEL. That is correct. Mr. FINE. When you first took the position? Mr. STROBEL. That is correct. Mr. FINE. When you came down as consultant? |