me and the administration. In view of this situation I think it would be better if I returned to my engineering firm, and I, therefore, ask that you accept my resignation, effective immediately.

As you know, I came to Washington with no thought of private gain, but only in the hope that I might be of some service to the Government. I regret that circumstances now make it inadvisable for me to continue that service.

Sincerely yours,

Hon. PETER A. STROBEL,

P. A. STROBEL,

Commissioner of Public Buildings.

NOVEMBER 8, 1955.

Commissioner, Public Buildings Service, Washington, D. C.

DEAR MR. STROBEL: I have your letter of November 8 submitting your resignation as Commissioner of Public Buildings. Your resignation is accepted with regret, for you brought to the Public Buildings Service a high professional competence and experience that has been of great benefit in the work of PBS. You have served during a very important period and have contributed immeasurably to the lease-purchase program which has been most beneficial to all concerned. I am deeply appreciative of your cooperation and help.

I understand your decision to resign is motivated by considerations of loyalty to the administration. I believe that decision was the wise one under the circumstances and commend you for your fine attitude. My good wishes go with you.

Sincerely yours,

EDMUND F. MANSURE, Administrator of General Services.

Re Peter A. Strobel.

Hon. EMANUEL CELLER,

GENERAL SERVICES ADMINISTRATION, Washington 25, D. C., November 22, 1955.

Chairman, Committee on the Judiciary,

House of Representatives, Washington 25, D. C.

DEAR CONGRESSMAN CELLER: In your letter to me of the 4th, you requested that I answer, on or before the 22d, each of the questions set forth therein about the activities of Mr. Peter A. Strobel while he was Commissioner of Public Buildings. In the main, these questions relate to whether or not Mr. Strobel, in specific detailed instances, did or did not violate the GSA Standards of Conduct or otherwise act improperly in the performance of his duties.

You asked that the questions be answered not only in the light of general principles of propriety which are applicable to all Government employees but also in the light of the GSA Standards of Conduct which are required to be adhered to by all GSA employees as a condition of employment.

The most serious penalty which could be inflicted administratively for a violation of our Standards of Conduct would be dismissal, if found to be warranted after full administrative investigation and hearing. As we informed you at the time, Mr. Strobel resigned on November 8 from the position of Commissioner of Public Buildings. His resignation was accepted on the same date. Therefore, answers to the questions no longer are material to administrative disposition of the matter. However, you have advised that the committee nevertheless desires specific answers to the questions.

You asked me similar questions when I testified during the hearing. As pointed out in your letter, I declined to give my opinion during the hearing in answer to the questions because I did not know about the activities of Mr. Strobel as brought out during the hearing until they were so brought out, and I did not hear all of the testimony.

I approved Mr. Strobel retaining his financial interest in his private engineering firm when he assumed the duties of Commissioner of Public Buildings, but it was expressly understood that he had relinquished active management of his firm. An investigation of his background conducted by GSA before he took office, disclosed that Mr. Strobel was eminently well qualified for the position and was a man of high moral character. I did not know about his continued activities

in behalf of his firm while he was Commissioner of Public Buildings until they were disclosed at the hearing. There was no way I could have known about these activities unless they were brought to my attention by Mr. Strobel or someone else. I would not have approved such activities if I had known about them.

Neither did I know about his activities as Commissioner of Public Buildings in regard to the Petroff or the Ferrenz and Taylor matters, nor did I know that these companies were clients of Mr. Strobel's private engineering firm nor did I know that he had had private business relations with Robert & Co. until this information was disclosed at the hearing.

Concerning Mr. Strobel's failure to submit to me a list of the clients of his private concern in response to official requests, it should be understood that such list was requested not to embarrass Mr. Strobel but to protect him from criticism. Had that list been furnished, we would have screened all proposed GSA contracts against it and when it was thus disclosed that GSA was about to enter into a contract with a client of Mr. Strobel's private engineering firm, Mr. Strobel would have been disqualified from participating in the negotiation, award, or execution of such contract.

In all fairness it must be said that the official record which forms the basis for my answers to your questions contains no affirmative evidence that Mr. Strobel deliberately intended to commit any breach of ethics or integrity, nor is there any evidence that Mr. Strobel deliberately intended to exercise any undue influence or in any manner to use his official position for private gain.

Will endeavor to express my opinion in response to each of your questions on the basis of the information gained from a review of the record and in the light of the foregoing general comments.

Concerning the Petroff matter, you ask:

Question 1. Was it proper or improper for Mr. Strobel when Commissioner of Public Buildings to have recommended Mr. Petroff, a regular and activeclient of Strobel & Salzman to do the work for the Public Buildings Service job in New York City? Was this a violation of the GSA Code of Ethics?

Question 2. Was it proper or improper for Mr. Strobel when Commissioner of Public Buildings to have inferred to Mr. Lawton that he (Mr. Lawton) was to do business with Petroff and not with any other firms? Was this a violation of the GSA Code of Ethics?

Answer. I feel that Mr. Strobel was motivated by his concern for the Government's interest in this instance and acted as he did only to assure speedy action. I do not regard his actions in this instance as improper-they may have been unwise. I would not consider them as in violation of our Standards of Conduct. Question 3. Was it proper or improper for Mr. Strobel not to have advised officials of GSA at the time, that Petroff was a regular and active client of Strobel & Salzman? Was this a violation of the GSA Code of Ethics?

Question 4. Was it proper or improper for Mr. Strobel not to have disqualified himself under the circumstances? Was this a violation of the GSA Code of Ethics?

Answer. These actions were improper and in violation of our Standards of Conduct.

Concerning the Ferrenz & Taylor matter, you ask:

Question 1. Was it ethical for Mr. Strobel when serving as Commissioner of Public Buildings to solicit business for his private firm from an architectural concern that might be interested in getting business from the Public Buildings Service? Was this proper or improper? Was this a violation of the GSA Code of Ethics?

Question 2. Was it a violation of GSA's Code of Ethics for Mr. Strobel, the Commissioner of Public Buildings, to solicit business for his private firm without getting specific approval therefor from GSA officials in accordance with section 4 of this code?

Answer. These activities did not measure up to the principles of ethics prescribed in our Standards of Conduct and, therefore, would be regarded as improper.

Concerning submission of a list of architects to CIA, you ask:

Question 1. Was it proper or improper for Mr. Strobel as Commissioner of Public Buildings to have participated in preparing a list of 14 "outstandi architects" for the CIA, which included a number of firms which had b relationships with Strobel & Salzman? Was this a violation of the GSA Ethics?

Question 2. Was it a violation of the GSA Code of Ethics for Mr. Strobel as Commissioner of Public Buildings to have participated in preparing a list of 14 "outstanding architects" for the CIA, a number of whom had business relationships with Strobel & Salzman?

Answer. Considering the status of the matter at the time the list was submitted, and since the extent of Mr. Strobel's participation in the selection of the names included in the list is not entirely clear from the record, I would not regard these actions as clearly improper or in clear violation of our Standards of Conduct.

Question 3. Was it proper or improper for Mr. Strobel, as Commissioner of Public Buiddings, to have participated in the preparation of this list without making known the fact that a number of the firms included were at the very time clients of Strobel & Salzman? Was this a violation of the GSA Code of Ethics?

Question 4. Was it proper or improper for Mr. Strobel, as Commissioner of Public Buildings Service, not to have disqualified himself under the circumstances in the preparation of this list of "outstanding architects"? Was this a violation of the GSA Code of Ethics?

Answer. These actions were improper and in violation of our Standards of Conduct.

Concerning the Robert & Co. matter, you ask:

Question 1. Was it proper or improper for Mr. Strobel, as Commissioner of Public Buildings, not to have informed the GSA Administrator of the business relationships between Robert & Co. and Strobel & Salzman? Was this a violation of the GSA Code of Ethics?

Question 2. Was it proper or improper for Mr. Strobel, as Commissioner of Public Buildings, not to have disqualified himself from participating in any way in the negotiation of a contract with Robert & Co. in view of its business relationship with Strobel & Salzman? Was this a violation of the GSA Code of Ethics? Answer. As I testified, I consider that I, and not Mr. Strobel, made the decision to contract with Robert & Co. in this instance. Mr. Strobel should have told me of his former business dealings with the company. His failure to do so was in violation of the spirit, if not the letter, of our Standards of Conduct. Concerning the Corps of Engineers contract, you ask:

Question 1. Was it proper or improper for Mr. Strobel to fail to have notified the Corps of Engineers prior to its execution of this contract with Strobel & Salzman in May 1954 that he had assumed a full-time Government position on April 1, 1954?

Question 2. Was this a violation of the GSA Code of Ethics?

Answer. While I think Mr. Strobel should have notified the Corps of Engineers when he assumed duty with the Government, his failure to do so was not a violation of our Standards of Conduct.

Also, you ask for my answer to the following additional questions:

Question 1. Was it a violation of the GSA Code of Ethics for Mr. Strobel, Commissioner of Public Buildings, not to have notified GSA officials that he was engaged in outside business activity on behalf of Strobel & Salzman?

Answer 1. Yes.

Question 2. Was it a violation of the GSA Code of Ethics for Mr. Strobel, Commissoiner of Public Buildings, not to have secured approval of GSA officials to engage in outside business activities on behalf of Strobel & Salzman?

Answer 2. Yes.

Question 3. In light of the testimony presented, was Mr. Strobel being entirely forthright when he informed the GSA Administrator prior to assuming his Government post, and again on December 27, 1954, that he had relinquished all active participation in the management of Strobel & Salzman?

Answer 3. No.

Question 4. Was it proper or improper for Mr. Strobel not to have informed the GSA Administrator that he would continue to seek clients for Strobel & Salzman after becoming Commissioner of Public Buildings?

Answer 4. It was improper.

Question 5. Was Mr. Strobel's action proper or improper in declining to sign the GSA Standards of Conduct Statement on December 20, 1954, when requested to do so by the GSA Officer of Compliance?

Answer 5: Since Mr. Strobel did sign the form on December 27, 1954, I would not regard the fact that there was some delay in the signing as of major importance.

Question 6. Was Mr. Strobel's action proper or improper in declining on December 27, 1954, and again on August 9, 1955, to permit the GSA Office of Compliance to obtain a list of clients of Strobel & Salzman?

Answer 6. Mr. Strobel was under no obligation to permit our investigators to examine his private firm's books, but he should have made the list available himself when he was first requested to do so.

Question 7. Whether all GSA employees are required, upon assuming employment, to sign and certify that they will adhere to the GSA Code of Ethics as a condition of employment?

Answer 7. All employees, as a condition of employment, are required to comply with our Standards of Conduct. It has only been since the early part of August 1954, however, that all employees are required to certify that they have read and are familiar with our Standards of Conduct.

Question 8. Why Mr. Strobel was not required upon assuming Government employment to sign and certify that he would adhere to the GSA Code of Ethics as a condition of employment?

Answer 8. See the answer to question 7, above.

Question 9. Why Mr. Strobel was not required to sign and certify to the GSA Code of Ethics until almost 10 months after his employment?

Answer 9. In view of the answer to question 7, it is apparent that the delay was 5, not 10 months. During that time, we were in the process of having thousands of the forms signed and it was not until about the first of December that his failure to sign came to my attention. He did sign on December 27, 1954.

Question 10. Whether there has been any conflict-of-interest resulting from Mr. Strobel's private activities on behalf of Strobel & Salzman?

Answer 10. The evidence adduced at the hearing would seem to indicate a violation of our Standards of Conduct concerning conflict between private interests and official activities.

Question 11. Whether Mr. Strobel's continuing relationship with Strobel & Salzman has been compatible or incompatible with his governmental duties as Commissioner of Public Buildings?

Answer 11. Incompatible.

I trust that the foregoing will be sufficient for your purposes.

Cordially yours,

(Signed) EDMUND F. MANSURE, Administrator.

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