The CHAIRMAN. But your reservation was that you would not continue any active management of Strobel & Salzman; is that right? Mr. STROBEL. That is right. I resigned from the actual management. You can't be two places at once.

The CHAIRMAN. And that you would have no direct or indirect relations with the General Services Administration?

Mr. STROBEL. That is correct.

Mr. MALETZ. Now, Mr. Strobel, do you recall that on December 27, 1954, you were urged by the Office of Compliance of GSA to permit one of its special agents to obtain a list of Strobel & Salzman's clients by examination of the company records or at least that you yourself submit such a list?

Mr. STROBEL. No, sir, I do not remember such a request at that time. Mr. MALETZ. You do not recall it.

Mr. STROBEL. No, sir. It came a good deal later.

Mr. MALETZ. Do you recall that on August 9, 1955, you were again urged by the special agent of the Office of Compliance to obtain a list of Strobel and Salzman's clients?

Mr. STROBEL. To my recollection, I got the first request for permitting one of his agents to go to the office and obtain the list of clients, I think it was early August or late July.

Mr. MALETZ. Did you permit the agent at that time

Mr. STROBEL. No. I told him that I would handle that myself.
Mr. MALETZ. Do you recall-

Mr. STROBEL. And I later produced the list of clients.

Mr. MALETZ. Now, these requests were made, were they not, to insure that you complied with section 6 of the standards of conduct, which requires every employee of GSA to submit complete information as to his outside connections?

Mr. STROBEL. Well, I would imagine that was the reason.

Mr. MALETZ. Yes. Do you recall that it was not until August 30, 1955, over a year after your Government employment that you submitted to Mr. Mansure personally a list of your clients pursuant to Mr. Mansure's request?

Mr. STROBEL. That is correct. Mr. Mansure had spoken to me about that probably a month earlier. He thought I should get the list in, and I proceeded to make up the list, or have it made up.

Mr. MALETZ. Mr. Chairman, I offer in evidence the standards-ofconduct statement required to be signed by General Services Administration.

The CHAIRMAN. That will be received for the record.

(The standards-of-conduct statement referred to is as follows:)

GENERAL SERVICES ADMINISTRATI ON STANDARDS OF CONDUCT

୮

When an individual accepts employment with the Government, he assumes responsibilities over and above efficient and loyal perform ence of his assigned duties. In the eyes of the public, his personal conduct, beth 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 un-
ethical business practices. The obligation to protect fully the
interests of the Government demands the avoidance of circum-
stonces which invite conflict between self-interest and integrity.
2. SAFEGUARDING INFORMATION. Adequate machinery has
been established for the proper dissemination of timely infor-
mation to all interested parties in a fair and equitable manner.
The unauthorized or premature disclosure of information or con-
firmation of publicly stated opinion relating to the operations
of this Administration is prohibited. The use of information
acquired as an incident to employment with this Administration
for the purpose of furthering ony nongovernmental interest olso
Is prohibited.

3. PLACE OF BUSINESS. Unless expressly authorized by his superior, on employee shall not conduct any Government business, discussions, or negotiations, relating to matters of concern to this Administration, except on Government premises, or, 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 approve or disapprove requests to pngage in out-
side 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 employ-
ment or business activity, and in no instance shall approval be
granted where such employment will involve conflict with Gov-
ernment 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 nor
mal 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.

6. OUTSIDE CONNECTIONS. Each employee shall submit to his
immediate superior a report of outside connections, listing all
personal or financial relationships which he has or formerly
had with any person, firm, corporation, or other entity doing busi-
ness with this Administration or which there is reason to be-
lieve might do any business with this Administration. The em-
ployee is responsible for the current status of this information.
It is the responsibility of the immediate superior, upon receipt
of such report, to forward it through appropriate channels to the
Director of Compliance in the Central Office or to the Compli-
ance Division representative in a regional office. Employees
shall not take final action with respect to any matter in which
such relationship or connection is involved unless specific
written authorization is received from the Director of Compli
ance or the Compliance Division representative.

7. GRATUITIES. GSA employees shall not accept any gratuity or
favor 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

as offers of future employment, which are made to influence official action, would, of course, constitute attempted bribery, Federal criminal offense.

8. FORMER EMPLOYEES. All transactions with this Administro-
tion in which any former employee of GSA or any of its prede-
cessor agencies or components is involved, in the capacity of
principal, agent, representative, trustee, or attorney, shall be
referred to the Director of Compliance in the Central Office of
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, leaseholds, and procurement contracts.

10. REPORTING OF IRREGULARITIES. It is the obligation of each employee to report immediately any apparent or sus pected irregularity coming to 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 office.

11. INTERMEDIARIES. In all relations with the public, employees
are prohibited from ree ammending or suggesting the use of any
nongovernmental intermediary (individual, firm, corporation,
or other entity) offering any service as consultant, agent, rep-
resentative, attorney, expediter, or specialist, for the purpose
of assisting in any negotiations, transactions, or other busi
ness 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 em ployment, 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 premises, 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 premises is prohibited.

15. USE OF INTOXICANTS. Intoxicants shall not be used or consumed on leased or Government-owned premises under GSA supervision. Any employee found using er under the Influence of intoxicants while at work will be subject to disciplinary action.

16. REFUSAL TO TESTIFY. Refusal on the part of a GSA amployee to testify before a congressional committee on the basis of possible self-incrimination, or testifying but invoking canstitutional 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.

Date

GSA WASH DC 55-1163

Signature

GSA FORM 1179

JULY 1954

Mr. KEATING. When were these standards promulgated?

Mr. MALETZ. July, 1954.

Mr. FINE. Is this the same one that he signed with the reservation? Mr. MALETZ. Yes.

Mr. FINE. Why put it in the record, then?

The CHAIRMAN. That will be put in the record for information. Mr. MALETZ. Now, Mr. Strobel, are you acquainted with the architectural firm of Serge Petroff of New York City?

Mr. STROBEL. I am.

Mr. MALETZ. That firm is actually an important client of Strobel & Salzman, is it not?

Mr. STROBEL. That is not exactly the full story, because we are probably a bigger client of that firm than Strobel & Salzman is of him. Mr. MALETZ. Since May, 1953 could you tell us how many contracts Serge Petroff has given Strobel & Salzman?

Mr. STROBEL. No, I cannot.

Mr. MALETZ. I show you a list prepared by Mr. Schwarz, business manager of Strobel & Salzman, which purports to set forth the name of each client for whom Strobel & Salzman has done work since May 1953, the project on which the work was done, and the date the contract was entered into. Now, will you examine this list and tell us whether it is accurate, according to your best information?

Mr. STROBEL. Being made up by the office of Strobel & Salzman, I would assume this is correct.

Mr. MALETZ. Very good.

May I have that list back.

According to this list, on May 20, 1953, Strobel & Salzman was retained by Serge Petroff on the United States Envelope Co. project; on December 1, 1954, Strobel & Salzman was retained by Serge Petroff on the Ortho Pharmacal project; on January 5, 1955, Strobel & Salzman was retained by Serge Petroff for the Ethicon project; on August 31, 1955, Strobel & Salzman was again retained by Serge Petroff for presumably, again, another United States Envelope project; is that correct?

Mr. STROBEL. That is correct, yes.

Mr. MALETZ. Therefore, since May 1953, Strobel & Salzman has been hired by Serge Petroff for four separate jobs; that is correct, is it not? Mr. STROBEL. Right.

Mr. MALETZ. Now, Mr. Strobel, do you recall a conference on August 26, 1954, in Washington, D. C., concerning proposed alterations for a building at 70 Columbus Avenue, New York City, which was to be occupied by the Immigration and Naturalization Service?

Mr. STROBEL. Yes, sir.

Mr. MALETZ. Do you recall that this conference was attended by representatives of the GSA and Immigration and Naturalization Service?

Mr. STROBEL. That is right.

Mr. MALETZ. And do you recall that the purpose of the conference was to present estimates and all pertinent facts on the building before occupancy by the Immigration and Naturalization Service?

Mr. STROBEL. Well, I would like to explain that story in detail, if I may.

We at the time you said got a request from the Immigration Service that they wanted to abandon their occupation of Ellis Island, which they had occupied under the same circumstances for about 10 years or so. It was a costly operation that should be abandoned.

The Commissioner of Immigration had picked space in the building located at 70 Columbus Avenue, in New York City, a building that was totally rented by GSA. For the Service to go in there, it would mean establishing detention quarters and making a rather costly and large alteration to a building that we are renting.

The time schedule was set at a most unreasonable, short time. The conference, as you mentioned, was to establish what should be done, how much money it would cost, because GSA, to my recollection, did not have sufficient money in the budget to take care of that alteration. It would be on a reimbursable basis.

I might say that I personally objected to that move, as I considered it to be not wise for the Government to spend what would amount to $400,000 or more in a rented building.

The CHAIRMAN. That is, you felt it would cost upward of $400,000 to make the changes that the Commissioner of Immigration desired? Mr. STROBEL. That is right, to make the building suit the occupa tion and the function of the service that previously was on Ellis Island.

Anyway, my objection to that was overruled, and we were ordered to proceed full steam. The Commissioner of Immigration pushed us just as hard as he could. In fact, some irregular activities had been started; so I had to call a special meeting, calling the immigration officials in, and I had the public buildings representative from New York down on the meeting, and the main purpose was to tell immigration what the procedure would be in order to get this space ready, and not necessarily let them do the way they wanted to.

They wanted to rush the act, so to say, and have a lot of work done without us knowing what we were to do.

So I told them that it must be done this way: First, we must have plans and specifications made so that the project is finalized; and we, then, on account of the time limit, might go in for a negotiated contract on a cost-plus-fixed-fee basis to have the work done.

My recollection is that we had 6 weeks to have the plans made and 3 months thereafter the work completed and ready for occupancy. If you gentlemen were in the construction business, you would know that that would mean a rather unreasonable request.

Well, we proceeded, and they agreed to lay off, so to say, and not interfere with our operation, and we had to get the plans and the specifications made. That is a function that under our decentralized method of operation is delegated to the regions.

I recall I do not know whether it was the same day or several days after that I got a request from the Public Buildings official in New York would I send up 5 or 6 men, architects and engineers, right away to prepare plans and specifications for this project, because he did not have sufficient manpower to do the job at that time. I had to refuse him the request of men from our office to go up there because we do not have extra men sitting around doing nothing. They are all occupied and they are all scheduled for work.

So I told him, "Go out"

Mr. MALETZ. Who was "him"?

Mr. STROBEL. The official in New York.

Mr. MALETZ. Would that be Mr. Edwin Lawton?

Mr. STROBEL. That would be Mr. Lawton; yes. I told him, "We cannot help you."

The CHAIRMAN. He is the deputy regional director of the Public Buildings Service?

Mr. STROBEL. That is right, sir. I told him to go out in private industry, that is, private architects and engineers, and try to find somebody that would be willing to do this project under the circumstances, and when I told him that, I at the same time said, "You might contact Serge Petroff. I know him. If he is willing to take on the job, we will get it done."

The CHAIRMAN. And you suggested the name of Serge PetroffMr. STROBEL. I suggested the name of Serge Petroff to him.

The CHAIRMAN. That is the man from whom you got this other business that was relayed to you before?

Mr. STROBEL. Well, in order to clarify that picture, I should probably say that he has gotten a lot more business from Strobel & Salzman than Strobel & Salzman has gotten from him in the past year.

Mr. MALETZ. Now, Mr. Strobel-I am sorry. Are you finished? Excuse me.

Mr. STROBEL. So that was the end of my contact with that proposition, because the authority was delegated to the New York regional deputy to handle that type of work. He did get in touch with Petroff. The work, as has been indicated, was by no means attractive work, because it was tenant changes that had to do with ventilation, rearranging of interior space, new lighting, plumbing, and so forth.

In other words, it is the type of work that no architect can get any glory or build any reputation on. It is the lowest type and least attractive work in the architectural business.

Mr. Lawton negotiated a contract or an agreement with Mr. Petroff and he did perform the work, by putting all his effort-I think his whole office as well as his personal effort-on the project, and got the plans almost completed in the same set. At that time, a change of mind had taken place with the immigration authorities, and

The CHAIRMAN. Let us pause at this moment to ask you 1 or 2 questions about Mr. Petroff.

Mr. STROBEL. Yes, sir.

Mr. MALETZ. All right.

Now, did you instruct Mr. Lawton to give that contract, the architectural contract, to Serge Petroff?

Mr. STROBEL. No; I did not.

The CHAIRMAN. You did not ask him to?

Mr. STROBEL. I gave him the name of Petroff.

Mr. LAWTON. You recall the meeting of August 26 with Mr. Lawton; do you not?

Mr. STROBEL. Was that the meeting where the immigration officials

were

Mr. MALETZ. Yes. Did you have a private discussion with Mr. Lawton after the meeting with Immigration and Naturalization officials?

Mr. STROBEL. That is possible; yes. That is possible.