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TWC readopts ethics policy with new provisions addressing foreign adversaries and outside activity disclosures

5504150 · July 29, 2025
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Summary

The commission readopted its ethics policy with revisions to prohibit certain access and outside activities, add reporting mechanisms for contacts from entities on the Commerce Department’s foreign adversaries list, and include a placeholder for an AI/data-use ethics link.

The Texas Workforce Commission approved readoption of its ethics policy after staff described revisions made to comply with a gubernatorial executive order and to improve clarity.

Deborah Simpson, assistant general counsel, told commissioners the policy had been readopted previously on July 30, 2024, but the governor subsequently issued an executive order requiring changes related to foreign adversaries. Simpson said the revised policy:

- Clarifies that employees may not access TWC systems for non-TWC purposes or outside the scope of employment. - Expands prohibitions on self-employment activities to apply regardless of whether the employee receives compensation. - Requires employees to submit a P-44 form for any outside employment, dual employment, or outside activity that overlaps with TWC operations or involves a leadership position (officer, partner, director, or manager of an LLC), even if unpaid. - Adds a reporting mechanism and prohibition on travel or gifts tied to entities on the U.S. Department of Commerce foreign adversaries list. - Adds a placeholder for a forthcoming TWC policy on data and artificial intelligence use.

A commissioner moved to approve the readoption as presented; the motion was seconded and carried.

Why it matters: The revisions align TWC policy with the governor’s executive order requirements, tighten outside-activity disclosures and controls, and add mechanisms for reporting contact or offers from entities identified as foreign adversaries.

Next steps: Staff will insert a link to the forthcoming AI/data-use policy when that document is finalized and will administer the updated P-44 process for outside activity approvals under the revised policy.