Training video tells supervisors to flag potential conflicts on confidential financial disclosure reports

Unidentified Speaker (Instructor) said supervisors should use their knowledge of employees' duties to spot conflicts between job responsibilities and entries on confidential financial disclosure reports and to notify their agency ethics office when in doubt.

The training video, presented as part two of an intermediary review series, lays out a two-step review intended to help supervisors identify potential conflicts of interest. The instructor described the first step as assessing the filer's likely duties and the second as checking whether those duties overlap with items disclosed on the form, such as stocks, mutual funds, outside employment or reported gifts.

Using a hypothetical filer named Ivy, identified in the example as a deputy information security officer, the instructor walked through the form sections. "If you are ever in doubt, let the ethics office know," the instructor said, advising supervisors to flag unclear items for ethics staff to research and advise.

The video applied the process to specific examples. The instructor identified a holding listed as the First Trust Nasdaq cybersecurity ETF and said it "looks like we might have a nexus" with Ivy's IT security duties; supervisors should inform the ethics office and "ask Ivy to stop work on anything to do with [that fund] while the ethics office completes its analysis and identifies next steps." The trainer made the same recommendation for a listed stock, CrowdStrike, calling it "a large IT security company" and advising supervisors to pause work on matters related to that company while ethics performs its review.

The instructor also noted that spouse employment and spouse-held stock may raise concerns, citing an example in which Ivy's spouse works for Amazon and holds Amazon stock. Supervisors were instructed to consider whether the company could be a bidder or contractor for the agency and to notify the ethics office if there is any possibility of a nexus.

The video proceeds through the standard form sections: Part 1 (assets and income), Part 2 (liabilities), Part 3 (outside activities — for example, board membership), Part 4 (agreements and arrangements), and Part 5 (reportable gifts). For outside activities, the instructor posed two specific questions: whether the agency requires prior approval and whether the outside activity overlaps with the filer's duties; if the supervisor cannot confirm prior approval, that question should be referred to the ethics office.

Throughout, the guidance distinguishes three types of supervisor responses: identify a likely nexus and notify ethics, ask the filer to stop work affecting the disclosed interest during the ethics review, or refer the issue to the ethics office when uncertain. The video closes by reiterating that supervisors' judgments about duties are essential to preventing conflicts of interest and that notifying the ethics office is the appropriate next step when a nexus is possible.

The segment did not record any formal agency determinations or case outcomes; it is instructional, not a report of an ethics decision. The training closes by thanking supervisors for their efforts.