Ethics Quote Of The Month: David J. Apol, Acting Director, U.S. Government Ethics Office

On October 5, David J. Apol, Acting Director of the U.S. Government Office, felt it necessary to send the following memo to all Trump Administration agency heads.


TO:   Agency Heads

FROM:    David J. Apol, Acting Director  and General Counsel

SUBJECT:   The Role of Agency  Leaders in Promoting an Ethical  Culture

As a leader in the United States Government, the choices that you make and the work that you do will have profound effects upon our nation and its citizens. It is essential  to the success  of our republic that citizens can trust that your decisions and the decisions made by your agency are motivated  by the public good and not by personal interests.

You are ultimately responsible for the ethical culture within your organization. The priorities that you set, the messages that you deliver, and the actions that you take demonstrate your level of commitment to ethics in Government. Your personal conduct sets a powerful example  for the employees  in your organization.

I am grateful to agency leaders who have demonstrated their commitment to ethical service. At the same time, I am deeply concerned that the actions of some in Government leadership have harmed perceptions about the importance of ethics and what conduct is, and is not, permissible. I encourage you to consider taking action to re-double your commitment to ethics in Government. Attached is a sample of actions that OGE has observed in Government agencies,  which  you can take to strengthen  the ethical culture in your agency.

The citizens we serve deserve to have confidence in the integrity of their Government. The public’s trust is not guaranteed. We must earn that trust every day, because the loss of that trust is catastrophic. I want to personally thank you for your service and your work to earn and secure the public’s trust.


Suggested Actions for Agency Leaders

Demonstrate personal ethical behavior by modeling a “Should I do it?” mentality (versus a “Can I do it?” mentality)

  • Talk about the importance of ethics to your organization by including ethics themes in speeches, communicating ethics priorities in memos, and recognizing the support that ethics officials provide. For example:

    • the Secretary of Defense recently stated his expectation that all employees maintain high ethical standards1
    • the Secretary of Agriculture recently announced new ethics training initiatives and encouraged employees to participate2
  • Get to know your ethics program, and ensure that it is staffed by qualified personnel and has sufficient resources

  • Include ethics officials in meetings of senior leaders

  • Recognize and praise honorable service by employees in your agency

  • Underscore the consequences to the organization and its mission of unethical behavior

  • Promote a safe culture for reporting misconduct


I. This is being sent out now, 10 months into the administration?

II. On the other hand, this is Ethics 101. I said much the same thing, indeed more and with more detail, in a recent presentation to a Boy Scout Troop. If the leaders of top government departments and agencies need to have basic government ethics principles like “The public’s trust is not guaranteed. We must earn that trust every day, because the loss of that trust is catastrophic” explained to them, that itself suggests an alarming lack of trustworthiness.

III. A message of this kind needs to be sent by the President, the officer at the top of the organizational chain, or it is meaningless.

IV. I wonder if President Trump ever saw it…..


8 thoughts on “Ethics Quote Of The Month: David J. Apol, Acting Director, U.S. Government Ethics Office

  1. It is hard to discern to whom this is being targeted. By default, it is the Trump admin-istration in power but at the same time many department heads are holdovers from the prior administration.

    I agree that these directives should come from the top executive and it is unkown if the acting director was instructed to do so from senior administration officials.

    I am a bit uneasy about his alluding to improper behavior within this memo and why this memo was made public. Nothing teases the imagination of the pro or anti administration forces then the suggestion of improper behavior. If he has knowledge of impropriety then he should address it head on and not leave it to the public’s imagination.

  2. Interesting…I don’t know anything about Apol other than that he took over from Walter Shaub, who was a harsh critic of the Trump administration’s ethics.

    Jack, you know well Jean Anouilh’s play Becket. Reading the article below from a few months ago, and given the memo you’ve cited here, I wonder if Apol has recently undergone a Becket-like conversion? If so, methinks that would be a good thing, and an even greater story.

  3. When I said “roll it back”, I didn’t mean by *that* much, discarding even ethics 101 stuff… I just meant the extraneous, unnecessary, politically correct stuff.
    The stuff that in a sane world, wouldn’t be a necessary defence against unethical behaviour, because it goes too far.

  4. My guess is that it’s being sent to try to reign in so-called “resistance” members in government agencies by reminding them that they will cause damage to government if they are perceived as acting in the interests of the Democratic Party rather than in the public good.

    And I doubt the President saw it. Or, if he did, gave it a glance and said, “Yeah, that’s great!” and hasn’t given it a second thought since.

      • Isn’t it obvious?

        Demonstrate personal ethical behavior by modeling a “Should I do it?” mentality (versus a “Can I do it?” mentality)

        Sounds like a stroke rebuke to all those Democratic holdovers using military aircraft and chartered private planes paid for with tax dollars.

        It all makes sense if you understand that for a certain segment of the population, the words Democratic party, left, liberal, and progressive are just synonyms for bad person. If a person does something wrong they’re obviously a Democrat, like Jack the Ripper, General Tojo, George Wickham, Walder Frey, and The Dark Lord Sauron.

  5. Take it for exactly what is says.

    Unless people choose to read between the lines, I think the memo is broad enough to imply that there is a perceived rotting of ethics within the government that needs to be addressed before it really gets out of hand.

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