Question: I have served as a Grant Compliance Auditor in the District government for over 10 years. Recently, while reviewing some community‑based grant files, I discovered credible information suggesting that my supervisor may have improperly shared confidential scoring information with an applicant. A few weeks ago, I heard office chatter about him possibly doing something like this before, but I never believed it until then. This could be an ethics violation, but I am nervous about reporting it because I am worried about retaliation from my supervisor and being drawn into a lengthy investigation.
Before I could decide on whether to report what I saw or not, I received an email from BEGA asking whether I had time to speak regarding an ongoing investigation concerning a colleague. I am concerned that responding to BEGA’s interview request, or even retaining the files, may put me at risk. For my own protection and job security, I am trying to understand my responsibilities. Am I required to participate in the meeting? And if I do, what protection is available to me?
Answer: Thank you for reaching out to BEGA. I’m sorry to hear that you are experiencing challenges regarding whether to comply with a BEGA investigation request. We understand that this can be a difficult decision for any employee who may be called upon. However, District government employees have a duty to comply with BEGA investigation requests. The good news is that both BEGA and the District Personnel Manual (“DPM”) provide important safeguards for employees who do so.
BEGA Safeguards
BEGA investigations prioritize confidentiality. Specifically, interviews and other investigation‑related requests made by BEGA are not shared with entities outside of BEGA. In addition, BEGA does not disclose how or where it obtains evidence and information to the public.
District Personnel Manual (“DPM”) Safeguards
Under DPM § 1801.1, once you have credible information about a potential violation of the District Code of Conduct or this chapter, you must immediately and directly report it to the DC Office of Government Ethics (OGE), the Office of the Inspector General (OIG), or both. Reporting internally within an agency or raising concerns directly with the subject of the potential violation does not satisfy this obligation, you must go directly to OGE and/or OIG.
Under DPM § 1801.2, you must not interfere with or obstruct any investigation conducted by a District or federal agency. This means you should preserve relevant records, avoid alerting potential subjects, and follow lawful instructions from investigators.
DPM § 1801.3 requires you to fully cooperate with any investigation, enforcement action, or other official function of OGE. Full cooperation includes timely and truthful responses, producing documents, and participating in interviews or hearings when requested.
You are also protected from retaliation. Under DPM § 1801.4, no one may take coercive, harassing, or retaliatory action against you for acting in good faith. “Good faith” means you reasonably believe the violation is credible—even if it is later unsubstantiated. Prohibited retaliation includes demotion, adverse assignments, threats, harassment, or intimidation.
Practical Steps You Can Take
- Respond and Report Promptly: Cooperate fully. Respond to OGE requests and follow instructions. If applicable, file a direct report with OGE and/or OIG with dates, facts, documents, and witnesses (anonymous reporting is permitted).
- Preserve Evidence: Keep all emails, notes, and materials intact. Do not alter or delete anything.
- Avoid Informal Probing: Do not conduct your own investigation or alert the colleague; this could be viewed as interference.
- Track Potential Retaliation: Document any adverse actions and notify OGE or OIG if they occur. Retaliation is strictly prohibited under § 1801.4.
We encourage you to contact our office for specific advice, and to review the resources linked below:
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