By facsimile letter dated April 2, 1991 you have asked the New Castle County Ethics Commission to issue an Advisory Opinion as to whether you may receive an honorarium for your participation in a trade symposium held by or on behalf of a vendor from whom you purchase services on behalf of New Castle County.
Conclusion:
The Commission has determined that because of your position with the County and the fact that the symposium is for the ostensible benefit of a vendor of the County, it would be improper for you either to receive the honorarium directly or to instruct the vendor to contribute the honorarium to a charity of your choice. The vendor may, however, make a contribution of the honorarium to a charity of its designation.
Facts:
The honorarium is in the amount of $100.00 and the group soliciting your attendance has given you the option either of receiving the $100.00 directly or making a donor-specific contribution in like amount to a charity of your choice.
Analysis:
While the Commission believes that it is appropriate and/or beneficial for County employees to participate in trade symposiums aimed at improving services from vendors, the receipt of remuneration by participants such as you might create an "appearance of impropriety" as defined in Code Section 2-30.1 of the New Castle County Ethics Code.
Finding:
The Commission has determined that because of your position with the County and the fact that the symposium is for the ostensible benefit of a vendor of the County, it would be improper for you either to receive the honorarium directly or to instruct the vendor to contribute the honorarium to a charity of your choice. The vendor may, however, make a contribution of the honorarium to a charity of its designation.
