Ethics & Compliance for Financial Disclosure Management Filers: An FAQ

If your work involves contracting or procurement; you regulate, audit or inspect non-Federal entities (NFE); or your activities might have a direct or substantial effect on the financial interest of NFEs, you may be required to file an OGE450, which also includes completed Ethics Training each calendar year while you’re in that position. Here’s an FAQ about what that means.
What is the OGE450?
It’s the Office of Government Ethics’ confidential financial disclosure form. The form’s basic purpose is to assist the Exchange and its associates in avoiding conflicts between official duties and private financial interests or affiliations.
Where do I file the OGE450?
FDM (Financial Disclosure Management), which works similar to income tax filing software, is a secure Army electronic filing system that guides filers through questions about reportable financial information and flags missing and incorrect information.
When can I file the OGE450?
Annual filers can start their forms no earlier than Jan. 1 and have until Feb. 15 to complete.
What if I need an extension?
You must submit a written request explaining why you need the extension to the ethics office at ethics@aafes.com or fordkel@aafes.com, which must be approved by the ethics official.
Why do I need to complete ETH4 Ethics Training?Â
Not only is this a requirement for all 450 filers, the purpose of Ethics Training is to ensure that associates understand and adhere to ethical principles and company policies, fostering a culture of integrity and accountability, and mitigating risks associated with unethical conduct.
What is covered in Ethics Training?
- Conflicts of Interest
- Employment Issues
- Fundraising
- General Principles of Public Service
- Gifts
- Impartiality in Performing Official Duties
- Misuse of Position
- Official Travel Benefits
- Outside Activities
- Political Activities
- Real-life ethical violations and their consequences.
- Use of Government Resources
Where do I take ETH4?
ETH4 is available in LEX and takes about an hour to complete.
When can I take ETH4 in LEX?
Every year, Jan. 1 through Oct. 31.
What do I do if I am not positive about an ethical situation in my workplace?
If you are not positive that what you are about to do is appropriate, ask your ethics counselor. One mission of ethics counselors is to advise personnel on accomplishing their goals without violating the standards of conduct. In fact, disciplinary action for violating the standards of conduct will not be taken against you if you act in good-faith reliance upon the advice of your ethics counselor following a full disclosure of all relevant circumstances.
Can I really get in trouble for violating an ethics principle?
Violating ethics principles may result in disciplinary or corrective action, including criminal prosecution. Protect yourself by seeking the advice of your ethics counselor before you act.