Subject: Revised Code of Conduct
From: "Chris Lu" <[email-masked]>
To: "Adam Hitchcock" <[email-masked]>, [email-masked], [email-masked], [email-masked], "Valerie Jarrett" <[email-masked]>, [email-masked], [email-masked], [email-masked], "Pete Rouse" <[email-masked]>, "Melody Barnes" <[email-masked]>, "Bauer, Bob (Perkins Coie)" <[email-masked]>, [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked]
Cc: [email-masked], [email-masked], "Jayne Thomisee" <[email-masked]>, [email-masked], [email-masked], [email-masked], [email-masked], "Katie Johnson" <[email-masked]>, "Elizabeth Utrup" <[email-masked]>
Date: Tue, 12 Aug 2008 16:57:38 -0500

Bob has revised the code of conduct based on last Friday's discussion.  The sections that have been changed are marked with asterisks:
 
Obama Transition Project
Code of Ethical Conduct
 
As a condition of being permitted to serve as a member of the Obama Transition Project, I agree to abide by the following requirements:
 
**1. I will disqualify myself from involvement in any particular Obama Transition Project matter which to my knowledge may directly conflict with a financial interest of an immediate family member, partner, client, or other individual or organization with which I have a business relationship within the past 12 months. Should there be no such direct conflict, but the potential for the appearance of a conflict, I will address this issue for resolution to the Project Executive Director.
 
**2. I will disqualify myself from involvement in any particular transition matter the subject of which I have engaged in regulated lobbying activities, as defined by the Lobbying Disclosure Act, within the previous 12 months.
 
3. I will not solicit or accept any money or things of value in exchange for a promise to support or use influence on behalf of any person who is a candidate for any appointive office or place in the United States Government.
 
**4. I understand that in my Obama Transition Project-related activities, unless given specific authorization, I am not permitted to make any representations on behalf of Senator Obama or the Democratic Nominee for Vice President, their designees, or any official of the Obama Transition Project, and in all my service to the Transition, I will identify myself only as acting on behalf of the Transition Project on transition-related matters.
 
5. I understand that authorization is required from the Obama Transition Project's Executive Director or the Executive Director's designee before seeking, on behalf of the Obama Transition Project, access to any non-public information.
 
6. I will hold in confidence any non-public information provided to me in the course of my duties with the Obama Transition Project and ensure that such information is used exclusively for purposes of the Obama Transition Project.
 
7. I will not use or permit to be used any non-public information, in any manner, for any private gain for myself or any other party, at any time during or after the operation of the Obama Transition Fund.
 
8. During my service with the Obama Transition Project, I will not communicate with or appear before, with the intent to influence, any federal agency with respect to which I have substantial responsibility during the activities of the Obama Transition Project, on behalf of any other person or entity (except federal, state, or local government entities). I will promptly cause my firm or organization to establish reasonable procedures to assure that I will not participate in any undertaking with respect to which I am affected by this provision.
 
**9. For 12 months following the conclusion of my service with the Obama Transition Project, I will not on behalf of any person communicate with or appear before, for compensation and with the intent to influence, any federal agency on a particular regulatory or policy matter for which I had substantial responsibility during my service to the Transition Project. 
 
10. I will conserve and protect any federal property entrusted to me, and shall not use federal property, including motor vehicles or other forms of transportation, stationery, printing, equipment and supplies, other than for purposes directly related to the activities of the Obama Transition Project.
 
11. Neither I nor any member of my immediate family will accept a gift from:
 
a. anyone who is seeking a job with the federal government; 

b. a federal employee in any agency or department within the scope of my Obama Transition Project responsibilities; 

c. any person or organization that conducts activities regulated by or has a matter pending before an agency or department within the scope of my Obama Transition Project responsibilities; or
 
d. any person or organization under circumstances where it may reasonably appear that the gift is being given in order to influence my decisions, advice, recommendations or actions as an Obama Transition Project member
 
12. If I am currently a federally registered lobbyist: 

a. I understand that I may not contribute to or collect contributions for the Obama Transition Project. 

b. I understand that I may not incur any expenses on behalf of the Obama Transition Project, whether they are paid by me personally or by my employer.
 
**c. I understand that I will not be permitted to serve in a titled role for the Obama Transition Project, including but not limited to serving as a chair of a working group or holding an honorific title, or having lead or substantial responsibility for any final recommendations.
 
**13. I will not represent, aid or advise a foreign government or foreign political party for the duration of service to the Transition Project.
I understand that my commitment to abide by these requirements may be made public and that this document will be made available to any department or agency to which I may be assigned. I will seek guidance from the Counsel to the Obama Transition Project, or designated agency ethics officials, as appropriate, if necessary to ensure compliance with these standards of conduct. I furthermore acknowledge that failure to comply with the above provisions may result in my dismissal