The Department of Homeland Security (DHS) and its six components with the largest international presence lack comprehensive policies and training to govern employees’ off-duty conduct while abroad, according to a recent DHS Office of the Inspector General (OIG) report.
DHS OIG conducted the investigation to determine whether DHS had in place adequate policies and training relating to off-duty conduct for employees traveling abroad in the wake of a series of incidents involving drinking alcohol to excess, use of illegal drugs, solicitation of prostitutes, and engagement in “notoriously disgraceful conduct."
The auditors noted that off-duty misconduct can undermine the Department’s credibility and integrity, as well as hinder its ability to achieve its mission.
According to the report, as of August 2015, DHS has 1,467 representatives from 11 components and offices stationed in 308 cities in 80 countries. US Customs and Border Protection (CBP), the US Coast Guard, and US Immigration and Customs Enforcement (ICE) have the largest permanent international presence.
To support relations with other countries and international organizations, government employees stationed abroad are held to a high standard of ethics. The Secretary of State is responsible for the overall coordination and supervision of US government activities abroad.
While there are guidelines imposed by the DHS regarding off-duty conduct, these departmentwide policies do not specifically address conduct abroad, as well as certain types of misconduct, such as drinking excessive amounts of alcohol and using drugs.
For example, although the consumption of alcohol is permissible, all six components of DHS have policies with guidance on alcohol consumption. However, the policies of CBP and US Citizenship and Immigration Services (USCIS) do not include guidance related to alcohol consumption while on official travel outside the United States.
Furthermore, some components of DHS’s policy on alcohol consumption remain unclear and need to be further explained. The failure to address when employees should limit alcohol consumption was deemed problematic.
For example, according to CBP’s policy, employees should limit their alcohol consumption for a “reasonable” period of time, rather than a specific number of hours, before operating a government-owned vehicle. DHS also has a strict drug policy for its employees, which prohibits the use of illegal drugs on and off duty.
However, certain components, such as USCIS, do not have policies containing specific language prohibiting the consumption of illegal drugs while off duty or where consumption is legal.
The auditors also determined that policies regarding the solicitation of prostitutes were lacking, even noting that five of the six components do not have any policies in place prohibiting solicitation of prostitutes.
This comes in light of allegations that Secret Service agents solicited prostitutes and engaged in other misconduct during President Obama’s visit to Cartagena, Colombia in April 2012 for the Summit of the Americas conference.
USCIS is the only component out of the six to have an extensive policy on this subject matter. Their policy specifically prohibits soliciting prostitutes while on official international travel, while off duty, and where prostitution is legal.
The report also pointed out gaps regarding “notoriously disgraceful conduct.” While CBP, the Transportation Security Administration, and USCIS have policies which include the term “notoriously disgraceful conduct,” neither of the three components defines it.
DHS OIG investigators concluded that it is important that DHS and its components fill the gaps that are present in policies regarding use of alcohol, drugs, prostitution, and other “notoriously disgraceful conduct.”
“Employees need to understand that poor decisions about off-duty conduct can have serious ramifications for their careers and DHS’ ability to carry out its mission,” stated DHS OIG. “Comprehensive policies reinforced by training create a consistent message about proper behavior.”
In response, the federal investigators recommended that DHS ensure it has comprehensive policies specifically addressing off-duty conduct abroad and make certain all employees traveling and working abroad are adequately trained and acknowledge and understand these policies.
DHS officials concurred with the recommendations, but disagreed with certain premises.
“DHS disagrees with OIG’s apparent underlying premise that any conduct policy covering DHS employees must specifically state it applies off-duty employees,” DHS official Jim H. Crumpacker said. “Leadership does however, recognize the potential benefits of providing additional information to employees to help ensure appropriate conduct.”