Team Moulton Conflicts of Interest Policy

I am committed to not only following both the letter and spirit of the ethics rules to avoid conflicts of interest, but also demonstrating a commitment to avoiding any appearances of a conflict between my official congressional work and any personal financial interests.

Members of Congress and their senior staff are required to disclose their finances once per year and in periodic transaction reports (“PTR”s) so that the public and journalists can scrutinize their financial interests. In order to provide additional transparency beyond those reports, my team and I have added my financial disclosure information and the policy we use to avoid conflicts of interest in the course of our work to my website.

There are several House ethics rules that prohibit Members of Congress and congressional staff from financially benefiting from their public positions. These include rules related to contracting with the federal government, accepting gifts, restrictions on outside employment, using the office for personal gain, and the STOCK Act, which regulates investing in initial public offerings and making investment decisions based on material nonpublic information (insider trading).

These rules lay out several bright lines to guide Members and staff away from conflicts of interest. For example, Members must do the following related to any personal investment:

Recuse themselves from participating in legislative actions in which they have a material conflict
Never use their official position to benefit a company in which they are invested, such as by promoting a product using official resources or passing information learned in an official capacity to a company in which they are invested
Never use information they receive because of their official position to benefit themselves financially--in particular, Members cannot sell or purchase stock based on non-public information that is made available to them due to their official position

Because a member of Congress has a Constitutional obligation to vote on matters coming before the House, members of Congress are generally allowed to vote on the floor on a bill even if the bill benefits a company in which they are invested or that company’s industry as long as the bill is not solely focused on the company in which they are invested. Actions that go beyond voting on the House floor are, however, subject to more restrictive recusal requirements.

My goal is to be transparent and thorough in preventing conflicts of interest. My team and I scrutinize every decision we make to determine whether the action could have a real or perceived conflict with a personal financial interest that I or a member of my senior staff and my family might have. With that in mind, as part of our due diligence process we apply the conflicts of interest policy outlined above to companies in which my wife, my senior staff or I have a direct financial interest. As I update my financial disclosures, I will update the policy to include anything else in which I am invested.