POLICY USING DISCLAIMERS Adopted 2/22/19

The Guam Preservation Trust (GPT) restricts use of official titles to avoid the appearance of inappropriate endorsement by the Guam Preservation Trust and use of official GPT titles for private gain. Regardless of the prohibition, there are some specific instances when an employee’s or board member’s title can be used with a disclaimer stating that the views are the employee’s or board member’s and not those of the Guam Preservation Trust. The basic content of a disclaimer is as follows, with edits to fit the specific permissible situation.

This [explain activity] was prepared or accomplished by [insert author’s name] in his personal capacity. The opinions expressed in this article are the author’s own and do not reflect the view of the Guam Preservation Trust.

Official Duties: No disclaimer is needed. When an employee or board member is engaged in any official duty activity with an outside organization, the employee may use his/her official title in connection with the activities without violating ethics rules. In an official duty, the employee represents the Guam Preservation Trust and therefore reference to current official position or title is permitted. This applies to speaking, teaching, writing, and any other activities carried out on behalf of the Guam Preservation Trust.

Completing Work for Prior Employer: When completing written work for a prior employer, employees or board members must include a disclaimer to ensure that the work is not inappropriately attributed to the Guam Preservation Trust, even if the employee is permitted official time to complete the work. The disclaimer makes it clear that the work is not an official Guam Preservation Trust work.

Outside Activities: Generally, when engaged in outside activities, employees or board members may not use or reference their titles or Guam Preservation Trust affiliation except as one of several biographical details and provided it is given no more prominence than other significant details. However, there are limited circumstances when employees or board members may permit their titles to be used, as long as there is a prominent disclaimer, as explained below:

• An employee or board member may use, or permit the use of, his/her title in connection with authorship of an article to be published in a scientific or professional journal, or editorial board or service for a scientific or professional journal, provided that the title or position is accompanied by a reasonably prominent disclaimer stating that the views expressed in the article are the employee’s or board member’s and do not represent those of the Guam Preservation Trust.

Example: John Doe works with another board member as part of his teaching at the local university as an approved outside activity. He and the other board member jointly prepare an article for publication in a scientific journal. He may use his official Guam Preservation Trust title but it must be accompanied by the following disclaimer, prominently placed so readers see it: John Doe contributed to this article in his personal capacity. The views expressed are his own and do not necessarily represent the views of the Guam Preservation Trust.

• The Guam Preservation Trust permit employees or board members to use their official Guam Preservation Trust title in connection with outside activities that do not involve teaching, speaking or writing, provided the employee’s or board member’s title or position is not used in a manner that could reasonably be construed to imply that the employee’s or board member’s affiliation with the Guam Preservation Trust sanctions or endorses the employee’s or board member’s activities. Therefore, employees or board members may use their official government title in connection with an outside activity (other than teaching, speaking, or writing), only as follows:

An employee or board member may permit his/her name and official title in connection with an outside activity (other than teaching, speaking, or writing) as long as there is a prominent disclaimer indicating that the employee or board member is serving in a personal capacity, e.g., the name and official title may be listed on the letterhead or other program provided that the listing contains an asterisk with an explanatory side or footnote stating that the individual serves in his/her personal capacity.

Example: As a member of an award committee for a professional association in his personal capacity, John Doe helps the association review award nominations and determine the winner. His name and title are listed on the award nomination form as follows: John Doe, Guam Preservation Trust* and at the bottom of the list is the following disclaimer: *John Doe is serving in his personal capacity.