Service Manual Chapter 633 FW 1, "Working with Friends Organizations"

FISH AND WILDLIFE SERVICE
PUBLIC USE MANAGEMENT
Public Use Management

Part 633 Friends Organizations

Chapter 1 Working with Friends Organizations

633 FW 1

TABLE OF CONTENTS
Topics
OVERVIEW

RESPONSIBILITIES
FRIENDS DEFINED

FRIENDS
ACTIVITIES

SERVICE
INTERACTION WITH
FRIENDS

SERVICE SUPPORT
TO FRIENDS

Sections
1.1 What is the purpose of Part 633, the Friends policy?
1.2 What is the scope of Part 633?
1.3 What are the objectives of this chapter?
1.4 What are the authorities and policy we use for working with
Friends organizations?
1.5 What are the responsibilities of Service personnel related to this
policy?
1.6 What are Friends organizations and what is their purpose?
1.7 What if an existing Friends group does not meet the
qualifications of a Friends organization as defined by this policy?
1.8 Does the Service consider cooperating/interpretive associations
to be Friends organizations?
1.9 How do Friends organizations compare to concessionaires?
1.10 How do Friends organization members compare to Service
volunteers?
1.11 Do Friends members need to sign Volunteer Service
Agreements?
1.12 Should Project Leaders include work contributions by Friends
members in their annual site volunteer totals?
1.13 What activities must Project Leaders ensure that Friends do
not participate in on Service-managed property?
1.14 What is the Service’s role in establishing new and maintaining
Friends organizations?
1.15 May Service employees and volunteers be Friends members
and serve on a Friends Board of Directors?
1.16 What responsibilities should the Service require of Friends
organizations?
1.17 May the Project Leader extend the use of Service facilities,
equipment, and vehicles to a Friends organization?
1.18 What can the Service provide in addition to the use of
facilities?
1.19 May a Project Leader use Federal funds to support a Friends
organization?
1.20 May the Service co-sponsor or participate in Friends off-site
events?

OVERVIEW
1.1 What is the purpose of Part 633, the Friends policy?
A. Part 633, the Friends policy, includes four chapters to assist U.S. Fish and Wildlife Service
(Service) employees to achieve our mission more efficiently and effectively through partnerships
with nonprofit Friends organizations (Friends).

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B. These chapters describe the policy, guidance, and administrative procedures for Service
employees to establish partnerships and working relationships with Friends organizations.
C. While these chapters are written to implement specific provisions of the National Wildlife
Refuge System Volunteer and Community Partnership Enhancement Act of 1998, and the
National Fish Hatchery System Volunteer Act of 2006, they also provide direction and
administrative procedures for other Service programs seeking to establish and work with Friends
organizations.
D. The two Acts cited in section 1.1C above encourage the Service to:
(1) Enter into partnerships with non-Federal entities such as Friends organizations to promote
public awareness of the resources of the National Wildlife Refuge and National Fish Hatchery
Systems and facilitate public participation in the conservation of those resources, and
(2) Accept donations of funds and other contributions by people and organizations through
partnerships with non-Federal entities such as Friends organizations.
1.2 What is the scope of Part 633?
A. Although this policy is based on the Refuge and Hatchery System Friends partnership
programs, it provides direction for all Service employees and program areas seeking to establish
and work with Friends organizations.
B. Employees should also consult with their Regional Friends Coordinator/Regional Liaison for
additional guidance when preparing a Friends Partnership Agreement, its supplemental
agreement, and other attachments for questions beyond the scope of this policy.
1.3 What are the objectives of this chapter? This chapter:
A. Identifies authorities for partnering and working with Friends organizations;
B. Describes the roles, responsibilities, and ethical considerations of Service employees working
with Friends organizations;
C. Defines Friends and the difference between Friends and volunteer activities; and
D. Outlines Service expectations of Friends organizations.
1.4 What are the authorities and policy we use for working with Friends organizations?
A. Following are the authorities for this policy:
(1) The Anadromous Fish Conservation Act (16 U.S.C. 757a-757g), as amended.
(2) The Fish and Wildlife Act of 1956 (16 U.S.C. 741a-742j).
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(3) The Fish and Wildlife Coordination Act of 1934 (16 U.S.C. 661-667e), as amended.
(4) Lobbying with Appropriated Moneys (18 U.S.C. 1913).
(5) The National Fish Hatchery System Volunteer Act of 2006 (16 U.S.C. 760aa, 1-4).
(6) The National Wildlife Refuge System Administration Act of 1966 (16 U.S.C. 668dd-ee), as
amended.
(7) The National Wildlife Refuge System Volunteer and Community Partnership Enhancement Act
of 1998 (16 U.S.C. 742f), as amended.
(8) The Refuge Recreation Act of 1962 (16 U.S.C. 460k - k-4), as amended.
B. We closely follow these Service policies while implementing the requirements in Part 633:
(1) Coordination and Cooperative Work with State Fish and Wildlife Agencies (601 FW 7).
(2) Appropriate Refuge Uses (603 FW 1).
(3) Compatibility (603 FW 2).

RESPONSIBILITIES
1.5 What are the responsibilities of Service personnel related to this policy? See Table 1-1.
These employees…
A. The Director

Table 1-1: Responsibilities for Friends Program
Are responsible for…
Establishing national policy, guidance, and administrative
procedures for Service employees working with Friends
organizations.

B. Chief, National Wildlife
Refuge System

Providing national oversight of the Friends program.

C. Headquarters
Directorate Members and
Regional Directors

(1) Ensuring compliance with policies when conducting
partnership activities with Friends organizations, and
(2) Encouraging relationships and mutually beneficial
partnerships with communities through Friends
organizations.

D. The National Friends
Program Coordinator

(1) Providing leadership and direction for the overall
program;

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Are responsible for…
(2) Providing expertise to other program areas seeking to
establish and maintain Friends organizations;
(3) Developing, coordinating, and disseminating Service
policy and standards of operations for the Friends program;
(4) Providing guidance and technical assistance to field,
Regional offices, and other programs on the Friends
program;
(5) Developing, coordinating, managing, delivering, and
encouraging the growth of the program Servicewide;
(6) Establishing and maintaining national partnerships to
support the Friends program;
(7) Developing, coordinating, and managing training
programs and other support programs for the Friends
program;
(8) Evaluating the progress of the Service’s Friends
partnerships;
(9) Conducting annual program reviews for select stations;
and
(10) Maintaining an accurate and up to date list of all Friends
groups and verifying the list at least annually.

E. Regional Directors

F. Regional Friends
Coordinators (or
designated Regional
Liaisons)

(1) Providing leadership for Friends partnerships in their
Regions and designating a Regional Friends Coordinator to
guide this function; and
(2) Reviewing, approving, and signing Friends Partnership
Agreements and supplemental agreements with Friends
organizations or designating an employee to perform these
functions.
(1) Evaluating the progress of the Service’s Friends
partnerships in their Regions;
(2) Providing expertise to other program areas seeking to
establish and maintain Friends organizations;
(3) Assisting in implementing the national Friends program;

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Are responsible for…
(4) Disseminating information to Friends, Project Leaders,
and Service Liaisons;
(5) Providing guidance and technical assistance to field
offices;
(6) Suggesting training for Service employees and Friends in
their Regions;
(7) Providing support to the Project Leaders and Friends
organizations in developing new and modifying existing
Friends Partnership Agreements;
(8) Providing support to ensure that partnership activities
comply with applicable ethics laws and regulations and
consulting with servicing Ethics Officials as needed;
(9) Processing Friends Partnership Agreements for the
Regional Director’s approval and signature;
(10) Ensuring agreements within their Regions do not lapse
(see 633 FW 3); and

G. The Project Leader or
Designee

(11) Maintaining an accurate and up to date list of all Friends
groups in their Regions and verifying it for accuracy on at
least an annual basis.
(1) Serving as the Service Liaison with the Friends
organization or designating an employee to serve in that role
(see section 1.5G);
(2) Assessing the needs of the Service site/program and
comparing them with the benefits and costs of partnering with
a Friends organization. To make this assessment, the Project
Leader must consider:
(a) Compatibility with Service site/program mission
and objectives,
(b) Community involvement,
(c) Future plans for the site/program,
(d) Funding, and

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Are responsible for…
(e) Staffing levels required to participate in and
sustain a Friends partnership;
(3) Working with the Friends organization to develop new or
modify an existing Friends Partnership Agreement and
seeking the assistance of the Regional Friends Coordinator/
Regional Liaison to do so, and sending the completed
agreement to the Regional Friends Coordinator/Regional
Liaison for review and to get the approval and the signature
of the Regional Director (see 633 FW 3);
(4) Annually orienting the Friends Board of Directors on the
Department of the Interior (Department), Service, program,
and site’s mission, goals, objectives, scope of operations,
and the many programs that play a role at the site/program,
such as visitor services, biology, law enforcement,
maintenance, etc.;
(5) Annually meeting with the Friends Board of Directors to
review and assess the effectiveness of the partnership as it
relates to the purpose, goals, objectives, roles, and
responsibilities outlined in the Friends Partnership
Agreement to ensure expectations are clear and realistic,
and to ensure it describes how Friends activities support the
site (or sites) or program. This includes performing annual
reviews as described in Exhibit 1;
(6) Disseminating information to Friends and Service
Liaisons;
(7) Advising Friends on ways in which they can assist the
Service and maintaining regular communications with
Friends about the site/program operations;
(8) Working with the Friends on the ongoing development of
programs, activities, and projects that support the site’s
annual work plans, Comprehensive Conservation Plans, and
other management plans;
(9) Ensuring that the time Service staff members invest in the
partnership is efficient, effective, and sufficient;
(10) Helping identify and provide opportunities for the Friends
to develop skills that will increase their effectiveness and help
the organization assist the Service;

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Are responsible for…
(11) Helping identify and provide opportunities for training
and skill development for themselves as well as for the
designated Service Liaison that will improve the Service’s
effectiveness in working with Friends partnerships;
(12) Helping identify opportunities for recognition of Friends
accomplishments and ensuring Friends are included in
recognition functions;
(13) Ensuring that Friends sales items, publications, and
other services or programs are consistent with the Friends
Partnership Agreement, and the mission, goals, and
objectives of the Service;
(14) Ensuring that the Friends have a current and valid
Friends Partnership Agreement and, as applicable,
Fundraising Agreement in place, which clearly identifies and
describes fundraising activities the Friends will conduct to
carry out their mission to support the Service site or program
prior to any fundraising taking place. Some fundraising
activities may require a separate Fundraising Agreement
when certain dollar thresholds are anticipated;
(15) Ensuring that all net funds collected on Servicemanaged property through direct solicitation activities by
Friends are deposited in the appropriate Service Contributed
Funds Account (CFA) for which the funds were generated
(e.g., Gifts account, Community Partnership Enhancement
Donation Receipt account). This requirement does not apply
to donations collected by Friends through indirect
solicitations (e.g., donation box), nature store revenue,
memberships, or any fundraising activities conducted off
Service property (see 633 FW 4 and 212 FW 8 Donations,
Fundraising and Solicitation). In addition, Project Leaders are
responsible for reporting back to the Friends group on an
annual basis regarding funds deposited into the CFA to
ensure accountability for all parties;
(16) Annually verifying that the Friends maintain an active
tax-exempt status under Section 501(c)(3) of the Internal
Revenue Code;
(17) Requesting and reviewing the Friends’ annual report,
which must include, at a minimum, annual total expenditures

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and revenues and the current number of members (if
applicable);
(18) As part of annual reporting, providing requested data
about the Friends organization to the Regional or National
Friends Coordinator, or both;
(19) Ensuring compliance with applicable ethics laws and
regulations in all Friends-related activities and consulting
with their servicing Ethics Official when potential ethics
issues arise. Note that Friends organizations are
considered a prohibited source under applicable ethics gift
regulations and Service employees are subject to
limitations on the acceptance of food, entertainment, and
other gifts from prohibited sources;
(20) Ensuring that Friends obtain and hold insurance for
certain specialized activities (e.g., water-related activities,
use of live wildlife at an event, selling food);
(21) Attending Friends meetings, as a Service employee,
when the Friends require information or support to carry out
the joint activities described in the Friends Partnership
Agreement; and

H. Service Liaisons (may
be the Project Leader or a
staff person they designate
to serve as liaison to the
Friends)

(22) Conducting quarterly reviews, which include confirming
accuracy of board and staff contact lists as well as observing
discussions of budgeted versus actual expenses.
(1) Working closely with the Friends to provide regular
communication and coordination of mutually developed
programs and projects;
(2) Disseminating information to the Friends that could help
them achieve mutual goals and objectives of the partnership;
(3) Working with other staff members to provide the Friends
with updates and presentations on activities associated with
the site/program;
(4) Attending Friends meetings, as a Service employee,
when the Friends require information or support to carry out
the joint activities described in the Friends Partnership
Agreement;
(5) Ensuring that Friends board members complete and sign

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Are responsible for…
a Volunteer Service Agreement (Optional Form (OF) 301A),
where applicable and ensuring that the scope of the
volunteer services (duties) to be performed are accurately
described in the “description of service to be performed”
section of the agreement;
(6) Assessing fulfillment of the Friends Partnership
Agreement;
(7) Assessing routine operation of any nature store to ensure
consistency with Service policies (see 633 FW 4);
(8) Providing the Friends organization with information about
training and grant opportunities to facilitate the
accomplishment of the goals of the partnership;
(9) Working closely with their supervisor or Project Leader to
identify and attend training that will build skills and improve
their effectiveness in working with the Friends organization;
(10) Ensuring compliance with applicable ethics laws and
regulations in all Friends-related activities and consulting with
their servicing Ethics Official when potential ethics issues
arise. Note that Friends organizations are considered a
prohibited source under applicable ethics gift regulations and
Service employees are subject to limitations on the
acceptance of food, entertainment, and other gifts from
prohibited sources;
(11) Briefing Project Leaders and other staff regularly on
Friends activities and projects; and

I. Servicing Ethics Officials

(12) Planning and coordinating opportunities to recognize
Friends for their accomplishments and achievements for the
Service, while ensuring the proper use of Serviceappropriated funds.
(1) Working closely with Regional Friends Coordinators
and Project Leaders to assist with partnership training
activities that involve ethics topics;
(2) Conducting an ethics review of significantly
modified Friends Partnership Agreements;
(3) Providing ethics training to Service employees who
work closely with Friends organizations to provide

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Are responsible for…
information on the ethics laws applicable to working with
partner organizations; and
(4) Providing guidance and support to ensure that
partnership activities comply with applicable ethics laws
and regulations. Ethics reviews also include guidance on
complying with all ethics laws and regulations, including
gift rules applicable to accepting food, entertainment, and
other gifts from Friends organizations.

FRIENDS DEFINED
1.6 What are Friends organizations and what is their purpose?
A. The Service partners with many types of nonprofit organizations, but Friends organizations are
unique. The primary purpose of Friends organizations is to bring non-governmental assistance to
the Service through volunteer efforts, private contributions, community outreach, and other
activities. We further define them by the following qualifications:
(1) Friends are independent organizations that have tax-exempt status under Section 501(c)(3) of
the Internal Revenue Code.
(2) Friends are established with an organizational mission of supporting the purposes and
objectives of a Service site (or sites) or program with which they are affiliated.
(3) Friends cooperate with the Service under an approved and current Friends Partnership
Agreement (and often a supplemental agreement) that defines and describes the scope of the
partnership.
(4) Friends most commonly support a single Service site, but may support multiple Service sites,
offices, or programs.
(5) Friends organizations may participate in programs, training, grant opportunities, and other
activities that are specific to Service Friends groups (i.e., Regional and national workshops,
Friends Academy, etc.).
B. Friends organizations are most commonly formed and managed primarily by community
volunteers and provide many vital volunteer services to the Service, including community
outreach; coordinating special events; developing and delivering educational, interpretive, and
other visitor services programs; coordinating volunteers; and conducting habitat restoration and
biological and maintenance program support. While performing these functions on behalf of the
Service, Friends are considered Service volunteers and must work under an approved Volunteer
Service Agreement (OF 301A).

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C. Members of Friends organizations may engage in lobbying, in general following section
501(c)(3) of the Internal Revenue Code for tax-exempt organizations, but they are prohibited from
lobbying when they are actively working as a Service volunteer as well as while they are
representing the Friends organization on Service property. Friends are also prohibited from using
direct or indirect appropriated Federal funds, resources, or other Federal support to conduct any
lobbying activities. When volunteering for the Service, Friends members must comply with Service
and Departmental policies (see sections 1.11, 1.12B, and 1.17). See the example below.

Jake Smith works once a week maintaining trails as a Service volunteer.
He is also a Friends member and restocks books in the bookstore for the
site’s Friends organization. He wants to call his Congresswoman to
lobby for funds to build a larger visitor center. He can do this as a
Friends member, but he cannot do it while volunteering for the Service
or on Service-managed property. He also cannot report the time he
spends contacting the Congresswoman as Service volunteer hours.

1.7 What if an existing group does not meet the qualifications of a Friends organization as
defined by this policy?
A. This policy clearly defines the Service’s unique relationship with Friends organizations and
establishes policy for staff working with Friends through Friends Partnership Agreements. We
value opportunities to work cooperatively with other types of partners in wildlife conservation.
Other partners may be nonprofit organizations, volunteer groups, cooperating associations, or
coalitions of organizations that may have broader landscape or single-species missions. Some
may even support multiple partners whose missions or management objectives are not the same
as the Service’s. Our partnerships with Friends are unique and different from other wildlife
conservation partnerships because Friends are established with an organizational mission of
supporting the purposes and objectives of a Service site (or sites) or program with which they are
affiliated.
B. Those partners that do not meet the definition of a Friends organization in this chapter will
need special consideration from Project Leaders to define the partnership through other
instruments, such as a Memorandum of Understanding, Cooperative Agreement, Volunteer
Service Agreement, etc.
1.8 Does the Service consider cooperating/interpretive associations to be Friends
organizations? Although cooperating associations were formed in the early years of the Friends
program and some still exist today, new cooperating associations are rarely, if ever, formed today
as Friends organizations. The Service’s relationship with existing cooperating associations is not
affected by this policy unless those groups meet the definition of Friends as described in section
1.6A and the relationship is described through a Friends Partnership Agreement. If an existing
cooperating association’s activities are beyond the scope of Friends activities described in this
policy, we may need to redefine the relationship as something other than a Friends partnership.
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1.9 How do Friends organizations compare to concessionaires? Friends organizations and
concessionaires are very different from each other and must be treated as such.
A. A concessionaire is any person, corporation, or organization operating a commercial visitor
services business for monetary gain or profit under a concession contract (awarded after
competition) for the recreational, educational, or interpretive enjoyment of the visiting public.
We award concessions contracts only where public visitation is sufficient for a sustainable
venture and additional recreational opportunities are necessary for the full enjoyment of the
public.
B. While a nonprofit organization could apply for and be awarded a concession contract, the
mission work of Service Friends organizations is on behalf of the Service. A Friends organization
is not a concessionaire, which is a private entity that undertakes activities for monetary gain or
profit.
1.10 How do Friends organization members compare to Service volunteers?
A. Friends members often perform the same functions as our volunteers. For example, they may
lead environmental education programs and site tours, help with biological programs, conduct
community outreach, and staff special events. Individual Friends are considered Service
volunteers when engaged in these activities, on or off-site, under the supervision of the Service
and with an approved Volunteer Service Agreement that clearly describes the duties and location
of the volunteer activity (also see section 1.11 and 150 FW 1, Policies, Procedures, and
Responsibilities for Volunteers).
B. Friends organization members may participate in some activities that cannot be done by
Service volunteers. Friends organizations may perform work associated with lobbying, soliciting
donations, administering games of chance, and the operation or administration of the
organization. When performing these activities, Friends cannot represent themselves as Service
employees (see section 1.12B). Additionally, Friends organizations are prohibited by law from
using appropriated Federal funds, resources, or support to conduct lobbying activities. The
Friends organization has the discretion to count those hours in some other way (e.g., as its own
community service hours).
C. Our work with Friends organizations must comply with the following gambling, lobbying, and
fundraising policies and laws:
(1) 50 CFR 27.85, Gambling;
(2) 5 CFR Part 735, Employee Responsibilities and Conduct;
(3) 41 CFR 101-20.306, Management of Buildings and Grounds;
(4) 18 U.S.C. 1913, Lobbying with Appropriated Moneys; and

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(5) 374 DM 6, Donations Guidelines.

FRIENDS ACTIVITIES
1.11 Do Friends members need to sign Volunteer Service Agreements? Individual Friends
members who work in an official Service volunteer capacity (see section 1.12) must complete a
Volunteer Service Agreement (OF 301A). The Volunteer Service Agreement covers the individual
volunteer for tort claims under the Federal Tort Claims Act provisions (28 U.S.C. 2671) and for
injuries under the Federal Employees Compensation Act (5 U.S.C. 81). There are several
elements to a Volunteer Service Agreement that require careful attention (also see 150 FW 1-3,
Volunteer Services Program):
A. Each individual Friend must fill out a Volunteer Service Agreement before beginning volunteer
work in an official Service volunteer capacity. The Agreement is not intended as a blanket
volunteer agreement for Friends organizations. For tort claims and injuries, the Volunteer Service
Agreement only covers volunteers as individuals, not the entity of the Friends organization.
B. It is the responsibility of Service employees to ensure that the scope of the volunteer
services (duties) the volunteer will perform are accurately described in the “description of
service to be performed” section of the agreement. Failure to complete this section of the
agreement with the appropriate amount of detail could result in legal complications if there is a
tort claim or injury.
C. Volunteer Service Agreements are effective for up to 1 year, and must be reviewed and
modified annually and any time a change is made to the volunteer’s scope of work, including (but
not limited to) the use of equipment, assignment locations, and physical activity requirements.
Keeping the agreement up to date is important to ensure fair protection for tort claims and injuries,
especially as the complexity of the volunteer assignment increases.
1.12 Should Project Leaders include work contributions by Friends members in their
annual site volunteer totals?
A. Yes, Project Leaders should include Friends members’ and Friends employees’ work
contributions in their annual volunteer totals only when they are performing official Service
volunteer activities, on or off Service-managed property, under an approved Volunteer Service
Agreement. Official Service volunteer activities may include, but are not limited to:
(1) Leading Service environmental education programs and site tours;
(2) Helping with Service biological and maintenance programs;
(3) Planning, conducting, or staffing community outreach activities and special events on behalf of
the Service;
(4) Staffing Service visitor centers and special events;

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(5) Implementing grant projects in support of joint goals of the Friends organization and the
Service;
(6) Attending training and conferences that will be beneficial to the Service and are approved by
the Project Leader; and
(7) General board meetings when the agenda is focused on the direct support of the Service or
joint goals and not the operation or administration of the Friends organization (see section 1.12C).
B. Project Leaders must not include as official Service volunteer hours the time Friends spend on
any activities that neither Service employees nor Service volunteers are permitted to do and are
not in direct support of the Service mission (see section 1.15C). These prohibited activities
include:
(1) Lobbying: Influencing or attempting to influence Members of Congress or any government
official on legislation. Legislation includes action by Congress, any State legislature, any local
council, or similar governing body, with respect to acts, bills, resolutions, or similar items, or by
public referendum, ballot initiative, constitutional amendment, or similar procedure (see section
1.10B).
(2) Soliciting donations: Commonly referred to as “fundraising,” soliciting for donations includes
seeking donated funds or other non-monetary or in-kind gifts such as services, items, and real
property from a non-Federal entity, group, or individual without consideration or an exchange of
value (see section 1.10B).
(3) Administering games of chance or gambling: Examples include, but are not limited to, raffles
for a fee, door prizes for a fee, lotteries, BINGO, etc. (see section 1.10B and 633 FW 4).
C. As stated in section 1.12A(7), we cannot include activities for operation and administration of
a nonprofit organization as volunteer services. Examples of operation and administration
include, but are not limited to: serving on a Friends Board of Directors; the administration of a
Board of Directors and its employees; completing State and Federal nonprofit requirements,
such as writing bylaws and applying for tax-exempt status under Section 501(c)(3) of the
Internal Revenue Code; board meetings that are focused on the business and management of
the board and organization, the operation and administration of a nature store; developing
organizational documents, executing business transactions, and completing grant applications
on behalf of Friends; maintaining the Friends website or social media sites; and creating
newsletters.
1.13 What activities must Project Leaders ensure that Friends do not participate in on
Service-managed property? Project Leaders must not:
A. Involve Friends in law enforcement activities;
B. Involve Friends in any Service administrative functions that are sensitive in nature, such as
employee hiring, discipline, or other activities that would require access to personnel files or
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materials protected by the Privacy Act;
C. Involve Friends in hazardous activities without proper certifications;
D. Permit Friends to participate in lobbying and games of chance on Service property;
E. Allow Friends to participate in and promote activities that are inconsistent with the National
Wildlife Refuge System Improvement Act, Departmental and Service policies, and the objectives
or purposes of the Service site or program with which they are affiliated; or
F. Allow Friends to influence decision-making processes related to fish and wildlife management
that may be inconsistent with the Service’s compliance with State laws and regulations or affect
our timely coordination and consultation with the States on the acquisition and management of
national wildlife refuges (see 601 FW 7, Coordination and Cooperative Work with State Fish and
Wildlife Agencies).

SERVICE INTERACTION WITH FRIENDS
1.14 What is the Service’s role in establishing new and maintaining Friends organizations?
Although we may actively encourage the formation of Friends organizations to assist us in
attaining our mission, the Service and its employees are prohibited from actually forming Friends
organizations (e.g., formally recruiting citizens to fill board positions, completing Internal Revenue
Service (IRS) applications, developing organizational documents). Members of the public must
form Friends organizations, and their formation must comply with the requirements of applicable
State and Federal laws regarding incorporation, charitable status, etc. However, Service
employees may provide certain resources to help in establishing and maintaining Friends
organizations. For example, Service employees may:
A. Provide office space and help with organizing and hosting Friends meetings, including
consulting with interested citizens about the Service’s interest in establishing a Friends
organization or providing information about vacant board positions;
B. Provide information, technical assistance, training, and mentoring to the board to increase the
effectiveness of the Friends organization or the Service-Friends partnership, or both;
C. Engage the Friends organization in strategic planning opportunities for the partnership to help
identify joint projects between the Service and Friends (e.g., general board meetings or special
retreats, Service annual work planning meetings, Service staff meetings). Employees can find
guidance for possible projects by reviewing appropriate management and planning documents
(e.g., Comprehensive Conservation Plans, Visitor Services Plans);
D. Provide a variety of support services to Friends at local, State, regional, and national levels;
E. Provide opportunities for recognition of Friends organizations; and
F. Participate in Friends activities, programs, services, projects, and meetings that help meet the
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joint goals of the partnership, whether on or off-site, except when they contain the prohibited
activities we describe in section 1.12B. Service employees remain subject to applicable ethics
laws and regulations, including, but not limited to, the Standards of Conduct for Employees of the
Executive Branch and the Department’s supplemental regulations when performing these duties.
1.15 May Service employees and volunteers be Friends members and serve on a Friends
Board of Directors?
A. Service employees may:
(1) Be members of Friends organizations, pay membership dues, and participate in membership
votes in their personal capacity (as a private citizen on their own time). Service employees, even
in their personal capacity, must avoid participating in any Friends activities that could be a conflict
of interest with the employee’s official duties and are required to obtain ethics approval prior to
engaging in certain outside work or activities (including certain volunteer roles) with Friends
organizations. Examples of Friends organization participation that may raise ethics concerns may
include serving on a Friends Board, making financial or administrative decisions for Friends
groups, or negotiating/executing contracts on behalf of the Friends group. For more information,
contact your servicing Ethics Official and see 212 FW 4.
(2) Serve on Friends committees in an official capacity, subject to managerial approval and ethics
review, as long as those committees are not involved in lobbying, games of chance, solicitation of
donations, or the operation and administration of the organization (see section 1.12B).
Committees are a way for employees to assist in the mutual goals of the partnership. Certain
official capacity participation may be limited by ethics or other restrictions and Service employees
should obtain additional approval before serving on Friends committees in an official capacity.
B. Service volunteers may:
(1) Be members of Friends organizations, serve on a Friends Board of Directors, pay membership
dues, and participate in membership votes in their personal capacity (as a private citizen on their
own time). Service volunteers who are Federal employees should consult their ethics officials for
additional guidance on their volunteer activities.
(2) Perform volunteer work for the Friends organization as a Service volunteer as long as the work
supports mutual goals of the partnership under an approved Volunteer Service Agreement and
meets the guidance on volunteer work contributions in section 1.12.
C. When participating in Friends organizations, Service employees must comply with applicable
Federal ethics laws and regulations and the Department’s supplemental regulations.
1.16 What responsibilities should the Service require of Friends organizations? The Service
should require that Friends organizations:
A. Work with the Service to achieve the purposes defined in the Friends Partnership Agreement
and any supplemental agreements and ensure that the time Service site staff invest in the
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partnership is efficient, effective, and sufficient.
B. Work with the Service to ensure the Friends Partnership Agreement is current and approved
and maintain current tax-exempt status under Section 501(c)(3) of the Internal Revenue Code and
State laws.
C. Work with the Service to regularly assess compliance with Friends program policies and
procedures, effectiveness of internal controls, and accountability for revenues, donations, and
expenditures.
D. Independently manage the legal, financial, personnel, and administrative activities and
responsibilities of the organization (see 633 FW 2).
E. Identify a Friends Liaison, typically the president or other board member, to facilitate
communication with the Project Leader or Service Liaison about Friends activities and projects.
F. Coordinate with the Project Leader or Service Liaison on all activities, programs, services, and
projects related to meeting the joint goals of the partnership.
G. Notify and invite the Project Leader or Service Liaison to Board of Directors and committee
meetings that require Service information and support to carry out joint activities.
H. Ensure that Friends members and their employees do not act in any way that leads to the
public perception that they are Service employees. This does not keep Friends from conducting
routine volunteer services (as a Service volunteer), such as working in a visitor center or
performing interpretive activities.
I. Ensure appropriate identification (e.g., logo shirt, name badge) of Friends members and Friends
employees while acting on behalf of the Friends organization on Service-managed property.
J. Avoid any implication in all of its activities that the Service endorses a particular commercial
product, political position, or fundraising activity (see 633 FW 4).
K. Transfer all net funds collected through activities that directly solicit donations (e.g., silent
auction, plant sale, benefit event) on Service-managed property directly to the Project Leader
to be deposited in the appropriate Service Contributed Funds Account (e.g., Gifts account,
Community Partnership Enhancement Donation Receipt account) (see 633 FW 4).
L. Display a sign that identifies nature stores as nonprofit activities of the Friends organization
in support of or on behalf of the Service site/program (see 633 FW 4).
M. Cooperate in Service efforts to comply with Departmental and Service policies,
procedures, and standards regarding ethics laws and regulations, and provide information to
Service employees regarding Friends meetings, events, and activities to assist them in
complying with ethics laws and regulations, including the Standards of Ethical Conduct
for Employees of the Executive Branch.
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SERVICE SUPPORT TO FRIENDS
1.17 May the Project Leader extend the use of Service facilities, equipment, and vehicles to
a Friends organization? Yes, Friends may use Service facilities, equipment, and vehicles
consistent with Service and Departmental policies and guidelines and as mutually agreed upon
within an approved Friends Partnership Agreement.
A. Departmental policies and guidelines prohibit Friends organizations from using appropriated
Federal funds and Federal facilities and equipment, including, but not limited to, Governmentprovided office space, vehicles, telephones, computers, printers, faxes, or copy machines to
conduct lobbying activities. For example, Friends meetings that are held to discuss influencing a
Member of Congress or specific legislation must not be held in Government-provided meeting
space, and emails must not be composed on Government-provided or Friends-owned computers
on Service-managed property. The same applies for administering games of chance (see section
1.10B, 1.12B, and 633 FW 4).
B. Friends use of Government facilities and equipment (access to non-public areas, federallycontrolled information systems, etc.) must comply with Homeland Security Presidential Directives
(HSPD) that mandate common identification standards for Federal employees, volunteers,
Friends, and contractors before they can use the facilities, equipment, or information. Friends
representatives may need to obtain Federal security clearances to conduct the business of the
Friends organization on Service-managed property and equipment.
C. When working as an official Service volunteer, Friends may operate Government-owned
vehicles to assist the Service in carrying out Service programs under an approved Volunteer
Service Agreement (OF 301A). Friends, when serving as volunteers in Government-owned
vehicles, either driving or as passengers, may represent their Friends organization as it relates to
the mutual goals of the Service and the organization, but they must not engage in any prohibited
activities while operating Government-owned vehicles (see section 1.12B, 633 FW 4, and 320 FW
3, Motor Vehicle Use).
D. The Project Leader must ensure that the Friends organization is providing reasonable care,
maintenance, and housekeeping of the Service property/facilities/equipment they are using.
E. The Project Leader may allow the Friends organization to alter Service facilities through
redesign, renovation, or construction, with prior approval, to carry out new sales, storage, or
routine work. If the redesign, renovation, or construction is extensive, the terms of such renovation
and use should be described and approved in the Friends Partnership Agreement. All permanent
improvements a Friends organization makes to Service facilities become the property of the
Service. Nonpermanent or portable improvements belonging to the Friends organization remain
the organization’s property. The Project Leader may require Friends to repair any damages made
to Service facilities as a result of the installation of nonpermanent improvements.
F. The Project Leader retains the right to have emergency access to all Service facilities that
Friends organizations use.

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G. The Project Leader may withdraw the use of land or withdraw, modify, or relocate facilities,
equipment, or vehicles from Friends at any time for management or emergency reasons.
Whenever possible, the Project Leader should give the Friends organization a 60-day written
notice and meet with the Friends President or Executive Director beforehand to discuss
relocation options or the decision to withdraw, and to give the organization the opportunity to
address the reasons leading to that action. Project Leaders should give strong consideration
to the loss of business income the organization may incur as a result of the withdrawal and
make every possible attempt to remedy the situation.
1.18 What can the Service provide in addition to the use of facilities? In addition to providing
Friends with the use of facilities, equipment, and vehicles, the Service may provide:
A. Utilities, such as water, electricity, heat, air conditioning, internet, and phone to the extent that
these utilities are available and previously required for the operation of the building and other
Government purposes. The Project Leader may require that the Friends organization provide for
their own utilities if expenses are above and beyond what is required for Government purposes.
(1) Friends must comply with Homeland Security Presidential Directives (HSPD) that mandate
common identification standards for Federal employees, volunteers, Friends, and contractors
before they can use Government computers or networks. This means that Friends representatives
would need to obtain Federal security clearances, paid for by the requesting office, prior to
conducting the work of mutually agreed-upon programs and projects on Service-managed
computers or networks.
(2) For conducting the operation and administration of the Friends organization, Friends may use
or install, if approved by the Project Leader, an unsecured internet connection. Friends may
purchase a separate unsecured line or wireless connection to use as long as they do not connect
to the Service’s network, and the Friends are using their own computers. Friends must ensure
they do not conduct activities in association with lobbying or games of chance on Servicemanaged property, even if using their own computers (see section 1.12B).
B. Contracted housekeeping and general upkeep (e.g., light bulb replacement, trash removal) to
the extent that the Government is already providing these services for the overall operation of the
building. Any specialized upkeep needed by the Friends organization that is beyond the general
operational expenses of the building is the responsibility of the Friends organization (e.g.,
specialized light bulbs for a nature store display).
C. General maintenance of Government facilities used by Friends, not including maintenance of
Friends-owned property such as, but not limited to, nature store shelving, cash registers, and
computers.
1.19 May a Project Leader use Federal funds to support a Friends organization? Yes,
subject to availability and using procurement procedures and requirements found in 301 FW 1
through 7, Acquisition Policies and Procedures, the Service may use Federal funds to support the
Friends organization only for expenses directly related to the projects and programs that support
the Service mission. The Service may not use Federal funds to support a Friends organization’s
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activities or projects related to lobbying, games of chance, fundraising activities, or the operation
and administration of a Friends organization, including the purchase of a Friends organization’s
personal property (see section 1.12B and 633 FW 2 and 4).
1.20 May the Service co-sponsor or participate in Friends off-site events? Yes, the Service
may co-sponsor and participate in Friends-sponsored events that are not on Service-managed
property if:
A. The event is in direct support of the Service site (or sites) or Service program(s) that are the
subject of the underlying Friends agreement;
B. The event does not include lobbying activities;
C. The Service and the Friends organization ensure that there is not any express or implied
involvement or endorsement of the Service in any solicitation of donations and games of chance
activities at the event, and that the event activities do not expressly state or otherwise imply the
Service’s endorsement of a particular commercial business, brand, product, service, or enterprise;
and
D. The Service has ensured that the Friends hold appropriate liability insurance, as determined by
a qualified professional, and the Service is held harmless for any liability associated with the offsite event.

/sgd/ Stephen Guertin
Deputy Director
Date: July 2, 2021

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