Re-directing prohibited honoraria

May a City employee re-direct an honorarium that is prohibited by the State Ethics Act to a third-party?  

No. Pursuant to Section 1103(d) of the State Ethics Act, a public employee may neither accept an honorarium nor redirect such honorarium to a third-party, even if that third-party is a non-profit or charitable organization.  

These advice tidbits are for reference only. They are not intended as legally protective guidance or binding interpretation of laws within the Board's jurisdiction. You can request individualized informal advice by contacting BOEGCStaff@phila.gov or clicking the Ask for Advice button on the Board's website.