This memo from the Executive Director of the Ethics Commission advises legislators that they cannot accept invitations to an annual reception hosted by the Pacific Resource Partnership (PRP). PRP is a lobbying organization that advocates for legislation benefiting Hawaii's construction industry. The reception involves food, drinks, and opportunities for legislators to meet with PRP members. As the per person cost is around $100 and its purpose is purely social networking, accepting the invitation could be seen as intended to influence or reward official action, which would violate state ethics rules. Legislators can provide additional information to argue there is a clear state benefit to their attendance.

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January 9, 2012
MEMO TO: Legislators (Via Email)
FROM: Leslie H. Kondo, Executive Director
SUBJECT: Invitations to The Pacific Resource Partnership’s Annual Reception
honoring the recipient of the 2012 Hawaii Carpenters Union
Outstanding Union Builder Award
We received an inquiry from a legislator regarding an invitation to The Pacific
Resource Partnership’s Annual Reception honoring the recipient of the 2012 Hawaii
Carpenters Union Outstanding Union Builder Award.1 It is our understanding that The
Pacific Resource Partnership (“PRP”) has extended invitations to the event to certain
government officials, including all legislators. Because it is our position that the State
Ethics Code does not allow you to accept the invitation, we are addressing this
memorandum to all legislators.
We understand that the reception involves heavy pupus and an open bar and is
scheduled for Tuesday, January 10, 2012, at the Oahu Country Club, from 5:30 p.m. to
7:30 p.m. From our discussions with John White, PRP’s Executive Director, we also
understand that the reception is a social, “meet-and-greet” type of event, an opportunity
for PRP’s members to meet and talk to legislators and other government officials.
Initially, we understood that PRP estimated the per person cost of the reception to be $40;
however, we subsequently understand that the per person cost is approximately $100.
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On its website, the Pacific Resource Partnership (“PRP”) describes itself as “operat[ing]
actively and effectively with all levels of government, successfully advocating for legislation and
public policy that benefit Hawaii’s building industry and its workforce.” In addition, PRP states that,
“[a]s the voice of the construction sector, we often take a lead role on prominent issues that are
decided at the federal, state and county levels, such as capital improvement spending, land use,
zoning, job training, and tax incentives. We introduced and supported legislation and regulations
that protect workers’ rights, enforce business and labor laws, procurement, fair hiring, licensing,
and jobsite security.” http://www.prp-hawaii.com/Government-Relations.aspx.
PRP is registered with the Commission as an organization which employs a lobbyist.
For the period March 1, 2011 through April 30, 2011, and the period January 1, 2011 through
February 28, 2011, PRP reported lobbying expenditures of $3,749.21 and $3,832.43, respectively.
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Memorandum to Legislators
January 9, 2012
Page 2
The State Ethics Code prohibits state employees from accepting any gift, including
a meal or an invitation to a “food-and-drink” event, if it is reasonable to infer that the gift
is intended to influence or reward official action.2 With respect to the PRP reception,
considering: (1) the host is a company involved in lobbying activities and appears to
advocate on many state-related issues, (2) the per person cost is significant, (3) the event
is a “meet-and-greet” function, purely social in nature, and (4) there does not appear to be
(and nobody has suggested that there is) a “state benefit” associated with legislators or
other government officials’ attendance at the reception, we do not believe that the Ethics
Code allows the acceptance of PRP’s invitation to the reception.
You are welcome to provide us with additional information that may allow us to
better understand the “state benefit” in your attendance at the event. If you have questions
or would like to discuss our position further, please do not hesitate to contact us.
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For more information about the types of gifts that may be accepted under the State Ethics
Code, please refer to the Ethics Commission’s publication, “Guidelines for Gifts Under the State
Ethics Code.” The guidelines are available through the Commission’s website at
http://hawaii.gov/ethics/pubsguides/gifts/GiftsGuidelines.pdf.
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