Trump for America, Inc. Code of Ethical Conduct
Lt. Gen. Flynn’s involvement in advising Mr. Trump on matters relating to Turkey or Russia—including attending classified briefings on those matters—could violate the Trump for America, Inc. Code of Ethical Conduct, which states:
I will disqualify myself from involvement in any particular transition matter which to my knowledge may directly conflict with a financial interest of mine, my spouse, minor child, partner, client or other individual or organization with which I have a business or close personal relationship. Where there is no such direct conflict, but there may be an appearance of a conflict, I will address this issue for resolution to the TFA General Counsel. I currently have no knowledge of any such conflicts.
In addition, a Memorandum of Understanding signed on November 8, 2016, by the former Chair of the Transition Team, Chris Christie, and White House Chief of Staff Denis McDonough requires that in order to obtain non-public information, including classified information, the Transition Team must:
Require the Transition Team member to sign a statement representing that, to the member’s knowledge, he or she has no financial interest or imputed financial interest that would be directly and predictably affected by a particular matter to which the information is pertinent.
The Memorandum of Understanding also requires the Transition Team to ensure that each member “has agreed to abide by the Transition’s Code of Ethical Conduct, and has thereby represented that he or she has no conflict of interest that precludes the individual from working on the matters the individual has been assigned to work on with the EOP or relevant Department or Agency.”
https://oversight.house.gov/news/press-releases/cummings-requests-documents-relating-to-michael-flynn-s-apparent-conflicts-of