What is the Departments definition of “directly or indirectly?
A15. Directly or indirectly refers to any course, avenue, or method. Directly encompasses holdings and transactions in which the labor organization officer or employee, spouse, or minor child receives a payment or other benefit without the intervention or involvement of another party. Indirectly includes any payment or benefit which is intended for the labor organization officer or employee, spouse, or minor child or on whose behalf a transaction or arrangement is undertaken, even though the interest is held by a third party, or was received through a third party. Q16. I am employed by XYZ Widgets and also serve as the president of the local labor organization representing XYZ Widgets employees. During a recent conversation with the XYZ Widgets human resources manager, I mentioned that I am placing my 15 year-old daughter in a private school. Shortly thereafter, XYZ Widget Company sent me a check for $1,000 with a note saying “Good luck with the new school!” Must I report the check? A1
