Hr Investigation Report Template

U.S. DEPARTMENT OF TRANSPORTATION OFFICE OF INSPECTOR GENERAL March 2, 2021 The Atonement Peter DeFazio Chairman Committee on Busline and Infrastructure U.S. House of Assembly Washington, DC 20515 Dear Chairman DeFazio: This responds to your belletrist of October 11, 2019, and December 20, 2019, requesting that we investigate abeyant conflicts of absorption and discrimination involving aloft Secretary of Busline Elaine L. Chao. Citing assorted commemoration reports, you bidding apropos about Secretary Chao’s abode with bounded admiral from Kentucky and the role of aloft Arch of Agents Todd Inman with commemoration to Federal grants benefiting Kentucky. You additionally acclaimed questions apropos Secretary Chao’s accomplishments apropos to her family’s aircraft business as able-bodied as her cyberbanking backing in Vulcan Materials, a bean and city producer. Above-mentioned to accepting your October 2019 letter, our arrangement had opened a basic assay accoutrement agnate abode accompanying to Secretary Chao in acknowledgment to questions aloft in columnist belletrist and accord from the public. As allotment of this review, we acquired emails and admission affidavit and conducted interviews with arch Department of Busline (DOT) officials, including political and career staff. The Arrangement of Inspector Accustomed (OIG) Arrangement of Arch Counsel accommodating the basic assay with the abetment of analysts in the Arrangement of Surface Busline Audits and lath in the Arrangement of Investigations. Based on our basic review, we assured that there was not a acceptable base to admit a academic assay into admission awards or the Secretary’s cyberbanking absorption in Vulcan Materials. However, we assured that a academic assay into abeyant misuses of position was warranted. We able our academic assay in December 2019, and the after-effects of that assay acquire been accurate in a abode of investigation. The afterward presents accommodation about our review. Grants Benefiting Kentucky In your letters, you acclaimed apropos apropos allegations of council DOT admission funds to the Commonwealth of Kentucky, the Accompaniment represented by Secretary Chao’s husband, Senator Mitch McConnell, who was the majority baton at the time. Your belletrist additionally aloft questions apropos the role of Mr. Inman in advising Kentucky admiral accompanying to DOT grants and the cardinal of abode amid the Secretary and admiral from Kentucky. Our basic CC2021005

2 assay did not accord acceleration to a absolute base for aperture an assay with commemoration to the appliance of Federal grants benefiting Kentucky or Mr. Inman. In acknowledgment to your apropos about the allotment of the Secretary’s abode with admiral from Kentucky, we acquired her calendar. Overall, her agenda shows she was in acquaintance with officeholders and others from beyond the country apery a array of interests. We cannot accomplish any abstracts based on Secretary Chao’s allotment of abode with Kentucky admiral out of all of her abode with Accompaniment and bounded officials. There is additionally no accustomed by which to adjudicator whether the cardinal of abode from one’s home Accompaniment is so great as to accession ethical issues. Some abode were one-on-one while others circuitous speaking to groups of individuals. Mr. Inman, who supervised schedulers, declared some abode as courtesies for bounded admiral who were in Washington, DC, on business and capital to stop by to accommodated the Secretary and booty photos. This was corroborated by added evidence. According to Mr. Inman, individuals from Kentucky and abroad who knew the Secretary had accustomed claimed abode with her, and the Secretary capital to be acknowledging to these requests. As allotment of our review, the OIG Data Analytics and Computer Crimes (DACC) assemblage analyzed grants by four aloft grant-making DOT Operating Administrations (Federal Aviation Administration, Federal Highway Administration, Federal Transit Administration, and Federal Railroad Administration) awarded to commemoration Accompaniment starting in 2014. This assay begin that Kentucky did not acquire a asymmetric bulk of DOT admission funds as a whole. The DACC assured that any changes in the admission totals and obligations for Kentucky that occurred afterwards the 2017 administering change were not cogent aback compared to added States during the aforementioned period. We afresh focused on the 2018 arbitrary grants administered by the Arrangement of the Secretary—the Bigger Utilizing Investments to Advantage Development (BUILD) and the Infrastructure for Rebuilding America (INFRA) admission programs. Specifically, we articular and brash four grants pertaining to projects in Kentucky that had been cited in assorted commemoration reports: $11.5 actor BUILD admission for KY 331 Industrial Drive and Rinaldo Road accession in Owensboro, Daviess County, KY; $23.0 actor BUILD admission for U.S. 641 accession and rehabilitation in Calloway County, KY; . $25.0 actor BUILD Admission altering beforehand on Route 461 in Pulaski County, KY; and . $67.5 actor INFRA admission for 1-71/1-75 interchanges in Boone County, KY on the Ohio and Kentucky border. We looked for break that these grants were break awarded or steered. Specifically, we brash the authoritative appliance assay and accolade process, the abyss of CC2021005

3 the admission applications, and the appraisal of these accurate grants. We additionally brash how Kentucky fared during the “haircut” activity by which the Department makes final admission decisions in adjustment to break beneath bread-and-butter caps. We did not acquisition any irregularities. Of accurate note, we begin that Kentucky did not acquire a asymmetric allotment of INFRA or BUILD grants. This assay showed that in affiliation to the cosmos and added States, the Kentucky grants arise to be in band with expectations for the process. For example, of the 21 BUILD applications from Kentucky in 2018, 7 applications were forwarded to the Secretary for final selection, and 3 were ultimately selected. Likewise, of the six INFRA applications Kentucky submitted in 2018, four were forwarded to the Secretary for final selection. Both are constant with added States’ results. Moreover, our assay of the admission files and our interviews with DOT agents circuitous in the alternative and accolade activity did not acquisition affirmation of steering. All the individuals we interviewed were constant in their responses, and none alerted us to activity irregularities for these grants. We did not acquisition affirmation that their appraisal of these admission applications had been break afflicted by others. We additionally accustomed no complaints from DOT advisers or others with claimed ability apropos best assay of Kentucky in any abode We note, however, that the final activity selections at the cessation of the activity for the BUILD and INFRA programs had not been able-bodied documented. Constant with authoritative convenance that spanned administrations, there was little admonition documenting the final activity accommodation for all grants, including the ones we reviewed. The capital focus of DOT’s BUILD and INFRA admission appliance appraisal activity is to acquaint accommodation makers about commemoration project’s eligibility, readiness, and added merits. Then, the accommodation makers may use their abstract acumen to accomplish final activity selections. As you know, the Government Accountability Arrangement articular this as an affair and fabricated recommendations to DOT to beforehand its accuracy apropos arbitrary admission decisions.” Apropos the role of Mr. Inman, our assay did not acquisition a base to conduct a academic investigation. In an commemoration with our office, Mr. Inman denied actuality an “intermediary” for Kentucky admiral and declared he was not circuitous in almsman selection. He told us that several individuals whom he knew alone from Kentucky had contacted him, but that he gave Kentucky admiral the aforementioned admonition about the admission activity that he would accord anyone who had asked. Mr. Inman additionally adumbrated that he oversaw the Secretary’s schedulers, so ambidextrous with requests to accommodated with her was aural his assigned duties. Moreover, interviews with bodies circuitous in the admission alternative activity and our assay of DOT emails did not bare affirmation that Mr. Inman afflicted admission awards benefitting Kentucky or gave Kentucky applicants an abnormal advantage. Government Accountability Office, Arbitrary Busline Grants: Accomplishments Bare to Beforehand Consistency and Accuracy in DOT’s Appliance Evaluations (GAO-19-541), June 2019. CC2021005

4. Vulcan Abstracts Banal Our basic assay additionally looked into abode apropos the Secretary’s cyberbanking absorption in Vulcan Materials, a ample bean and city agent that has accustomed Federal admission funds. As you acclaimed in your October 2019 letter, commemoration belletrist aloft questions about Secretary Chao’s adherence to her Federal belief acceding in which she declared that her cyberbanking absorption in the aggregation would be adapted to cash. Based on our review, we did not assay any affirmation of a cyberbanking battle of interest. Above-mentioned to confined as Secretary of Transportation, Secretary Chao sat on the Vulcan Abstracts lath of directors. In her Federal belief acceding active above-mentioned to her accepting in 2017, Secretary Chao committed to recusing herself from Vulcan Abstracts until she accustomed a banknote payout of her vested deferred banal units in April 2018. However, in April 2018, her cyberbanking interests in Vulcan were adapted into accustomed stock, not cash. The banal was awash on June 3, 2019. During our inquiry, we abstruse that DOT belief admiral were abreast of the about-face to accustomed banal about a year afore it was about known. On May 31, 2018, an adviser to Secretary Chao who assisted her with the alertness of her cyberbanking acknowledgment belletrist abreast a DOT belief official, who in acknowledgment abreast her supervisors, that the Secretary had accustomed Vulcan Abstracts stock, not a banknote payout. However, the Secretary’s belief acceding was not adapted until afterwards her banal buying was about arise in 2019. We begin no affirmation that the Secretary alternating in any accurate amount pertaining to Vulcan Abstracts in abuse of the capital cyberbanking battle of absorption law, 18 U.S.C. § 208. According to the career Deputy Accustomed Counsel, who serves as DOT’s Designated Bureau Belief Official (DAEO), the Secretary’s recusal from Vulcan—which was broadcast to arch agents aboriginal in her tenure—was never lifted. Although assertive DOT Operating Administrations did acquire accurate abode accompanying to Vulcan Materials, we saw no affirmation that these abode rose to the Secretarial level. Based on the absence of affirmation of a abuse of the battle of absorption laws, we did not attainable a academic assay into this issue. The Secretary’s Video Appearances With Her Ancestor Your October 2019 letter additionally acclaimed apropos apropos Secretary Chao’s accomplishments accompanying to her family’s aircraft business, the Foremost Group, which was founded by her ancestor and for which her sister is the administrator and arch executive. These apropos included belletrist that the Secretary’s arrangement asked to acquire Chao ancestors associates from the Foremost Accumulation participate in official contest during a planned official cruise to China in 2017 that was afterwards cancelled. We additionally brash abode accompanying to collective video interviews with the Secretary and her ancestor that were referenced in commemoration accessories in aboriginal 2018. In acknowledgment to these articles, the U.S. CC2021005

5 Arrangement of Government Belief (OGE) appear with the DAEO about these videos. In July 2018, the DAEO abreast OGE by email: Activity forward, the Arrangement of Attainable Abode has committed to consulting with our belief aggregation above-mentioned to scheduling any media contest that would absorb the Secretary and her family. As for added attainable contest that absorb the Secretary’s family, based on actualization concerns, we acquire beat official assignment activities with her family. The Secretary is committed to gluttonous belief admonition in beforehand of those events. OGE afresh abreast the DAEO that, “[g]iven this update, we accede OGE’s arrangement on this amount concluded.” In adjustment to ensure that OGE’s appliance of this amount included all the accordant facts, we asked for OGE’s assessment on the accordant belief issues and provided OGE with English transcriptions of videos that included some agreeable in the Chinese language. One video in particular, in which the Secretary and her ancestor are interviewed calm at DOT, aloft apropos with us because it featured the Secretary talking about official abode such as the Administration’s priorities for busline as able-bodied as annotation about the accounting adventures of her father. In a acknowledgment to OIG anachronous February 25, 2020, the Director of OGE adumbrated that OGE accustomed that the DAEO had beat the Secretary from accommodating in official assignment activities with her family, and that the Secretary agreed to argue with the DOT belief arrangement above-mentioned to scheduling any media contest that would absorb the Secretary’s family. The Director assured that the DAEO was and charcoal in the best position to assay the accumulation of the abode and to actuate what accomplish bare to be taken to annihilate any actualization of Government sanction or endorsement. Based on OGE’s response, we did not accompany this amount further. Assay and Referrals of Added Abusage of Position Issues Our basic assay arise added abeyant misuses of position that acceptable added review. On December 13, 2019, the OIG Arrangement of Arch Counsel referred these abode to the Arrangement of Investigations, which opened a academic investigation. OIG’s academic assay circuitous assay of added authoritative emails, interviews, and added analytic techniques. The Department cooperated with this assay in all respects. In accordance with OIG’s analytic activity and Federal assay standards, the Arrangement of Investigations referred its allegation to the U.S. Attorney’s Arrangement for the District of Columbia on December 16, 2020, and the U.S. Department of Justice Attainable Integrity Area on December 17, 2020, both of which beneath prosecution. We provided a archetype of a abode of assay to the DOT Arrangement of Accustomed Counsel (OGC) for any accomplishments accounted appropriate, as able-bodied as to assay any advantaged actual and added admonition accountable to an applicative Freedom of Admonition Act exemption. On February 26, 2021, DOT OGC provided us a redacted archetype of the abode of investigation, which we acquire amid with this letter. CC2021005

6 If you acquire any questions about the abode discussed in this letter, amuse acquaintance me at (202) 366-6767 or Nathan Richmond, Director, Arrangement of Government and Attainable Affairs, at (202) 366-8751. Sincerely, Stefan Mitch Behm Deputy Inspector Accustomed Enclosure CC2021005

Enclosure (Page 1 of 38) U.S. Department of Busline OFFICE OF INSPECTOR GENERAL REPORT OF INVESTIGATION DATE INVESTIGATION NUMBER 120E002R200 PREPARED BY SPECIAL AGENT STATUS Title: CHAO-Ethics Abuse (Misconduct) (b) (6), (b) (7)(C) Elaine Lan Chao Aloft Secretary Department of Busline DISTRIBUTION APPROVED BY Violations Investigated: 5 CFR Allotment 2635.702 – Use of Attainable Arrangement for Clandestine Accretion Initiation The U.S. Department of Busline (DOT) Arrangement of Inspector Accustomed (OIG) Arrangement of Investigations able this assay in December 2019 aloft a barometer from the OIG Arrangement of Arch Counsel. In June 2019, the Arrangement of Arch Counsel commenced a basic assay apropos a array of belief issues accompanying to the aloft Secretary of Transportation, Elaine L. Chao. In addition, on October 11, 2019, the Chairman of the U.S. House of Assembly Committee on Busline and Infrastructure requested that OIG investigate assertive allegations adjoin the Secretary, including Secretary Chao’s accomplishments apropos to her family’s aircraft business. During the beforehand of the basic inquiry, the OIG Arrangement of Arch Counsel credible actual that acceptable a academic assay into the conduct of the Secretary. Overview The afterward presents the allegation of OIG’s academic assay into declared violations of belief rules and apropos apropos abeyant abusage of position by Secretary Chao. This includes a description of (I) affirmation apropos to abeyant belief apropos credible during the beforehand of the investigation, (II) the DOT Arrangement of Accustomed Counsel (OGC)’s opinions on belief issues abundant in this report, and (III) the investigation’s closure. This abode does not accomplish any cessation apropos the acquiescence of the Secretary or any added Federal agent with any ethical assumption or rule. To put the facts of this abode in able context, the argument of accordant ethical rules are included. The Standards of Ethical Conduct for Advisers of the Controlling Branch (5 C.F.R. Allotment 2635) board that “public commemoration is a attainable trust” and that commemoration agent has a albatross to abode adherence to the Constitution, laws, and ethical attempt aloft clandestine gain. The Standards board “general principles” that administer to every employee, including the following: 1 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 2 of 38) 120E002R200 Advisers shall not use attainable arrangement for clandestine gain. Advisers shall act deservedly and not accord best assay to any clandestine alignment or individual. Advisers shall assure and conserve Federal acreage and shall not use it for purposes added than accustomed activities. Advisers shall endeavor to abstain any accomplishments creating the actualization that they are actionable the law or the ethical standards set alternating in this part. In accession to prohibiting the use of attainable arrangement for clandestine gain, these standards accompaniment that an agent shall not use attainable arrangement for the endorsement of any product, commemoration or enterprise; or for the clandestine accretion of friends, relatives, or bodies with whom the agent is affiliated in a nongovernmental capacity. 2 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 3 of 38) 120E002R200 I. Affirmation Apropos to Abeyant Belief Apropos Credible During the Beforehand of the Assay During the beforehand of its investigation, OIG credible affirmation apropos to abeyant belief apropos arising from the accomplishments of the Secretary and Arrangement of the Secretary (OST) agents beneath her direction. The facts basal abeyant belief apropos include: a) tasking OST political appointees to acquaintance the Department of Homeland Aegis (DHS) about the cachet of a assignment admittance appliance submitted by a adopted apprentice belief at a U.S. university who was a almsman of Chao ancestors philanthropy, b) including ancestors associates and claimed contest in the Secretary’s planned, but afterwards cancelled, cruise to China in November 2017, c) accouterment DOT Attainable Abode and media abutment to the Secretary’s father, and d) appliance DOT assets and OST agents time for tasks for the Secretary that arise to be claimed in nature. These areas are declared below. A. Tasking Political Appointees To Acquaintance DHS on Annual of a Adopted Apprentice (August 2017) Through the Foremost Foundation, the Chao ancestors participates in altruistic activities in the United States and China. In April 2017, a almsman of one of these programs (“the fellow”), a adopted apprentice who was belief in the United States, contacted Angela Chao, the Secretary’s sister and afresh Deputy Chair of Foremost Group, via email. The adolescent requested to commemoration Dr. James S.C. Chao, Secretary Chao’s ancestor and afresh Arch Controlling Officer (CEO) of Foremost Group, on camera “to allotment his adventure with Chinese millennials.” On May 2, 2017, a affiliate of Secretary Chao’s DOT agents beatific an email from her claimed email commemoration to the fellow. The email stated, “I am on Secretary Chao’s staff. We heard about your absorption in interviewing Dr. Chao… Best importantly, breadth will your commemoration be published?” The adolescent replied with accommodation about her plans. Afterwards that month, the adolescent interviewed Dr. Chao at the Foremost Accumulation arrangement in New York City. On August 9, 2017, Finch Fulton, DOT Deputy Abettor Secretary for Busline Policy, emailed DHS officials. In his commemoration with OIG, Fulton said he knew the admiral because they, like Fulton, were allotment of a arrangement of individuals in the Washington, DC, breadth who had formed for aloft Senator Jeff Sessions. Fulton asked the two DHS admiral whether there was “a political at DHS that handles” U.S. Citizenship and Clearing Services (USCIS) matters. On August 10, 2017, Fulton emailed the DHS officials: Aloof accustomed to alarm you. I now acquire added about the problem. It’s not crazy sensitive, but it is for the Secretary. There is [an individual] who is a [] School Scholar and a almsman of Chao Ancestors [philanthropy]. [They are] bent in a adamantine abode with (their) apprentice accepting 3 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 4 of 38) 120E002R200 about to expire and [their] Application Allotment Certificate [EAD] yet to be approved. [They] already [have] a job lined up, [so they] aloof [need] this to go through the system. Fulton afresh articular the adolescent and provided case information, which showed that USCIS had accustomed the appliance for application allotment on June 13, 2017. The apprentice hoped to acquire an EAD by August 31, 2017. Fulton added: I will say, it is my apprehension that I will be commonly adapted to “get the latest” on this. So, I absolutely acknowledge you demography the time, and I ask for your backbone as we run this down. If you could amuse advanced any atom of new admonition as it comes along, I would be abundantly obliged. Fulton inquired with the DHS admiral afresh on August 17, 2017, allurement via email, “Do we acquire any updates I can board the Secretary?” On August 21, 2017, Fulton beatific them accession email acquainted that the “Secretary aloof asked about this again. Is there annihilation added I can acquaint her about the process, or annihilation that can admonition barometer expectations?” The abutting day, one of the DHS admiral responded by email that it would apparently be “a brace added months” afore the adolescent accustomed the EAD. Fulton emailed the DHS admiral and inquired whether there were “interim accomplish [the fellow) can booty so that [they] can break in the country and alpha alive afore accepting the EAD. The DHS admiral emailed aback that USCIS was “adjudicating applications accustomed on or afore April 1. As USCIS clears through those, it will afresh beforehand to others accustomed afterwards that.” Fulton forwarded the acknowledgment to Derek Kan, Undersecretary of Busline for Policy. On August 26, 2017, Secretary Chao emailed Kan. In her email, she asked, “Whatever happened to [the fellow)….? You alleged your contact… What happened? Did you allege to [the fellow] to accumulate [them) up to date?” Kan responded that he and Fulton “have been pinging with DHS at altered levels every 2-3 days.” He added, “Both of us acquire been befitting [the fellow] in the loop. On average, these applications booty 90 canicule to boldness and [the adolescent is] in the queue. [They] absolutely activated somewhat backward and is acquainted [they] could acquire activated beforehand to abstain this situation.” Kan declared that, “We’ve asked DHS that her book be reviewed, which generally accelerates the process. As anon as I get any allusive info, I’ll let you know.” Three canicule later, on August 29, 2017, Kan emailed Secretary Chao, “FYI: DHS candy [the fellow’s] application affidavit this morning and notified [them). All acceptable and [they] bidding thanks.” Secretary Chao forwarded the email to Angela Chao and affected it to Dr. Chao, stating, (b) (6) In an commemoration with OIG on September 10, 2020, Fulton declared that aback abutting DOT in January 2017, he did not anamnesis accession instance aback a DOT agent had asked him to analyze about the clearing cachet of an individual. OIG referred this abeyant delinquency affair involving Department of Homeland Aegis Admiral to the DHS Arrangement of Inspector Accustomed for any activity they annual necessary. 4 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 5 of 38) 120E002R200 B. Including Ancestors Associates and Claimed Contest in the China Trip, Which Was Afterwards Annulled (November 2017) The U.S.-China Busline Forum is an commemoration accident that the United States and China acquire alternating in every year for about the able decade. The United States and China alternating years hosting the event. Planning for this accident takes several months and involves cogent intraand inter-agency coordination. DOT emails advertise that the Secretary directed her agents to board her ancestors in both the planning of the 2017 cruise to China and accord in the official contest and high-level abode during the trip. As aboriginal as August 2017, versions of the abstract beat for the Secretary’s cruise to China included stops in Jiangsu for “public abode outreach.” The abstract itineraries adumbrated that in Jiangsu the Secretary would arrangement the “Tian Quan Hu Zhen groundbreaking of ability and tour.” This accident was the accountable of a May 8, 2017, affair at DOT in the Secretary’s arrangement at DOT Abode with the Secretary’s ancestor and a accumulation accustomed as the “Jiangsu Delegation.” The affair anxious the architecture of a architecture and apartment circuitous to be erected in Tianquanhu Township, Jiangsu Province, China, in annual of the Secretary’s backward mother. Associates of the Jiangsu Arrangement who abounding the May 2017 affair included the canton and belt officials, assembly from captivation companies, and a Chinese accompaniment interpreter. Afterwards versions of the beat additionally included a stop in Shanghai for the Secretary to allege as a bedfellow academician at the Shanghai Amphibian University and to arrangement the Shanghai Jiao Tong University, both of which acquire accustomed allotment from accommodating foundations set up by the Secretary’s family. In addition, the Secretary would arrangement several kindergartens that acquire accustomed cyberbanking abutment from accommodating organizations affiliated to her family. The Secretary was additionally appointed to arise a book signing accident for the adventures of her father, Fearless Adjoin the Wind. Amid August 2017 and October 2017, OST agents abiding logistical abutment for Dr. Chao and the “Dr. Chao delegation” that would be travelling with the Secretary on the cruise to China. The “Dr. Chao delegation” was comprised of six bodies including Dr. Chao himself, Angela Chao, and Angela Chao’s husband. Examples of logistical abutment included OST admiral requesting, through the U.S. Department of State, to acquire the Chinese Admiral of Busline (MOT) board two cartage for the Dr. Chao arrangement and (b) (6) In accession instance, a DOT official in the all-embracing activity arrangement emailed the Secretary allurement her whether Dr. Chao would be absorbed in affair with a aloft aerial akin Chinese official, who was Dr. Chao’s aloft acquaintance and lived in Shanghai. An email barter on October 4, 2017, amid OST agents reflect a antecedence to abutment the needs of Dr. Chao. The email barter from one OST staffer to accession declared “Above all, let’s accumulate [the Secretary] happy. If Dr. Chao is happy, afresh we should be aerial with a calamus in our hat.” A baby cardinal of OST advisers accommodating logistical abutment for the Dr. Chao delegation. For example, on October 23, 2017, in acknowledgment to U.S. Embassy admiral requesting the biographical and authorization admonition for the Dr. Chao delegation, an agent in the DOT Arrangement of All-embracing Busline and Barter responded that the agent would “defer to [an OST 5 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 6 of 38) 120E002R200 staffer] and/or Todd [Inman, aloft DOT Director of Operations,] for Dr. Chao and non-DOT delegation’s authorization bio pages.” 22 Emails advertise that on or about August 25, 2017, DOT Arrangement of Accustomed Counsel (OGC) career belief attorneys met with aloft DOT Arch of Agents Geoffrey Burr, Deputy Secretary Jeffrey Rosen, Undersecretary for Busline Activity Derek Kan, and an OST scheduler about the proposed cruise to China and the proposed itinerary. Belief attorneys bidding affair about contest planned in Jiangsu, at assertive kindergartens, at Shanghai Amphibian University (SMU), and at Shanghai Jiao Tong University (SJTU) due to an credible affiliation with Foremost Accumulation and/or a Chao ancestors foundation. It is cryptic from the addendum taken by the OGC belief attorneys on September 11, 2017, that the attorneys were acquainted of Dr. Chao’s appearance or the appearance of those in Dr. Chao’s delegation. In addendum of the meeting, the belief attorneys bidding apropos about the proposed itinerary. Specifically, the addendum stated: [T]he Belief Aggregation bidding apropos that the contest in Jiangsu and Shanghai at the kindergartens and at Shanghai Amphibian University and Jiao Tong University, should be claimed contest for the Secretary because of their affiliation to her family’s business. The Secretary, as a Government official, may not use her attainable arrangement for her own clandestine gain, or the accretion of others. The Belief Aggregation bidding apropos that if the Secretary were to appoint in “public diplomacy” contest at locations carefully affiliated with the Foremost Group, it would board an inappropriate advantage, in the anatomy of publicity, to Secretary Chao’s family’s business. However, the Secretary could still arrangement the sites that her family’s foundation has contributed to in her claimed capacity. But, the Belief Aggregation fatigued that the Secretary should assignment anon with the Foundation to set up such claimed contest and not absorb DOT agents in the alertness of such contest or on the day (outside of one actuality to board a articulation in case of DOT emergency and all-important security). Afterward the affair with OGC belief attorneys, OST agents affiliated to adapt for and alike the contest listed on the abstract beat as scheduled. For example, on September 11, 2017, an OST staffer emailed a Foremost Accumulation agent several abstract cruise itineraries, commemoration absolute the claimed contest in Jiangsu and Shanghai that belief attorneys had bidding affair about. On September 22, 2017, an OST staffer emailed the Secretary allurement her to affirm the abundance of ability from the White House to be beatific via FedEx. The Secretary afresh forwarded the email to her ancestor and he responded, (b) (6) In addition, DOT attainable abode admiral accommodating with the U.S. Embassy columnist arrangement and Chinese media outlets to align media advantage emphasizing the Secretary’s claimed and ancestors story. On October 13, 2017, the Secretary emailed an OST staffer a annual of agitation items. These included: “redo beat -to reflect SJTU” “Need to acquaint who will be at top leaders meeting: Dr. Chao Angela Chao [Angela Chao’s husband] “Coming alternating but not in room: [Foremost Employee]” “DOT: none” “US Embassy – Ambassador, I’m sure. Maybe Ascendancy Officer” “MOT: they will booty affliction of.” 6 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 7 of 38) 120E002R200 “Things to ask [Official at Chinese Admiral of Transportation]:” “(b) (6) ”; “Lai’an kindergarten feast – allure [Chinese official] and affair secretary and added admiral as appropriate”. “invite [Chinese official] and affair secretary and added admiral as appropriate”; “Dr. Chao’s accident Wed am – [Senior Chinese government officials] arrive to attend.” “SJTU and SMU – accomplishment they get as big admirers as they can …but minimum accomplishment it will be 400-500.” In the 2 weeks afore the trip, (b) (5) For example, in an barter amid Inman and an OST staffer on October 16, 2017, Inman wrote that (b) (5) The OST staffer responded via email to Inman (b) (5) On October 18, 2017, an OST staffer emailed a Chinese admiral official adhering bios for commemoration affiliate of Dr. Chao’s delegation. The staffer wrote, “Thank you for the befalling to assignment with you on Secretary Chao’s attainable arrangement to China… As offered, amuse acquisition absorbed a annual of bodies who will be accompanying Secretary Chao’s father, Dr. James S. C. Chao; their bios in English and Chinese, for your attainable reference.” On October 18, 2017, the aforementioned OST staffer emailed a Chinese admiral official, advertence that, “As for the Accompaniment Leaders meetings, our ancillary will include: Secretary Elaine L. Chao, U.S. Secretary of Transportation[:] Agent Terry Branstad, US Ambassador[:] Dr. James S.C. Chao, Architect and Chairman, Foremost Group[:] Ms. Angela Chao, Deputy Chair, Foremost Group[:] [Angela Chao’s husband][:] Mr. Derek Kan, Undersecretary for Busline Activity nominee[:] US Embassy staff.” The OST staffer emailed the admiral official again, thanking the official for (b) (6) allurement about Dr. Chao’s alternative for two atramentous sedans, and attractive into the “desired basement align in the aerial akin meetings.” Additionally on October 18, 2017, U.S. Embassy admiral emailed DOT admiral stating: We’re acquainted that Secretary Chao is bringing Dr. Chao, Angela Chao, and [Angela’s husband] to China. We acquire from MOT that Dr. Chao, Angela, and [Angela’s husband) are planning to accompany Secretary Chao to her official meetings. Is this correct? We appetite to ensure that this wasn’t a miscommunication. If this is the case, can you amuse board us with a complete annual of the abode that they would attend? We would charge to vet this with the Accompaniment Department. Centralized Department of Accompaniment emails on October 19, 2017, acknowledge (b) (5) OIG begin these Department of Accompaniment emails on DOT servers in affiliation with the Government’s aegis of a Freedom of Admonition Act accusation for admonition about the China trip: 7 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 8 of 38) 120E002R200 (b) (5) On October 20, 2017, Inman able out to the DOT Designated Bureau Belief Official (DAEO), career Deputy Accustomed Counsel Judy Kaleta, allurement to meet. The DAEO is the bureau agent with primary albatross for administering the circadian activities of the agency’s belief abode and analogous with the Arrangement of Government Ethics. Kaleta told OIG that, at that meeting, she abstruse the Secretary planned to arise an accident during the cruise breadth her ancestor would be signing copies of Fearless Adjoin the Wind. Additionally, Kaleta told OIG that(b) (5) On October 24, 2017, OGC delivered an belief announcement (titled “Ethical Ambit for the Secretary’s Cruise to China”) to James Owens, afresh a non-career Deputy Accustomed Counsel, with admonition for Kan. In the memo, OGC brash how the cruise could activity aural belief ambit and delineated official contest and claimed contest with specific belief advice. In particular, the October 2017 belief announcement common that the Secretary may not use her attainable arrangement for clandestine accretion or the accretion of others: “Such accretion does not acquire to be carefully bread-and-butter in attributes and can board alike such abstract allowances as publicity or added attainable awareness.” The announcement bidding affair that if “the Secretary were to appoint in contest at locations carefully affiliated with the Foremost Group, it would board an inappropriate advantage, in the anatomy of publicity, to Secretary Chao’s family’s business interests.” The announcement bidding accurate affair about the planned accident involving Dr. Chao signing and announcement a adventures about him: “The Secretary should abstain accessory such an accident as her presence, alike in her claimed capacity, could board publicity to the accident that would potentially admission sales of the book.” The announcement provided that at added contest with affiliation to her ancestor and the family, the Secretary “can accord official remarks, but any acknowledgment of her ancestor should be limited. The Secretary’s ancestor may attend, but should not sit on date with her.” The announcement additionally bidding affair about the Secretary’s ancestor and sister accessory official contest and mutual abode with Chinese officials. The Secretary would be acceptable to accompany a “plus one” to amusing contest breadth added guests or spouses would be in attendance. However, the announcement 8 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 9 of 38) 120E002R200 declared that it would be inappropriate for the Secretary to use her official position to board her ancestors associates admission not afforded to a clandestine citizen. Finally, the October 2017 belief announcement provided that the Secretary would acquire to arise several contest in her personal, rather than official, capacity. These contest included visits to institutions with access to the Chao family’s accommodating foundation, the Foremost Foundation, and her ancestor Dr. Chao. It was afterwards bent that “all of the kindergartens on the Secretary’s agenda two in the ambit and one in Shanghai – acquire all accustomed allotment from the Chao family.” The announcement provided that, at these claimed events, the Secretary could accompany one DOT agents actuality to accompany her and biking to and from these contest at the Secretary’s expense. At or abreast the time of the October 2017 belief memo, the cruise was cancelled. (b) (5) In an commemoration with OIG in December 2020, Kaleta declared that she stood abaft the accommodation of the October 2017 belief memo. In the interview, Kaleta declared issues about the annulled China cruise as a “disconnect” amid the admonition provided to OGC belief attorneys and admonition OGC would afterwards apprentice in the cruise planning process. For example, OGC afterwards credible that OST agents had able animadversion for and planned to accompany the Secretary to clandestine claimed contest on the cruise at DOT expense. Kaleta declared that DOT agents should not adapt or abstract animadversion for contest the Secretary attends in her claimed capacity. In addition, on official travel, the Secretary charge booty the best absolute routes, not divert, and not actualize official contest to appoint in claimed activity. Kaleta additionally declared she afterwards abstruse that an OST official told the Department of Accompaniment that the Secretary’s contest had been austere by DOT belief attorneys, which Kaleta told OIG was not the case. Aback OIG asked Kaleta whether the Secretary would be able to arise a book signing accident announcement her father’s biography, such as the one on the beat of the annulled China trip, Kaleta declared that it depended. She would appetite to apperceive who would be at the accident and would not appetite to say that the Secretary could not arise such an accident as a accustomed matter. Kaleta acclaimed the Secretary’s appearance would present difficult questions because there is a acute acuteness about her attainable status. She added the Secretary has a greater appulse than a accustomed DOT agent aback she attends an event. In a December 2020 interview, OIG additionally asked DOT Accustomed Counsel Steven Bradbury, who was accustomed anon afterwards the China cruise was cancelled, about the trip. Bradbury declared the proposals and itineraries for the annulled China cruise were consistently changing, and it is fair to say those itineraries were not absolutely vetted by OGC belief attorneys. C. Accouterment DOT Media and Attainable Abode Abutment for the Secretary’s Ancestors (2017– 2018) OIG’s assay brash two areas of affair accompanying to abutment for the Secretary’s family: (1) DOT media abutment and (2) attainable abode and added abutment at assertive events, as follows. 9 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 10 of 38) 120E002R200 C-1. DOT Media Activity Abutment A assay of DOT emails and interviews with agents arise that OST staffers provided assorted media and attainable abode abutment to the Secretary’s ancestor in 2017 and 2018. In accession to the planned book signing in China, there were several added instances breadth OST agents were directed to admonition beforehand Dr. Chao’s biography, Fearless Adjoin the Wind. For example, in August 2017, the Secretary directed two OST staffers to accelerate a archetype of Fearless Adjoin the Wind to a acclaimed CEO of a aloft U.S. association (which is not adapted by DOT) alternating with a letter requesting that he abode a exordium for the book and a sample foreword. Emails arise that the Secretary had asked a third staffer to adapt the sample foreword. OIG’s assay adumbrated that the Secretary circuitous OST agents in agnate requests for forewords to Fearless Adjoin the Wind to several added arresting individuals, such as leaders at three aristocratic U.S. educational institutions. OIG begin affirmation that OST staffers actively maintained a annual of all of Dr. Chao’s awards. For example, on September 30, 2017, the Secretary emailed an OST staffer, “Where is listings of awards for Dr C[] that you adapted with latest Boston award? Email to me asap.” The staffer responded with an adapter absolute a annual of awards for the Secretary’s ancestor and additionally declared that, “a adamantine archetype should acquire accustomed in NY.” Similarly, on November 9, 2017, the Secretary emailed an OST staffer a annual of an inscribed bays and directed the staffer to “include on dr c annual of awards.” OIG additionally begin affirmation that the aloft DOT Director of Attainable Affairs, Marianne McInerney, and OST staffers additionally drafted, edited, and implemented a media activity and attainable relations plan. The advisers who formed on this certificate were no best active by DOT during the assay and would not accord to a autonomous interview. OIG attempted to commemoration McInerney on December 12, 2019. McInerney asked OIG to accelerate her a academic commemoration request, which OIG afterwards beatific to her via email. McInerney did not acknowledge to that appeal or to OIG’s assorted added requests for an interview. On January 29, 2020, OIG additionally attempted to commemoration an OST staffer who formed on this document. The OST staffer did not accord to a autonomous commemoration with OIG. However, emails appearance their captivation in this document. On March 26, 2018, McInerney emailed an OST staffer requesting “all the attainable awards and date[s].” The staffer responded with “Columbia 4/17 SUNY Amphibian 5/1 Lloyd’s Annual Houston 5/23.” The abutting week, on April 4, 2018, McInerney emailed the staffer requesting admonition in proofing a certificate titled, “Dr. Chao bounce 2018 Events.” The document, which was absorbed to the Director of Attainable Affairs’ email, “proposes proactively leveraging Dr. Chao’s attainable awards and equities to amend contempo coverage.” The certificate additionally highlights several awards Dr. Chao was to acquire in the advancing weeks: an countdown EPIC accolade from Columbia University; an accolade from Accompaniment University of New York (SUNY) Amphibian College; a Lifetime Accomplishment Accolade from Lloyd’s List; and an honorary amount from Massachusetts Amphibian Academy (MMA). The certificate added highlights Dr. Chao’s contour in a affiliate in Dynasties of the Seas, II (Dynasties), a book about all-embracing aircraft firms, and Journeys – An American Adventure (Journeys), an article accumulating that includes an article by the Secretary about her family’s clearing story. 10 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 11 of 38) 120E002R200 In a area alleged “Strategy,” the “Dr. Chao bounce 2018 Events” certificate states, “We acclaim amplifying the advantage in bounded columnist a bureau to body Dr. Chao’s contour and to allotment the adventure of his journey.” The activity additionally describes recommendations apropos to Dynasties: “We acclaim alive with the administrator to beforehand the book to boilerplate columnist in May above-mentioned to the June book launch. From our perspective, we would ask the administrator for permission to advantage the affiliate as allotment of beat on Dr. Chao.” The aforementioned certificate additionally sets alternating a timeline for Dr. Chao’s media strategy. According to the document, the tasks to be able include: “update agenda Dr. Chao media kit. (Bio, Abbreviated Excerpts of Dr. Chao story. Altruistic work. Photo profiles, etc.)”; “Work with Columbia to angle accolade and event”; “Work with SUNY Amphibian to angle accolade and event”; “Pitch and abode Dynasties”; and “Work with Lloyds to beforehand Lifetime Accomplishment award.” OIG’s assay arise affirmation that OST staffers arise to acquire implemented Dr. Chao’s media strategy. As declared in added detail in the area below, OST agents were circuitous in acclimation the 2018 contest at Columbia University, SUNY Amphibian College, Lloyd’s List, and MMA. Emails acknowledge that the Secretary directed the Director of Attainable Abode to “work on Dynasties of the Seas.” Throughout 2017 and 2018, added than three OST staffers were circuitous in alteration Dynasties, calm with Foremost Accumulation staff. Drafts of Dynasties edited by OST staffers focused primarily on the accomplishments of Dr. Chao, Angela Chao, and Foremost Group; the alive appellation of the Dynasties affiliate edited by OST staffers was, “Dr. James Chao & Angela Chao, Turning the Impossible into the Possible.” One OST staffer interviewed by OIG accustomed alteration the Dynasties affiliate and explained that this book was not awash or authored by the Chao family. Although the staffer accustomed the advertisement did not acquire any DOT-specific nexus, the staffer was asked to assay the affiliate and said the affiliate independent agnate argument and accent about the Secretary’s immigrant adventure that appears in official speeches. This staffer declared that the point actuality on this activity was McInerney. Dynasties was arise on June 8, 2018, by Marine Money, Inc. Emails additionally advertise that OST agents were circuitous in drafting and alteration Journeys. OST staffers submitted the article to the columnist of the accumulating in August 2017. Although Journeys was included on the media activity certificate about the Secretary’s father, our assay arise that the article did not alone focus on the Secretary’s father. In June 2018, DOT annal advertise that the columnist of Journeys was arrive to DOT to accommodated with the Secretary. Annal advertise that McInerney and the columnist were present at the meeting. Journeys was arise on July 3, 2018, by Rosetta Books. OIG additionally begin that, on January 6, 2018, the Secretary asked an OST staffer to adapt her father’s Wikipedia page. In an commemoration with OIG in January 2020, the staffer accustomed that she edited the folio and told OIG that they were the Secretary’s Wikipedia point person. Aback asked about autograph speeches or alteration agreeable about the Secretary’s father, the OST staffer declared that the Secretary’s ancestors adventure is generally a allotment of her attainable speeches. The staffer did not feel that alteration or speechwriting assignment that mentions Dr. Chao is alfresco the ambit of DOT duties because abundant of the adventure about the activity of the Secretary involves her father. According to the staffer, the ancestors adventure is a anecdotal apparatus activated as allotment of speechwriting. The OST staffer declared that there is a lot 11 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 12 of 38) 120E002R200 of overlap amid the Secretary’s official business with DOT and her claimed activity adventure because the Secretary ahead formed for MARAD, she came to America on a ship, and her ancestor owns ships. The OST staffer did not feel conflicted autograph about the Secretary’s ancestors story. A altered staffer believed it was the albatross of accession OST agents affiliate to administer the Asian abode contest for the Secretary, which includes alteration speeches and animadversion for the Secretary’s father. In OIG’s December 2020 commemoration with DOT Accustomed Counsel Steven Bradbury, he declared that he never batten to the Secretary about her abutment or credible beforehand of books and added publications about her ancestor or the Chao family, but was acquainted of the topic. Bradbury said the Secretary should not use her agents to adapt these book contest or to adapt the book material. He was not acquainted of the Secretary’s agents soliciting forewords for Dr. Chao’s biography. Bradbury said giving these books at contest breadth the Secretary appeared in her official accommodation would not be inappropriate, depending on the audience, because cogent the Secretary’s activity adventure could be apparent as a annual for DOT. Bradbury said it would not be adapted for the Secretary to absolute subordinates to assignment on these publications, but added he did not ahead of the OST staffers that formed on these publications as subordinates due to their connected able relationships with the Secretary. Bradbury said these were ethical questions and it would be best to abstain and abbreviate these tasks, if possible, and to ensure the OST staffers were compensated if they formed on these tasks alfresco of accustomed alive hours. In December 2020, DOT DAEO Judy Kaleta told OIG she has never been asked by OST to board belief admonition apropos to Dynasties or Journeys. Aback OIG asked whether the assembly and alteration of this media activity certificate was allotment of the official duties of OST staff, Kaleta declared that she had not been acquainted of this document. C-2. Attainable Abode and Added Abutment at Specific Contest OIG’s assay articular and brash 14 contest that the Secretary abounding or planned to arise with her ancestor that took abode from March 2017 to the summer of 2018. These board appearance at contest in both her claimed and official capacities and contest for which DOT agents provided attainable abode or added support. OIG did not actuate whether the Secretary abounding these contest in her official or claimed capacity. OIG contacted OGC for its assurance on whether these contest were official or claimed in attributes for the Secretary, and OGC’s responses are included in the summaries below. i. DOT 50th Commemoration (March 29, 2017) DOT captivated an accident adulatory its 50th commemoration on March 29, 2017. Over 500 people, including aloft Department Secretaries, accustomed associates of Congress, and added guests aggregate in the atrium of DOT’s abode for an “open house” to admire the commemoration of the Department’s creation, bless its achievements, and acknowledge the Department’s charge to acclamation the busline challenges of the present and future. The Secretary provided animadversion to the attendees. 12 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 13 of 38) 120E002R200 The Secretary’s father, Dr. Chao, additionally abounding this event. According to annal able by OST staff, about 100 guests with access to Dr. Chao and Foremost Group. Emails amid OST staffers referred to these individuals as “Dr. Chao’s” guests. Additionally, associates of the Chinese media were additionally in attendance. OST agents additionally able abundant itineraries and facilitated the booking of a clandestine Amtrak car for Dr. Chao and his guests to biking from New York to Washington, DC, and back. Emails advertise that OST staffers able out to Amtrak’s sales and allotment office, requested appraisement options, appear those appraisement options to Foremost Accumulation employees, and aloof a clandestine Amtrak car appliance a Foremost Accumulation employee’s acclaim card. OIG additionally begin emails advertence that OST agents met with Amtrak agents to conduct a walk-through of the Amtrak car aloof for Foremost Group. OIG begin emails assuming that, in the canicule above-mentioned to the commemoration event, OST agents able out to Chinese columnist to activity interviews of the Secretary and Dr. Chao. Additionally, the emails advertise the Secretary acclimated DOT arrangement spaces to blur several interviews with Chinese columnist with her ancestor present and accommodating in the interviews. ii. Chinese Consolidated Benevolent Association, Chinatown Contest (May 27, 2017) On May 27, 2017, Secretary Chao visited the Chinese Consolidated Benevolent Association (CCBA) in New York City. As allotment of this visit, Secretary Chao took allotment in a alternation of contest adulatory Chinese-Americans. The Secretary delivered animadversion at the New York Chinese Association Center, breadth she paid annual to her father, and alien him so he could bear animadversion to the audience. The Secretary and her ancestor additionally alternating in a array hosted by the CCBA. According to the accident area able by OST staff, the accident accomplishments for the array stated, “This array is actuality captivated to annual the assignment and success of DR. CHAO and THE SECRETARY. Additionally, it is to bless the contributions they acquire fabricated to the ChineseAmerican community.” The accident area additionally listed a cardinal of Chinese columnist organizations that were accustomed to awning the parade. According to the accident bedding aggregate by OST agents analogue her contest for that day, the Secretary and her ancestor additionally laid a band in annual of Chinese-American veterans and opened an display at Confucius Plaza. Further, according to accession accident area aggregate by OST staff, the Secretary was additionally appointed to arise a CCBA feast feast that black with her father, which included assuming for photos. This accident additionally had assorted Chinese columnist organizations in attendance. Foremost Accumulation sponsored a table at the banquet. The Secretary was referred to by her official appellation in the accident she and was listed as U.S. Secretary of Busline Elaine Chao on the CCBA’s website, breadth it accent her visit. OST agents able the Secretary’s animadversion for commemoration accident and conducted beat to Chinese columnist organizations for interviews to be conducted of the Secretary and her father. The Secretary and associates of her staff, including advisers from the Arrangement of Attainable Affairs, catholic to this accident appliance DOT biking funds. 13 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 14 of 38) 120E002R200 Aback asked by OIG if a assurance was fabricated on whether this accident was accounted to be an official or claimed accident for Secretary Chao, OGC declared that they had no almanac of a appeal to board belief admonition for this event. According to Department records, at atomic eight DOT agents accompanied the Secretary to this event. iii. Seamen’s Church Institute Silver Bell Accolade Feast (June 8, 2017) The Seamen’s Church Institute (SCI) Silver Bell Accolade Feast is an commemoration fundraiser accident anniversary amphibian leaders of the year. On June 8, 2017, the 40th commemoration bright was captivated in New York City. Dr. Chao was accustomed with the Silver Bell Accolade for his contributions to the amphibian industry. Secretary Chao presented a able set of animadversion in which she accustomed the SCI honorees and discussed the accomplishments of her father. These included the alpha of his own aircraft company, now accustomed as Foremost Group, and his accommodating allowance to SUNY Amphibian as “one archetype of the abounding means he is abrogation a bequest for the mariners who arise afterwards him.” Additionally, Secretary Chao alien her sister Angela Chao, afresh Deputy Chair of Foremost Group, who accompanied Dr. Chao on date for the accepting of the Silver Bell lifetime accomplishment award. Per Angela Chao’s abstract remarks, she provided her ancestor the befalling to speak. Angela Chao afresh affiliated her animadversion in which she discussed Foremost Accumulation and ancestors foundation-related amphibian educational programs. In communications about the event, OST agents brash organizers there would be a absolute of six agents traveling with the Secretary, including (b) (7)(E) The Secretary was built-in at the Foremost Accumulation table alternating with Dr. Chao and SUNY Amphibian President Rear Admiral Michael Alfultis, amid others. Further, OST agents able a Media Advising for the 40th Commemoration Silver Bell Awards Dinner. The advising declared Secretary Chao would “introduce her father, Dr. James S.C. Chao, who is this year’s almsman of the celebrated award.” The advising did not acknowledgment the added honorees. In added correspondence, the Secretary requested OST agents “alert Chinese columnist about this event.” Aback asked by OIG if a assurance was fabricated on whether this accident was accounted to be an official or claimed accident for Secretary Chao, OGC declared that they had no almanac of a appeal to board belief admonition for this event. According to Department records, at atomic two DOT agents accompanied the Secretary to this event. iv. United States Merchant Amphibian Academy Admission (June 17, 2017) On June 17, 2017, the U.S. Merchant Marine Academy (USMMA) captivated its admission commemoration in Kings Point, New York. The Secretary was the keynote apostle and presented the graduation address. Dr. Chao abounding as the Secretary’s guest. 14 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 15 of 38) 120E002R200 OST agents instructed added OST agents to acquaint the Chinese columnist of the accident and to “get a photo on date with Dr Chao with uniformed people.” The DOT columnist absolution labeled the accident as “U.S. Secretary of Busline Elaine L. Chao Addresses Midshipmen at USMMA Commencement; Secretary Chao Additionally Accustomed her Father, Dr. James S.C. Chao, in Celebration of Father’s Day.” In commendations to the columnist release, the Secretary instructed OST agents to “Enclose the accent Administer alone to Chinese media outlets I specified. Alarm them NOW and acquaint them we are sending a adventure over. They will book what columnist absolution and accent says.” Aback asked by OIG if a assurance was fabricated on whether this accident was accounted to be an official or claimed accident for Secretary Chao, OGC declared that they had no almanac of a appeal to board belief admonition for this event. According to Department records, at atomic four DOT agents accompanied the Secretary to this event. V. All-embracing Administering Foundation Bright (July 21, 2017) The All-embracing Administering Foundation (ILF) is a nonprofit alignment “that promotes the borough awareness, attainable service, and bread-and-butter capability of the Asian American Pacific Islander community.” ILF holds an commemoration awards bright to admit individuals and organizations for achievements in and improvements to the Asian American Pacific Islander community. לל On April 11, 2017, Secretary Chao was arrive to accord a keynote abode at the 2017 ILF Awards Gala. Her ancestor was additionally arrive to allege at the Awards Gala. In a letter anachronous April 11, 2017, to Dr. Chao, an ILF (official] stated, in part, “this accident is not alone to highlight Chao ancestors bequest but additionally to allotment your activity acquaintance to affect the able APA community.” The allurement adumbrated Dr. Chao had aggregate his biography, Fearless Adjoin the Wind, with the ILF New York Chapter’s Roundtable Discussion at the Harvard Club the antecedent year and “this time, we would like to allotment your adventures with the able nation.” On May 31, 2017, the Secretary emailed an ILF organizer, “Enable me to try to align Dr Chao to arise this event. I will arise and accessory advanced to seeing you all.” That aforementioned evening, the Secretary emailed the organizer again, “Can you conceivably ahead of a role for Dr. Chao and me? Do you ahead distributing 500 copies of his book? I alternate to accompany him to DC – although he’s actual agog to abutment you – if not a role for him? Abounding abounding thanks!” On June 6, 2017, the ILF organizer emailed the Secretary a certificate titled, “Draft – 2017 ILF Bright Timeline (as of June 5).” This certificate declared that, “We plan to acquire a accomplishments of Fearless adjoin the Wind at the clandestine ption” and “We plan to administer 500 books at the accident and admit adapted sections about Celebration of Secretary Chao as Busline Secretary in the bright book.” On July 9, 2017, ILF beatific OST agents the ILF Bright timeline as of that date. The timeline adumbrated the Secretary and Dr. Chao were appointed to accommodated with Chinese columnist about Fearless Adjoin the Wind. It additionally adumbrated ILF had broadcast books to the reporters in advance. In addition, the timeline indicated, “Dr. Chao’s book will be placed on commemoration bench of 500 attendees with the ILF Bright book and allowance bag.” During the accession of the Secretary, the Secretary’s headshot and title, “The Atonement Elaine L. Chao, the 18th U.S. Secretary of Transportation,” would be on 15 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 16 of 38) 120E002R200 screens to the larboard and adapted of the stage. The timeline added adumbrated that aback Dr. Chao speaks, his title, “Philanthropist and Architect and Chairman of Foremost Group,” with a headshot would arise on the adapted and larboard screens. The Secretary’s animadversion were labeled as “Keynote accent by Secretary Elaine Chao & Adapted animadversion by Dr. James S.C. Chao about his book, Fearless Adjoin the Wind.” OST agents able the Secretary’s remarks, which focused on Dr. Chao’s adventure and career. On July 17, 2017, OST agents accommodating with Foremost Accumulation agents to accelerate arrangement books to Dr. Chao for the ILF event, “as we acquire done for antecedent events.” In beforehand of events, OST agents would actualize arrangement books for the Secretary, including admonition such as biographical admonition about bodies built-in at her table. According to the agenda of contest for Dr. Chao, which was drafted by the Secretary’s agents and beatific to Foremost Accumulation staff, Dr. Chao had several media interviews at DOT in the afternoon of July 20, 2017. OIG’s assay of emails arise that OST attainable abode agents able out to Chinese media outlets admonition the outlets that the Secretary would “provide the keynote abode at the ILF feast on July 20th. In beforehand of the evening, we are agreeable a few media outlets to accompany us for a baby commemoration at the Department of Transportation.” The accountable band of one email was “An Commemoration with Dr. Chao and Secretary Chao.” OIG lath begin affirmation that those interviews did activity at DOT. On July 21, 2017, afterwards the ILF event, the Secretary beatific McInerney an email with the accountable line, “Can you animate columnist to awning ILF.” In a abstracted email on the aforementioned day, the Secretary directed McInerney to acquire an OST staffer “Print out online versions of media from yesterday” and directed afresh DOT Director of Operations Todd Inman to “send accession Go to Chinatown and buy newspapers: Apple Journal Sing Tao China Press.” OIG begin affirmation that McInerney beatific an email to assorted media outlets with “Dr. James S.C. Chao” in the accountable line. The email adumbrated OST agents were “gathering belief and advantage of the ILF accident for Dr. Chao.” It added declared “you can acquaintance us at any time for media interviews or comments.” In addition, an OST staffer responded to the Secretary, adhering two commemoration accessories that referenced the ILF accident and declared that they would additionally board those accessories “in your FedEx.” Aback asked by OIG if a assurance was fabricated on whether this accident was accounted to be an official or claimed accident for Secretary Chao, OGC declared that they had no almanac of a appeal to board belief admonition for this event. There are no DOT biking annal for this accident because it was captivated in Washington, DC. vi. Chinese American Academic and Able Society Commemoration Assemblage (August 19, 2017) On August 19, 2017, the Chinese American Academic & Able Society (CAAPS) captivated its 42nd Commemoration Assemblage in Flushing, New York. The affair for this assemblage was “New Thinking and New Technology in the Alteration Era,” and about 350 guests attended. Secretary Chao was one of three arrive keynote speakers. OIG’s assay of emails arise that the Secretary was built-in with her ancestor at one of two atonement bedfellow tables for dinner, and Angela Chao was built-in at the added atonement bedfellow table. 16 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 17 of 38) 120E002R200 During the awards ceremony, the Secretary, Dr. Chao, and Angela Chao were alien calm and were built-in on the stage. Angela Chao was presented with the CAAPS Acclaimed Entrepreneurship Award, and she fabricated abrupt remarks. The Secretary was presented with the CAAPS Lifetime Accomplishment Accolade and delivered the keynote speech. Afterward the ceremony, the Secretary, Dr. Chao, and Angela Chao remained built-in on the date for photographs. Above-mentioned to the event, on June 22, 2017, CAAPS beatific a abstract of the awardees’ citations and adventures to Dr. Chao and his agents at Foremost Group. On the aforementioned day, Dr. Chao forwarded this email and adapter to the Secretary. On June 26, 2017, the Secretary forwarded an email alternation to an OST staffer and stated, “would abundantly acknowledge if you can adapt Angela’s bio [ ] as per admonition provided Monday…..and acknowledgment to me with edits apparent in tracks. thanks.” GG An email anachronous August 19, 2017, from CAAPS to an accident presenter states, ..The Secretary appetite to abbreviate the activity to save time for Dr. James Chao, She would like you to acquaint Angela and Her together. Afterwards the accolade presentation, Dr. Chao can booty photo with both of them rather than with one of them commemoration time, to abate the accountability on Dr. Chao.” A chase up email afterwards that day stated, “Let’s chase the aboriginal plan by introducing them separately; and afterwards The Secretary has accustomed the award, Dr Chao will booty photo with both of them.” On August 21, 2017, 2 canicule afterwards the event, Kaleta beatific DOT Abettor Accustomed Counsel for Accustomed Law Terence Carlson and accession OGC belief advocate an email and asked, “Did you acquire an accolade that the secretary accustomed on Saturday?” On the aforementioned day, Carlson responded, “We did not. We were not asked about it.” Aback asked by OIG if a assurance was fabricated on whether this accident was accounted to be an official or claimed accident for Secretary Chao, OGC declared that they had no almanac of a appeal to board belief admonition for this event. According to Department records, at atomic four DOT agents accompanied the Secretary to this event. vii. Massachusetts Amphibian Academy fundraiser event, Salute to Amphibian Actuality of the Year (September 21, 2017) On September 21, 2017, MMA captivated a fundraising event, MMA’s 2017 Salute to the Amphibian Actuality of the Year, at the Intrepid Sea Air Space Museum in New York City. In a September 5, 2017, letter from MMA, Secretary Chao was arrive to allege on the “future of the Merchant Marine” and to formally acquaint her father, who was accustomed that black with the countdown Admiral’s Acclaimed Commemoration Award. OIG’s assay of emails arise that Secretary Chao did not acquaint her father. Rear Admiral Francis X. McDonald alien Dr. Chao and presented him with the award. McDonald afterwards alien Secretary Chao. Above-mentioned to the event, in an email anachronous July 26, 2017, from Angela Chao to the Secretary and Dr. Chao, Angela told Dr. Chao, (b) (6) The abutting day, the Secretary responded to Angela asking, (b) (6) 17 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 18 of 38) 120E002R200 On the aforementioned day, Angela responded, (b) (6) On August 1, 2017, the Secretary forwarded this email to OST agents and stated, “please put on my calendar.” OST agents forwarded this email to Kaleta on August 29, 2017. On August 29, 2017, Kaleta forwarded this email to Carlson, and Carlson responded to Kaleta on the affair of advertisement ability from ancestors on cyberbanking acknowledgment reports. In his email to Kaleta, Carlson wrote (b) (5) In a September 6, 2017, email, OST agents forwarded the Secretary’s MMA allurement to the OST belief email address, Kaleta, Carlson, and added OST staff. The email stated, “Please see attached. Not abiding if/how this changes accord on [The Secretary’s] part.” On September 13, 2017, a abstract of the abode was emailed from MMA to OST staff, at OST’s request. The email requested the approval of the Secretary’s adventures and photograph in the program. In the abode the Secretary was pictured with her adventures and the branch “Introduction of Admiral’s Acclaimed Commemoration Award.” Pictured below, on the aforementioned page, was Dr. Chao and his adventures with the heading, “Introduction of Emery Rice Award.” The abutting folio of the abode is a abounding folio Foremost Accumulation sponsor advertisement. On September 15, 2017, MMA beatific Foremost Accumulation agents adapted animadversion for Dr. Chao’s accession at the event. On September 18, 2017, a Foremost Accumulation agent forwarded the email to the Secretary and an OST staffer. In an email alternation anachronous September 17, 2017, apropos the MMA event, the Secretary brash OST staff, “In accession to accepting the adapted agenda which I requested below, amuse ask your acquaintance at Mass Amphibian – do they charge any abetment in advancing accession for me and for Dr Chao….let us see their introductions. Let me and [OST staffer] see intros.” In an email anachronous September 19, 2017, OST agents stated, “Here is my edited adaptation of Dr. Chao’s accession for Mass Maritime.” Additionally on September 19, 2017, OST agents beatific an centralized email stating, “Please see absorbed for a abstract of Dr. Chao’s animadversion for the residence,” with an absorbed Word certificate advantaged “Dr. Chao remarks.” An email anachronous September 21, 2017, from OST agents to MMA stated, “Can you amuse accord the hardly revised accession of Dr. Chao to Admiral MacDonald, with our aboveboard affliction for these aftermost minute changes?” OST agents additionally edited Dr. Chao’s introduction, which was delivered by McDonald. Aback asked by OIG if OGC had any almanac of accouterment an belief assurance to OST for this event, Kaleta provided OIG with a abstract email, anachronous August 29, 2017, from Kaleta to an OST staffer and the OGC Belief Arrangement mailbox, discussing the ambit of the Secretary accessory in her claimed accommodation against her official capacity. (b) (5) 18 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 19 of 38) 120E002R200 (b) (5) Kaleta told OIG this was alone a abstract email and was never appear with OST. This accident was additionally discussed in a abstract November 2017 belief announcement that OIG obtained. In the memo, DOT OGC belief attorneys declared (b) (5) In OIG’s commemoration with Carlson in January 2021, he recalled (b) (5) > but declared OGC and OST try to acquire an “exchange of ideas” above-mentioned to OGC accouterment a accounting belief assurance for an event. According to Department records, at atomic four OST agents abounding the accident with the Secretary, as did Amphibian Administrator Rear Admiral Mark H. Buzby. A affiliate of the Secretary’s abutting ancestors additionally abounding as a bedfellow of the Foremost Group. The Foremost Accumulation purchased a table for the accident as a $25,000 donation. viii. Chinese Institute of Engineers Bazaar Assemblage (October 14, 2017) In April 2017, the Chinese Institute of Engineers (CIE) arrive Secretary Chao to be the keynote apostle at its bazaar assemblage in Palisades, New York, on October 14, 2017. The Secretary had been a bedfellow apostle at two above-mentioned CIE conventions. On August 13, 2017, the CIE able out to the Secretary afresh to allure her to be its keynote speaker. The Secretary’s scheduler able out to Dr. Chao’s Controlling Abettor on August 15, 2017, to see if he admired to attend, and contacted the CIE on August 21, 2017, to formally acquire its allurement for the Secretary. On August 28, 2017, the Secretary emailed her scheduler and asked if she had accustomed the allurement to the CIE, abacus “If you acquire NOT accepted, I acquire added bulletin for you to acquaint organization. Wait for my instructions.” Afterwards that aforementioned day, the Secretary’s scheduler contacted the CIE and requested they affirm that Dr. Chao was accepting an accolade at the feast and, if he was, that OST assay any abstracts broadcast apropos Dr. Chao. The CIE replied to the Secretary’s scheduler that the CIE had nominated Dr. Chao for its Bazaar Medal. The abstract animadversion for the Secretary’s keynote address, aftermost edited by her speechwriter on the morning of the banquet, referenced her father’s book, Fearless Adjoin the Wind. Copies of the book were placed on the attendees’ chairs. Dr. Chao accustomed the CIE’s Bazaar Medal that black “For his administering in adopting energy-efficient and eco-friendly abode architecture and 19 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 20 of 38) 120E002R200 technology,” which is a byword from his accident adventures that was edited and provided to the CIE by OST staff. McInerney beatific the Secretary a abstract columnist absolution of the event, labeled as “Draft Release” and anachronous October 14, 2017, highlighting the Secretary’s accent and her father’s abandoning of the Bazaar Medal. However, OIG begin no almanac of an official columnist absolution by DOT for the CIE event. On August 28, 2017, OST abreast DOT OGC belief attorneys via email that the Secretary was activity to be the keynote apostle and her ancestor was accepting an accolade at the CIE event. Kaleta provided OIG with a abstract email, accounting by Carlson and addressed to Kaleta on September 1, 2017: (b) (5) Kaleta could not acquisition almanac of this email actuality aggregate with OST. OIG, in its assay of OST emails, additionally begin no almanac of this announcement actuality aggregate with OST by OGC. This accident was additionally discussed in the abstract November 2017 belief announcement acquired by OIG. In the abstract memo, DOT belief attorneys declared (b) (5) In OIG’s January 2021 commemoration with Carlson, (b) (5) In OIG’s December 2020 commemoration with Bradbury, he commented that (b) (5) Bradbury declared he did not apperceive whether the CIE accident was an official or claimed accident for the Secretary. 20 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 21 of 38) 120E002R200 According to Department records, at atomic three DOT agents accompanied the Secretary to this event. ix. OCA Westchester 37th Commemoration and Dynamic Achiever Accolade Bright (November 11, 2017) On November 11, 2017, the Westchester & Hudson Valley Affiliate of the Alignment of Chinese Americans (OCA-WHV) hosted its Dynamic Achiever Accolade Bright and 37th Commemoration Celebration in Tarrytown, New York. Dr. Chao was one of three Dynamic Achiever Awardees, and the OCA-WHV arrive Secretary Chao to arise as a acclaimed bedfellow and speaker. In a May 9, 2017, email to a Foremost Accumulation employee, an OCA-WHV adumbrative asked Dr. Chao to acquire their Dynamic Achiever Award. About 4 hours later, an OST staffer adumbrated Secretary Chao’s admiration to arise the bright in an email that additionally asked the Foremost Accumulation agent for the date of the bright “so that we can coordinate.” Per the Foremost Accumulation employee’s request, Dr. Chao accustomed a academic allurement on May 12, 2017. Later, in an October 23, 2017, email to OCA-WHV, a Foremost Accumulation agent declared Dr. Chao’s alternative that Secretary Chao acquaint him during the gala. From November 2 to November 6, 2017, an OCA-WHV official and an OST staffer batten several times via blast and exchanged emails during which they revised the Secretary and Dr. Chao’s corresponding activities during the gala. Amid added things, they discussed a abstract adaptation of the gala’s abode book and the adjustment in which the Secretary and Dr. Chao would speak, affectation for photographs, acknowledgment to their seats, and acquire dinner. In a November 5, 2017, email to the OCAWHV official, an OST staffer adapted two edits to the abode book: (1) Admit “Keynote by the Atonement Elaine L. Chao” and (2) Change to Dr. James S.C. Chao. In a November 7, 2017, email, an OGC belief advocate provided admonition apropos the bright to Inman and Carlson pursuant to Inman’s request. In the email, the OIG belief advocate brash that, in befitting with antecedent advice, Secretary Chao could acquire an allurement to the gala, she could arise as the Secretary of Transportation, and the feast would not be brash a allowance to her or DOT if she batten at the gala. The OGC belief advocate added advised, however, that if Secretary Chao “attends in her official capacity, she should not acquaint her father, because of his affiliation to the Foremost Accumulation and their busline interests.” In the accident Secretary Chao admired to acquaint her father, according to the belief attorney’s email, “she should arise in her claimed capacity, not as Secretary Chao, but aloof as the Atonement Elaine L. Chao.” In a November 8, 2017, email to a Foremost Accumulation agent and OST staffer, an OCA-WHV official accustomed approval to use 90 accoutrements provided by a bounded coffer to allowance one archetype of Dr. Chao’s book, Fearless Adjoin the Wind, aloft request. Afterwards that day, the Foremost Accumulation agent emailed an approval and the OCA-WHV official promptly bidding acknowledgment in a acknowledgment email to the Foremost Accumulation agent and OST staffer. On November 9, 2017, an OST staffer emailed a Foremost Accumulation agent an beat for the gala. According to the beat and added emails, a civic OCA official would bear acceptable animadversion and afresh acquaint Secretary Chao, who would bear her keynote abode and afresh acknowledgment 21 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 22 of 38) 120E002R200 to her seat. At this point, the adept of ceremonies would acquaint the Secretary and Dr. Chao for the presentation of his award. Additionally above-mentioned to the gala, Secretary Chao’s agents able out to Chinese accent media to awning the event, accurately the New York City arrangement of a Hong Kong-based commemoration outlet. In a November 10, 2017, email, McInerney abreast the media aperture of the accident and declared that Secretary Chao would bear the keynote and Dr. Chao would acquire the award. McInerney additionally asked if the commemoration aperture would acquire a anchorman in appearance and if she could facilitate a photograph. OIG brash an about 11-minute video of Secretary Chao’s accent at the gala, which an OST staffer accustomed from an attendee. In accession to, amid added things, congratulating the accolade recipients, the Secretary batten for about 2 and a bisected annual about her father, 2 and a bisected annual about busline issues, and 3 and a bisected annual about the Asian American association and diversity. OIG additionally brash video of Dr. Chao’s animadversion at the gala. The about 8-minute video does not appearance whether the Secretary alien her father. According to Department records, at atomic four DOT agents accompanied the Secretary to this event. x. Chinese Television Interviews (February 9, 2018) According to a announcement able by McInerney (see below), Secretary Chao abounding a cafeteria in or afore January 2018 with assembly from a Chinese state-owned broadcasting network. The announcement declared that during the lunch, the assembly discussed a abeyant documentary about Dr. Chao’s “life journey.” Subsequently, on January 22, 2018, McInerney accustomed an email from a agent with the broadcasting network’s English-language commemoration channel. In the email, the agent adapted the commemoration of Dr. Chao activity at his home and arrangement in New York in February 2018, asked for suggestions apropos “the family’s story,” bidding an ambition to commemoration Angela Chao, and asked for dates that would board Dr. Chao’s schedule. On January 29, 2018, the agent beatific accession email to McInerney accouterment an commemoration plan accounting primarily in Chinese. In the email, the agent declared the commemoration of Dr. Chao would be primarily conducted in Chinese, afresh her appeal for abeyant February commemoration dates in New York City, and asked to board Secretary Chao and Angela Chao to reflect on their accord with their father. According to an OST staffer’s adaptation of the commemoration plan, it primarily circuitous questions for Dr. Chao concerning, amid added things, Fearless Adjoin the Wind, Dr. Chao actuality dubbed the “Chinese Abode King,” how Foremost Accumulation “ascended to its cachet in the world,” and Dr. Chao’s business endeavors. These were followed by questions apropos Chinese culture, how Dr. Chao spends his day, his abode for the future, the accent of apprenticeship and family, the Ruth Mulan Chu Chao Center, and the Ruth Mulan Chu Chao Scholarships. The plan additionally adapted allurement Secretary Chao and Angela Chao for examples of the abutment they accustomed from their parents, abnormally Dr. Chao. Additionally, the plan proposed footage of Dr. Chao’s life, Foremost Group, Dr. Chao interacting with his daughters, and the Ruth Mulan Chu Chao Center. 22 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 23 of 38) 120E002R200 Secretary Chao and McInerney afresh exchanged emails on January 30, 2018, apropos added attainable media contest with Chinese-language media, including the aforementioned Chinese broadcasting arrangement that was planning the interviews about the Secretary’s father. In the antecedent email, the Secretary adapted administering the interviews on February 9, 2018, at Dr. Chao’s office. Aback McInerney replied with a catechism about the commemoration with the Chinese broadcasting network, Secretary Chao wrote, “I apperceive annihilation of accommodation of [this] appeal [.] You charge abode me a announcement and acquaint me details, etc. You charge cc [OST staffer] so [they] can align questions/answers. This is a TEAM project!” In response, McInerney able the above-referenced announcement for Secretary Chao and emailed it to the Secretary afterwards on January 30, 2018. Amid added things, the one-page announcement referenced Secretary Chao’s lunch, provided a adventures of the Chinese broadcasting network’s interviewer, and abbreviated the commemoration format. To her memorandum, McInerney absorbed the commemoration plan as translated by the OST staffer and the producer’s January 22 and 29 emails. According to centralized DOT documents, the commemoration occurred on February 9, 2018, at Foremost Accumulation abode in New York City, with Secretary Chao appointed to arise the filming from 2:00 p.m. to 4:00 p.m. OIG additionally begin affirmation apropos the use of a DOT-owned lighting kit during the interview. Afterwards accepting admonition from Foremost Accumulation about the admeasurement and blueprint of the arrangement allowance in which the commemoration would booty place, McInerney and DOT Media Centermost agents exchanged emails about bringing a carriageable commemoration lighting kit ahead purchased by DOT Attainable Affairs. In the aftermost of those February 7, 2018, emails, McInerney wrote, “Could you accompany it up … I may acquire to takek [sic] it” and the Media Centermost replied that they would accompany the lighting kit to her. During interviews with OIG, DOT Media Centermost and Attainable Abode agents declared they could not acquisition the lighting kit during a consecutive chase at DOT headquarters. The interviewees did not apperceive the accustomed area of the lighting kit or what happened afterwards DOT Media Centermost agents gave it to McInerney. Aback asked by OIG if a assurance was fabricated on whether this accident was accounted to be an official or claimed accident for Secretary Chao, OGC declared that they had no almanac of a appeal to board belief admonition for this event. According to Department records, McInerney accompanied the Secretary to this event. xi. EPIC Accomplishment Accolade at Columbia University Teachers College (April 17, 2018) On April 17, 2018, Secretary Chao abounding a clandestine bologna and alternating in a attainable abode babble with her ancestor and her sister Angela at Columbia University Teachers College. At the clandestine luncheon, Dr. Chao accustomed an countdown Apprenticeship for Persistence and Innovation Centermost (EPIC) Accomplishment award. A abstract columnist advisory, drafted by Columbia University and edited by OST staff, declared the abode babble accident as “a attainable babble about [Dr. Chao’s] adventures in advantageous acute affliction to become an administrator and the architect of one of the world’s bigger aircraft companies.” A abstract attainable relations plan created by a university official declared the accident as a way to advertise and barrage the EPIC, while acquainted Dr. Chao and donors 23 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 24 of 38) 120E002R200 accidental the $4 actor to barrage the center. In an email to her scheduler, the Secretary declared that she would “spend Monday in NY and arise 4/17/18 Dr Chao event.” During the abode babble with her ancestor and sister, the Secretary alien her ancestor and presented a accelerate appearance about her father’s life. Foremost Accumulation was accurately referenced several times in advisories anecdotic the event. In several abstract documents, the Secretary was referred to by her appellation as Secretary. In added abstract documents, she was referred to as the “Honorable Elaine Chao.” abstract columnist Several OST staffers formed with organizers on this event. OST staffers edited abstract columnist advisories for the accident and edited Dr. Chao’s adventures for the event. Added OST staffers formed to animate the Columbia University President to arise Dr. Chao’s event. For example, one OST official asked whether there has “been any acquaintance to the Secretary’s arrangement from [the President’s] office? All the efforts and burden acquire been activated from aural Columbia to animate [the] President … to be at Dr. Chao’s accolade ceremony.” In an commemoration with OIG, an OST staffer recalled extensive out to the President auspicious him to arise the event. The staffer told OIG that it was not abnormal to beforehand contest the Secretary was attending. OST agents were additionally circuitous in administering media beat on the event. Afterwards the abode chat, McInerney followed up with accident organizers, acquainted that she had not apparent any “pick-up from the event” and asked whether there would be a accessory columnist or photo absolution that would focus on boilerplate or barter press. McInerney afterwards emailed accident organizers advertence that she “was attractive for a articulation to adjustment on the abode for the family. If you appear beyond one, would you apperception forwarding.” Aback asked by OIG if a assurance was fabricated on whether this accident was accounted to be an official or claimed accident for Secretary Chao, OGC declared that they had no almanac of a appeal to board belief admonition for this event. According to Department records, at atomic four DOT agents accompanied the Secretary to this event. xii. Lloyd’s Annual Accolade (May 23, 2018) Lloyd’s Annual is an alignment that provides online news, analysis, and insights about the aircraft industry. Our assay of DOT emails arise that Secretary Chao planned to attend, but ultimately absitively not to attend, a May 2018 accident hosted by Lloyd’s Annual in Houston, Texas. At this event, the Secretary’s ancestor would acquire a lifetime accomplishment award. Abstract itineraries of this cruise advertise that the Secretary planned to arise the event, accord animadversion at the event, and present the accolade to her father. OIG begin affirmation that, on March 26, 2018, above-mentioned to her cancellation, OST agents arrive individuals the Secretary knew in Houston to the accident anniversary the Secretary’s father. OIG additionally begin affirmation that OST agents were circuitous in analogous this accident with Lloyd’s Annual organizers and Foremost Accumulation staff. On May 9, 2018, Kaleta emailed Inman advising Inman that the Secretary could alone participate to present the accolade to her ancestor in her claimed capacity. Kaleta brash that in her claimed capacity, the Secretary could not be alien with her title, and her animadversion should be constant 24 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 25 of 38) 120E002R200 with the following: “I am actuality tonight as a actual appreciative babe and in my claimed accommodation to present the Lloyd’s Annual Lifetime Accomplishment Accolade to my father.” Inman abreast the Secretary of Kaleta’s advice. The Secretary ultimately absitively not to arise the event. On May 18, 2018, afterwards the Secretary’s decision, one Foremost Accumulation agent emailed Lloyd’s Annual organizers advertence that they would “be demography over the align of the Lloyd’s annual event.” Afterwards this, several OST staffers’ claimed emails affiliated to be affected on emails with accident organizers. In one email, the Secretary’s sister Angela directed a Foremost Accumulation agent to ability out to McInerney and an OST staffer about the accident and to ask the OST staffer to accord the individuals that had been arrive by OST“a accustomed run of events.” xiii. SUNY Amphibian Admiral’s Scholarship Feast (May 1, 2018) OIG begin affirmation that the Secretary planned to attend, but ultimately did not attend, a fundraiser accident at the SUNY Amphibian College at which her ancestor would be accepting an award. On August 16, 2017, Rear Admiral Alfultis of the SUNY Amphibian College arrive Dr. Chao, Angela Chao, “and Foremost Accumulation to be accustomed at the SUNY Amphibian College Admiral’s Scholarship Dinner.” Alfultis acclaimed in his allurement that that this accident “has become the College’s capital agent for adopting scholarship support.” That aforementioned day, Angela Chao forwarded the allurement to the Secretary and two OST staffers. On August 17, 2017, the OST scheduler placed the accident on the Secretary’s calendar, and the Secretary told the scheduler that she would be accessory the event. Emails advertise that OST schedulers forwarded a archetype of this allurement to DOT belief admiral on September 1, 2017. On January 6, 2018, Alfultis alone emailed the Secretary’s scheduler and arrive the Secretary to arise several contest at SUNY, including the Admiral’s Scholarship Feast and VIP pre-dinner reception. Alfultis acclaimed that “Secretary Chao’s ancestor will be accustomed at our Admiral’s Scholarship Dinner.” On February 14, 2018, an OST scheduler emailed Alfutis and declared that the Secretary would be accessory the event. OST staffers were circuitous in analogous the accident with SUNY staff. Aboriginal itineraries of the accident advertise that the Secretary would be giving animadversion at the accident and introducing her ancestor and sister. OIG begin affirmation that OST staffers able animadversion for the Secretary. In addition, staffers brash Dr. Chao and Angela Chao’s biographies for the abode book. Accident bedding able by OST agents acknowledge that McInerney was targeting specific media for the event. OST staffers additionally edited pre- and post-event columnist announcements that accent the able accomplishments of Angela Chao, Dr. Chao, and the Foremost Group. One OST staffer declared this accident as “SUNY Amphibian Accident for Dr. C.” An OST staffer told SUNY accident organizers that four OST staffers would be accompanying the Secretary at the event: one beforehand staff, the Director of Operations, the Director of Attainable Affairs, and a claimed abettor to the Secretary. On April 9, 2018, an OGC belief advocate provided the afterward belief admonition to Inman: “SUNY Amphibian College has arrive the Secretary to allege at their 2018 Admiral’s Scholarship Dinner, captivated at Marina Del Ray, abreast SUNY Maritime’s campus. There will be about 650 attending. This is acquire to acquire as a speaking allure – it is not a allowance to the Secretary or the agency.” It is not bright 25 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 26 of 38) 120E002R200 that the OGC advocate was acquainted that the Secretary would be introducing her ancestor and sister at the event. The Secretary ultimately did not arise this accident and delegated this accident to Amphibian Administrator Buzby. On April 21, 2018, 9 canicule afore the event, McInerney emailed OST beforehand agents advertence that, “Just appetite to reconfirm that all admonition from or about SUNY should be directed to the Foremost offices. They will handle all items and be the lead.” Beforehand agents told OIG lath that because Secretary Chao had cancelled, all added inquiries apropos to Dr. Chao would go anon to the Foremost Group. xiv. Massachusetts Amphibian Academy Admission (June 22–23, 2018) In June 2018, Secretary Chao abounding an MMA admission commemoration at which MMA awarded the Secretary’s ancestor an honorary doctorate amount in attainable administration. In his commemoration with OIG, Inman declared he abstruse at the MMA’s fundraising accident at the Intrepid Sea Air Space Museum in 2017 that McDonald brash to present the Secretary or accession Chao ancestors affiliate with an honorary degree. Emails advertise that in March 2018, Inman requested DOT OGC belief admiral to admonish on the Secretary accepting an honorary degree. On March 14, 2018, Kaleta replied that the Secretary could acquire an honorary amount beneath two conditions: (1) the amount charge be from an accepted attainable or nonprofit academy of college apprenticeship and (2) the timing of the accolade should not annual a reasonable actuality to catechism the Secretary’s artlessness in a amount affecting the institution. Kaleta acclaimed that this was decidedly important in ablaze of DOT programs such as the University Busline Centers Abode and DOT’s accord with the amphibian academies. Inman contacted McDonald on annual of the Secretary to abatement the honorary degree. In an email on April 6, 2018, from MMA advisers to an OST staffer, the MMA agent states, “By the way, Todd Inman is the actuality who contacted President McDonald apropos Secretary Chao carrying the Admission Abode and Dr. Chao accepting the honorary degree.” Inman told OIG that he did not ask McDonald to accolade the honorary amount to the Secretary’s ancestor in lieu of the Secretary. McDonald told OIG that the accommodation to accolade the honorary amount to the Secretary’s ancestor was fabricated by MMA afterwards the Secretary beneath the degree. McDonald added that Angela Chao has been on MMA’s Lath of Advisors aback above-mentioned to Secretary Chao’s choice as DOT Secretary. Afterwards the accommodation to present the honorary amount to the Secretary’s father, aboriginal versions of the Secretary’s biking and accident agenda advertise that the Secretary planned to accord the MMA admission abode and arise the accident in her official capacity. OST beforehand agents accommodating with MMA organizers in planning this event, and MMA organizers beatific beforehand agents aboriginal versions of the admission abode book. MMA advisers additionally beatific copies of Dr. Chao’s bio for the abode book for OST agents to review. OST agents able animadversion for the Secretary to accord at the commencement. Inman abreast DOT belief attorneys that the Secretary planned to arise the admission in her official capacity, present the honorary amount to her father, and accord the keynote 26 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 27 of 38) 120E002R200 admission address. An belief advocate provided abstract admonition to Kaleta via email on May 30, 2018, (b)(5) Kaleta could not board affirmation this admonition was provided to the Secretary or her staff, but the Secretary appears to acquire followed this advice. According to Department biking records, one OST staffer accompanied the Secretary to this event. OIG interviewed the OST staffer, who was circuitous in planning this event. The staffer adumbrated that the Secretary did not arise the accident in her official accommodation and that the staffer was brought alternating as her “plus-one.” The OST staffer added that aback the Secretary abounding the accident in a claimed capacity, she did not accord animadversion at the event, did not sit with her father, and sat appear the end of the date alfresco of the appearance of the cameras. D. Appliance DOT Assets and Subordinate Time for Claimed Tasks OIG’s assay arise instances breadth OST agents associates performed claimed tasks for the Secretary and her ancestors that did not acquire an attainable antecedent to DOT tasks. On September 24, 2017, Secretary Chao beatific an email to an OST agents affiliate with the accountable line, “Dr. Chao’s (b) (6) .” In the email, Secretary Chao stated, “He bought a new (b) (6) (b) (6) at [the store] 2 years ago. 2 years later, it has malfunctioned. (b) (6) was bought from their shop. It was alternate to them for repair. The appraisal was 6 weeks. [Foremost Accumulation employee] has alleged and some genitalia had not arise in and it will still crave 2 added weeks. This is not right. Amuse alarm (b) (6) owners and ask them to expedite. I acclimated to go into the abundance with Dr Chao ….tell them I am SOT.” On September 30, 2017, Secretary Chao beatific an email to two OST agents members, advertence “please alarm [the store] afresh and assay on status. Dr C still has not heard. Do they accelerate (b) (6) for aliment (b) (6) [ ]? and appropriately acquire no ascendancy over how connected it takes? [OST staffer]: If [OST staffer] is not around, amuse alarm [store) and assay on aback (b) (6) ready.” Aback asked about this adventure in during his December 2020 commemoration with OIG, DOT Accustomed Counsel Steven Bradbury said these types of contest should be abhorred and alluringly the Secretary would accomplish added arrangements. OIG additionally begin several instances breadth the Secretary directed OST agents to accomplish claimed tasks for her. Examples of this include: The Secretary forwarding an email from a Foremost Accumulation agent absolute a “Life and Bequest of Ruth Mulan Chu Chao DVD album set design” to an OST staffer and administering that staffer to “print and fedex to Houston today for tomorrow delivery.” 27 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 28 of 38) 120E002R200 The Secretary emailing an OST staffer with subject, “Xmas ornaments” and administering the staffer to “sort out and fedex on Monday to Dr. Chao, and my sisters. Amuse abstract a awning agenda –let me see it-telling them what we are sending.” The Secretary emailing an OST staffer administering the staffer to “Please alarm [(b) (6) ] office, acquaint yourself and me, and acquaint them to let [(b) (6) ] apperceive that Sec Chao will be accompanying Dr. Chao who’s seeing [(b) (6) ]. Acquaint the arrangement that Dr. Chao is a abundant philanthropist -his best contempo allowance is a architecture at Harvard – Ruth Mulan Chu Chao Center…” A Foremost Accumulation agent emailing an OST staffer to appeal admonition in blame (b) (6) ] to move up (b) (6) for the Secretary’s father. “Do you ahead you can admonition to accord beneath [(b) (6) ] a alarm and beforehand a little for an ASAP (b) (6) ]? 2015 we got the [(b) (6) ] 6 weeks afterwards we fabricated the buzz call..hopefull [sic] we can get an EARLIER appt this time!” The OST staffer afresh forwarded this email to the Secretary, “Secretary – I am added than blessed to abetment but aloof appetite to accomplish abiding you are acquire with me administration this?”. Several hours later, the OST staffer responded to the Foremost Accumulation employee, “[Foremost employee] -I batten to [(b) (6) ]. She said she should acquire an arrangement scheduler by tomorrow morning. She will email you and additionally accumulate me in the loop.” In his December 2020 commemoration with OIG, aback abreast that the Secretary’s agents was asked by Dr. Chao’s abettor to acquaintance (b) (6) to “push a little” to get Dr. Chao (b) (6) Bradbury accompanying (b) (5) . The Secretary requesting OST staffers get photos of Dr. Chao active by (b) (6) The Secretary added asked an OST staffer to upload the photo, already autographed, to the DOT-OST aggregate drive “under binder for: Dr Chao.” The Secretary additionally requested OST staffers get photos of Dr. Chao active by (b) (6) A assay of Department emails additionally arise several instances breadth the Secretary directed her agents to assay and/or acquirement claimed items for her online, to board analytic for chargeless aircraft and advertisement codes. These purchases were paid for appliance the Secretary’s claimed acclaim card. In interviews with OIG investigators, one OST staffer explained that there are no “off hours” and that the Secretary works absolutely a lot. Aback asked about active claimed errands for the Secretary, a altered OST staffer accustomed that sometimes it was easier for the staffer to go to a abundance for an annual because if the Secretary went herself it would acquire adapted (b) (7)(E) as able-bodied as an beforehand vehicle. The staffer added that this convenance additionally helped accumulate the Secretary on time and abstain interruptions to the schedule. None of the staffers interviewed by OIG declared activity ordered or apprenticed to accomplish claimed or inappropriate tasks for the Secretary. In addition, none of the staffers interviewed by OIG declared accepting abstracted advantage from the Secretary for assignment performed. Accession staffer told lath that while they did not accept assignment was done for the Secretary’s ancestor or Foremost Group, the agents accessory out for Dr. Chao aback he is with the Secretary because he is in his 90s. 28 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 29 of 38) 120E002R200 In an commemoration with DOT DAEO Judy Kaleta in December 2020, OIG asked whether it would be adapted for DOT agents to accomplish claimed errands or tasks for the Secretary’s father. Kaleta declared that it would bang her as abnormal for that to occur. Aback asked whether it would be adapted for DOT agents to accomplish claimed errands for the Secretary, Kaleta replied, “No,” and declared that this is covered in the accustomed belief training all DOT advisers receive. Kaleta declared that she has no acquaintance of DOT agents assuming claimed errands or tasks for the Secretary. 29 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 30 of 38) 120E002R200 II. DOT OGC Opinions on Belief Issues Abundant in This Abode As allotment of its investigation, OIG interviewed DOT Accustomed Counsel Steven Bradbury and DAEO Judy Kaleta about several of the specific contest declared in Area I aloft and accompanying belief issues. The afterward presents OGC’s opinions apropos (a) the all-embracing belief ambit and vetting activity for claimed and official events, (b) a abstract November 2017 belief announcement that was drafted by OGC belief attorneys but never finalized, (c) improvements fabricated to the vetting activity for the Secretary’s events, and (d) the role of cultural belief of binding allegiance in the Secretary’s accord to her father. A. Belief Ambit for Claimed and Official Contest In his December 2020 commemoration with OIG, Bradbury said commemoration accident the Secretary attends, whether claimed or official, charge be beheld alone and in the accumulation of the surrounding circumstances. He added that claimed and official contest commemoration acquire restrictions in the belief regulations that charge be followed. Bradbury declared it is adapted for DOT to board a aegis detail and basal staffing at the Secretary’s claimed contest in adjustment to “run interference” and ensure that individuals do not try to ask official business of the Secretary. He gave the archetype of accession accompanying the Secretary to acquire a business agenda offered to her and brash that accession would acquaintance that alone at a afterwards date. Bradbury said it would not be adapted for DOT attainable abode agents to arise the Secretary’s claimed events. In addition, Bradbury declared that at claimed events, and decidedly at claimed contest that absorb fundraising, the Secretary’s role should be minimized, advertence she should be addressed or referred to as the Atonement Elaine Chao instead of DOT Secretary. In her December 2020 interview, Kaleta said there is not a connected activity for vetting the Secretary’s invitations to events, as vetting a accurate allurement is situationally dependent. She added vetting can ambit in formality, depending on the timing, and accompanying that abounding invitations are orally vetted. Vetting invitations may crave several aftereffect exchanges amid the organization/inviter, schedulers, and OGC attorneys to apprentice pertinent accommodation about the event, such as who would be sitting with the Secretary at her table. Kaleta added that if the Secretary is accessory in her official capacity, the belief advocate charge assay what abode are awaiting afore DOT. Added factors to accede aback vetting contest include, but are not bound to: what accord the accident or organizer has to the busline industry; whether the alignment or organizer is a lobbyist; the amount of any commons or attendance; who is sitting where; whether the Secretary is giving remarks; whether there is a fundraising component; and whether the accident involves political activity. Kaleta provided added accommodation on the guidelines about contest that the Secretary attends in her claimed capacity. It is permissible for DOT schedulers to abode claimed contest on the Secretary’s calendar, for aegis detail to accompany her, and for one agents actuality to arise to accumulate the Secretary attainable to the Department. Kaleta emphasized that DOT advisers should not abode 30 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 31 of 38) 120E002R200 animadversion for the Secretary’s claimed events. She declared that accustomed the Secretary’s position, it is attainable that advisers could feel apprenticed to do this blazon of assignment if asked by the Secretary. Kaleta common that DOT assets should not be acclimated for the Secretary’s claimed activity. For example, Kaleta said she would not apprehend the Secretary to use the DOT Media Centermost for claimed activity. Kaleta told OIG that the Secretary was appointed by the President to be on assignment armament for Asian and Pacific American initiatives and that OGC does booty some of this into account. However, it was a catechism of to what admeasurement and what end. B. OGC Abstract November 2017 Belief Announcement In November 2017, afterward the annulled cruise to China, Bradbury requested that Kaleta board him admonition accordant to the Secretary’s belief concerns. At the appeal of Kaleta, DOT OGC belief attorneys wrote a memo, apparent as Draft, to Bradbury apropos the (b) (5) (b) (5) (b) (5) In December 2020, OIG interviewed Kaleta apropos the abstract November 2017 memo. In her interview, Kaleta said (b) (5) OIG additionally interviewed Bradbury apropos the abstract November 2017 memo. Bradbury recalled (b) (5) 31 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 32 of 38) 120E002R200 (b) (5) (b) (5) Bradbury declared Kaleta fabricated it bright the adaptation presented to him was not the final adaptation of OGC’s assay of the contest detailed. He added the assay aural the announcement was abridged and did not acquire all of the facts all-important to accomplish a able belief determination. Bradbury could not anamnesis why the announcement was never accomplished but estimated it was apparently because there was no charge to as he saw his recommended activity beforehand for vetting the Secretary’s invitations as the resolution to the issues categorical in the memo. C. Improvements to Belief Vetting of Secretary’s Contest In his commemoration with OIG in December 2020, Bradbury said he believed the issues categorical in the abstract November 2017 announcement were the aftereffect of a abridgement of a accommodating assay by OGC belief admiral during the planning of the Secretary’s accident appearances. Bradbury accompanying that afterwards he came onboard at DOT in November 2017, he fabricated abiding all invitations accustomed by the Secretary, whether claimed or official in nature, were brash by OGC belief officials. Bradbury said he brash the Secretary and afresh Director of Operations Todd Inman that the Secretary should acquire one agenda with both claimed and official invitations on it in adjustment to accumulate bigger clue of all of the invitations advancing in from assorted channels. In a December 2020 interview, Inman additionally told OIG that he began alone ensuring all of the Secretary’s invitations were appropriately vetted in May or June of 2018. In our assay of emails and interviews with OST employees, OIG did not acquisition affirmation of agnate activities apropos to accident appearances by the Secretary continuing able the bounce of 2018. D. Binding Allegiance Announcement In beforehand of his December 2020 commemoration with OIG investigators, Bradbury provided OIG a memo, anachronous September 24, 2020, and blue-blooded “The Accent of Asian Cultural Belief to the Success and Capability of Secretary Elaine L. Chao.” The announcement provided by Bradbury states, in part, “Anyone accustomed with Asian ability knows it is a amount amount in Asian communities to accurate annual and binding commemoration against one’s parents, and this built-in amount of love, respect, and binding allegiance consistently takes antecedence over self-promotion and self-aggrandizement… As the earlier daughter, she is accustomed to accept a administering role in ancestors occasions that annual her ancestor and her backward mother.” 32 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 33 of 38) 120E002R200 The announcement adds, “If the Secretary focused alone on herself in media interviews or in cultural or amusing interactions involving Asian communities and alone any acknowledgment of her parents or admittance of her one active parent, her father, with these audiences, her acceptability and ability as a government official would be beneath appreciably in the eyes of abounding Asians and Asian Americans.” Bradbury said the announcement was accounting by him and was his idea. He added the Secretary and two added OST staffers additionally brash this certificate above-mentioned to it actuality provided to OIG. Bradbury said that Secretary Chao cannot be afar from her father’s adventure and that this abstraction is important to accumulate in mind, but does not alibi all of the issues discussed with OIG, such as the Secretary’s use of subordinates to accomplish claimed tasks. Bradbury said he brash the announcement to be an official DOT certificate because the Secretary’s accord with her ancestor is allotment of her capability as the Secretary. Aback presented with a archetype of this memo, Kaleta declared that neither she nor the career belief attorneys in OGC were consulted in the alertness or drafting of this memo. 33 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 34 of 38) 120E002R200 III. Assay Cease A. Beat to Secretary Chao for Comment OIG offered Secretary Chao, through DOT Accustomed Counsel Steven Bradbury, the befalling to allotment her thoughts apropos the belief issues beneath investigation. OIG was brash that Secretary Chao had annihilation to add to the ahead provided announcement apropos binding allegiance that came from Bradbury on her behalf. The binding allegiance announcement provided to OIG by Bradbury is included beneath in its entirety. September 24, 2020 THE IMPORTANCE OF ASIAN CULTURAL VALUES TO THE SUCCESS AND EFFECTIVENESS OF SECRETARY ELAINE L. CHAO Having served as U.S. Secretary of Labor from 2001 to 2009 and now confined the present Administering as Secretary of Transportation, Elaine L. Chao is the aboriginal Asian American woman anytime to sit in a President’s Cabinet in our Nation’s history. Her acclaimed almanac of attainable commemoration as an Asian American immigrant resonates acutely with the Asian American community, and she is an afflatus to bodies of Asian coast everywhere. Indeed, Secretary Chao’s amount as a cultural role archetypal and agent to Asian communities and to Asia is one of the important assets she brings to the President’s Cabinet and to her assignment as a arch adumbrative of the United States Government. Secretary Chao’s activity and ancestors history allege to the great possibilities our Nation offers first-generation Americans. The Secretary was built-in in Taiwan as the earlier of six daughters, and she came to America with her mother, Mrs. Ruth Mulan Chu Chao, and adolescent sisters by freighter aback she was 8 years old, speaking no English. Her parents had relocated from acreage China to Taiwan afore casual to America. Her father, Dr. James S.C. Chao, was one of the youngest sea captains of his time at the age of 29, and afterwards advancing to the United States, he founded a aggregation that eventually grew into a acknowledged all-embracing aircraft business. Afterwards in life, the Secretary’s parents acquire abundantly accurate educational opportunities for adolescent people, both in the United States and in Asia-a almanac of alms for which they are able-bodied accustomed on both abandon of the Pacific. Naturalized as a U.S. aborigine at the age of 19, Secretary Chao abounding Mount Holyoke College and Harvard Business School and formed in the cyberbanking area afore embarking on her connected career in attainable service. In accession to confined in two Cabinets, she has been Deputy Secretary of Transportation, Chairman of the Federal Amphibian Commission, Deputy Amphibian Administrator, White House Fellow, Director of the Peace Corps, and President and CEO of United Way of America, one of our Nation’s bigger charities. No amount how abundant success she has accomplished in her own career, Secretary Chao, like abounding Asian Americans, has never abandoned her roots as an Asian American immigrant and the acknowledgment she feels for her parents, who acquire formed so adamantine and sacrificed so abundant to board a activity of befalling for their daughters. Anyone accustomed with Asian ability knows it is a amount amount in Asian communities to accurate annual and binding commemoration against one’s parents, and this built-in amount of love, respect, and binding allegiance consistently takes antecedence over self-promotion and self-aggrandizement. It’s not hasty that Secretary Chao is aboveboard appreciative of her family. She dearly loves and ceremoniousness her 93-year-old ancestor and cherishes the anamnesis of her mother, who anesthetized abroad in 2007. As the earlier daughter, she is accustomed to accept a administering role in ancestors occasions that annual her ancestor and her backward mother. 34 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 35 of 38) 120E002R200 These belief are inherent to Secretary Chao as a actuality and as a attainable official, and it’s artlessly not reasonable to ahead she would or could absolutely abstracted and allowance off any announcement of binding allegiance from her functions as a affiliate of the Cabinet. Though it may be difficult for some non-Asians to appreciate, for those steeped in Asian culture, Secretary Chao’s angel and acceptability as a attainable official cannot be afar from her ancestors adventure and from her affirmation of binding commemoration against her parents. For example, aback Asian media contour Secretary Chao or awning her official accomplishments as Secretary, they consistently appetite to acquaint the adventure of her ancestors and board a contour of her ancestor as the arch of her family. Constant with the cultural amount of binding piety, Asian audiences acknowledge with greater commemoration for the Secretary, as a arresting Asian American daughter, aback she takes acceptable opportunities to admit her parents, both about and privately. And Asian audiences acceptable and acknowledge absolutely to accomplishments by the Secretary to board her ancestor in activities aback adapted for instance, as a “plus one” at contest breadth she may be actualization as Secretary. Similarly, aback the Secretary is affianced in attainable abode and beat to nations in Asia or added Asian communities on annual of the United States, those host communities appearance the Secretary’s achievement through the aforementioned cultural lens of binding piety. If the Secretary focused alone on herself in media interviews or in cultural or amusing interactions involving Asian communities and alone any acknowledgment of her parents or admittance of her one active parent, her father, with these audiences, her acceptability and ability as a government official would be beneath appreciably in the eyes of abounding Asians and Asian Americans. Thus, in authoritative time for expressions of binding allegiance and demography advantage of reasonable opportunities to board her ancestor in august functions, Secretary Chao enhances her acceptability and advances the interests of the Department by deepening her capability as a affiliate of the Cabinet and as a adumbrative of the Federal Government to Asian cultural communities. And, importantly, she does so afterwards creating any battle of interest. The all-embracing aircraft business founded by the Secretary’s ancestor is not adapted by the Department of Busline and does not acquire business afore the Department and if it anytime did acquire a absolute absorption in any activity to be taken by the Department, the Secretary would, of course, be recused from accommodating in that action. Over the beforehand of her career, both in and out of government, Secretary Chao has congenital an amazing almanac of attainable commemoration that exemplifies the accomplished standards of professionalism, competence, and ethical conduct. Beneath her leadership, the Department of Busline acts in accordance with the law, does not accommodation on ethics, and never puts clandestine interests aloft the interests of the American people. Any advancement to the adverse based on her accomplishments and abutment of her ancestors ignores the assorted cultural bolt and belief aloft which our country is founded. 2 35 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 36 of 38) 120E002R200 B. Barometer of Assay to the U.S. Department of Justice On December 16, 2020, OIG referred this assay to the U.S. Department of Justice (DOJ), United States Attorney’s Arrangement (USAO) for the District of Columbia, for bent prosecution. The USAO beneath to attainable a bent assay on this matter. The USAO declared that there may be ethical and/or authoritative issues to abode but there is not affirmation to attainable a bent investigation. On December 17, 2020, OIG referred this assay to DOJ Attainable Integrity Area (PIN) for bent prosecution. DOJ PIN beneath to attainable an assay on this matter. C. Abandonment of Secretary Chao On January 7, 2021, Secretary Chao appear her abandonment as U. S. Secretary of Transportation, to booty aftereffect on Monday, January 11, 2020. In a abandonment letter to aloft President Trump afterward the January 6, 2021, anarchism at the Capitol, Secretary Chao wrote, “I had planned on confined through the end of your appellation in office, but afterwards yesterday’s contest at the U.S. Capitol, I will abandon as U.S. Secretary of Transportation, able Monday, January 11, 2021, to board a abbreviate aeon of transition.” D. Cease of Assay Based on the abridgement of prosecutorial absorption from DOJ, OIG has bent it will abutting this investigation. OIG is accouterment a archetype of this abode of assay to the DOT OGC for activity it deems appropriate. 36 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 37 of 38) 120E002R200 GLOSSARY OF FREQUENTLY REFERENCED INDIVIDUALS AND TERMS Steven Bradbury Aloft Accustomed Counsel, Arrangement of the Secretary of Busline (OST); aloft Deputy Secretary, Arrangement of the Secretary of Busline (OST); and aloft Acting Secretary, Arrangement of the Secretary of Busline (OST) Terence Carlson Abettor Accustomed Counsel for Accustomed Law, Arrangement of the Secretary of Busline (OST) Angela Chao The Secretary’s sister, accustomed Administrator and Arch Controlling Officer of Foremost Accumulation Elaine L. Chao Aloft Secretary of Busline Dr. James S.C. Chao Secretary Chao’s ancestor and architect of Foremost Accumulation Foremost Accumulation The Foremost Accumulation is a privately-held aircraft aggregation based in New York, New York. Though Foremost Accumulation is based in New York, it operates globally and none of its argosy are flagged (registered) in the United States. Finch Fulton Aloft Deputy Abettor Secretary for Busline Policy, Arrangement of the Secretary of Busline (OST) Todd Inman Aloft Arch of Staff, Arrangement of the Secretary of Busline (OST) and above-mentioned Director of Operations, Arrangement of the Secretary of Busline (OST) Judy Kaleta Designated Bureau Belief Official (DAEO) and career Deputy Accustomed Counsel, Arrangement of the Secretary of Busline (OST) Derek Kan Aloft Undersecretary for Busline Policy, Arrangement of the Secretary of Busline (OST) Marianne McInerney Aloft Director of Attainable Affairs, Arrangement of the Secretary of Busline (OST) 37 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

Enclosure (Page 38 of 38) 120E002R200 INDEX OF ATTACHMENTS Initiation . October 11, 2019, Chairman of the U.S. House of Assembly Committee on Busline and Infrastructure, Letter to DOT-OIG Overview Accordant Federal belief regulations I. Affirmation Apropos to Abeyant Belief Apropos Credible During the Beforehand of the Assay A. Tasking Political Appointees To Acquaintance DHS on Annual of a Adopted Apprentice (August 2017) B. Including Ancestors Associates and Claimed Contest in the China Trip, Which Was Afterwards Annulled (November 2017) C. Accouterment DOT Media and Attainable Abode Abutment for the Secretary’s Ancestors (2017–2018) C-1. DOT Media Activity Abutment C-2. Attainable Abode and Added Abutment at Specific Contest i. DOT 50th Commemoration (March 29, 2017) ii. Chinese Consolidated Benevolent Association, Chinatown Contest (May 27, 2017) iii. Seamen’s Church Institute Silver Bell Accolade Feast (June 8, 2017) iv. United States Merchant Amphibian Academy Admission (June 17, 2017) All-embracing Administering Foundation Bright (July 21, 2017) vi. Chinese American Academic and Able Society (CAAPS) Commemoration Assemblage (August 19, 2017) vii. Massachusetts Amphibian Academy fundraiser event, Salute to Amphibian Actuality of the Year (September 21, 2017) viii. Chinese Institute of Engineers Bazaar Assemblage (October 14, 2017) ix. OCA Westchester 37th Commemoration and Dynamic Achiever Accolade Bright (November 11, 2017) Chinese Television Interviews (February 9, 2018) xi. EPIC Accomplishment Accolade at Columbia University Teachers College (April 17, 2018) xii. Lloyd’s Annual Accolade (May 23, 2018) xiii. SUNY Amphibian Admiral’s Scholarship Feast (May 1, 2018) xiv. Massachusetts Amphibian Academy Admission (June 22–23, 2018) D. DOT Assets and Subordinate Time for Claimed Tasks V. X. II. DOT OGC Opinions on Belief Issues Abundant in This Abode Memoranda of Activity (MOAs) 38 – Redacted for attainable acknowledgment by the U.S. Department of Transportation, Arrangement of Accustomed Counsel

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