Trainees working at the NIH who are not Government employees (non-FTEs) are not subject to the Standards of Ethical Conduct in the same manner as are regular employees. The NIH policies and procedures for requesting approval for non-FTEs to engage in certain activities involving outside entities, including official activities, personal activities, and receipt of awards, are available on the NIH Office of Intramural Research website, in the OIR Sourcebook.
OIR Sourcebook: Trainee Guidelines