[Name][Position][Date]

[Program Name]ORGANIZATIONAL

CONFLICT OF INTEREST TRAINING

Overview

Organizational Conflict of Interest - Defined [Program Name] OCI Mitigation Plan

Measures Employee Responsibilities Questions/Comments [Program Name] POCs

Organizational Conflict of Interest (OCI) - Defined

FAR 9.5 defines an OCI as a contractor’s inability or potential inability to render impartial services, where its objectivity may be impaired, or the contractor has an unfair competitive advantage.

The OCI situation can be either “actual” or a “perception” that a potential for an unfair advantage or bias could exist.

Organizational Conflict of Interest (OCI) - Defined Unequal Access to Information – Nonpublic information during

performance of a contract (e.g. proprietary or financial data of the government or a competitor) which may yeild an unfair competitive advantage

Biased Ground Rules – Establishing the “critical baseline” for a contract that your company may compete under (e.g. writing or advising on the SOW, specifications, evaluation criteria, proposal development, etc.)

Impaired Objectivity – contractor placed in a situation of providing assessment and evaluation over work performed or products provided by the same company

[Program Name] data

[Program Name] awarded xx/xx/xxxxGeneral stats about program, value, POP, etcOCI Mitigation Plan required because………Mitigation Plan applies to all APL entities, Team

Mates and subcontractors.Any other unique OCI related all data or

issues ……….

[Program] OCI Mitigation Plan Measures

USE YOUR PLAN’S TABLE OF CONTENTS AS A GUIDE, only an example below, then the subsequent slides should match and provide a few bullet points

Proprietary/Sensitive Data Safeguards Procedures

Assignment SeparationNDAs Marking, Handling, Storage, and Destruction of Data Protection of Information Technology Reassignment Departure

Audit OCI Training Recordkeeping Subcontractor Flowdown of OCI Mitigation Measures

(Sample)Assignment Separation

Assigned Personnel Firewall List Exclusion from certain assignments No transfers between certain programs Access controlled to all program shared sites

(This is just a sample of slides derived from your plan --each set of slides is unique to your plan, emphasize whatever measures make sense)

(Sample 2) [Program Name] NDAs

Employee Responsibilities

Maintain general awareness of OCI risk Read [program] OCI Mitigation Plan folder

on shared drive Comply with [Program Name] OCI

Mitigation Plan:Sign OCI NDA – Attachment XXSign OCI Training Certification – Attachment XXSign OCI Exit Interview – Attachment XXProtect all Program generated information per program

directivesDisclose any OCI that may arise during course of

performance to the your Contracts Manager, or anonymously via the Ethics hotline

NDA vs. Employee Restrictions

NDA obligations are to protect information and continues after leaving the program until either the information is made public or the Government or 3rd party authorizes release, i.e. “in perpetuity”, no defined end date

Employee restrictions are based upon the obligation stated in the Plan and are specific to the OCI risk created on the program, e.g. you cannot work on a related proposal or you cannot work on a related development or production contract , for a specific timeframe after you leave the program (1year , etc) . The restriction applies whether you work on a different company program or at another company. You must disclose any restrictions to the new hiring manager/company.

Any Questions?

[Program Name] POCs

Program Mgmt: HR: Contracts: Subcontracts: Security: