Procurement Integrity and Protection of Competition Sensitive Information Policy

Introduction

Purpose

The purpose of this policy is to ensure that GovC conducts business under U.S. Government (USG) Programs in full compliance with the Procurement Integrity Act and implementing regulations.

Scope

The policy applies to all Company employees (regular full-time and part-time) and temporary agency employees, independent contractors, and consultants.

Policy Statement

GovC is committed to complying with all laws and regulations intended to protect the integrity of the USG procurement process. The U.S. Procurement Integrity Act (the "Act") seeks to protect the integrity of the procurement process by (1) forbidding improper access to and disclosure of competition-sensitive information such as information about a competitor's proposal or inside information about the Government agency evaluation process, and (2) by restricting employment discussions and employment between U.S. Government employees involved in the procurement process and contractors competing for USG contracts. The Act both restricts acceptance of employment by some former USG employees and also restricts employment contracts between some current USG officials and USG contractors.

Offering or accepting competitors' confidential or trade secret information can be illegal, particularly in the USG marketplace. Improperly releasing or obtaining proprietary information may also violate the Privacy Act, the Defend Trade Secrets Act (including state laws implementing Uniform Trade Secrets Act), the Freedom of Information Act, and other laws and regulations.

Procurement integrity violations can lead to civil and criminal fines and imprisonment for the Company and its employees, and can lead to cancellation of USG contracts and grants and ineligibility for future awards. For example, receipt by a GovC employee of a competitor's pricing information during a competition can lead to the USG barring GovC from receiving that award. It could also serve as a basis for a bid protest that could eliminate the Company from the competition.

It is Company policy that employees and others covered by this Policy immediately contact the GovC Legal Department if they become aware of a possible Procurement Integrity Act violation by GovC, a competitor, or a USG employee or former employee. In the event that anyone covered by this policy receives, is offered, or is aware of anyone covered by this policy having received or been offered competition sensitive information, the proper response is to contact the Legal Department immediately. Employees shall not otherwise circulate, share, review, or discuss such information unless and until the Legal Department has been consulted and decided on appropriate next steps.

In situations involving a competitor gaining improper access to GovC or USG sensitive information, GovC may need to notify the USG with 14 days of learning of the violation to protect GovC's interest.

Any employee