Time and Labor Policy

Background

Because labor costs can be significant on US Government (“USG”) contracts, GovC and its subsidiaries must ensure the accurate and consistent recording of this major cost. Accordingly, as a USG contractor, it is imperative that any GovC employee working on a USG contract accurately record and charge time. Accurate and timely completion of time reports, consistent with this policy, is essential to meeting corporate financial goals and complying with Federal Acquisition Regulations. If labor costs are mischarged to the USG, GovC will have to reimburse the USG for the mischarged costs. However, GovC may also be subject to criminal, civil or administrative penalties and carry the risk of suspension or debarment. Specifically, incorrect or inaccurate labor charges could lead to a violation of the False Claims Act (FCA)

Purpose

To establish requirements that ensure the development and maintenance of effective and consistent controls over the time recording process, and that all necessary control objectives are met, and establish responsibilities that BUs, Managers, and Employees must adhere to.

Scope

This policy applies to all GovC employees who work for a BU that performs, directly or indirectly on USG contracts or subcontracts. Employees of BUs who only perform USG work that is commercial or competitive procurements are exempt.

Policy

It is the Policy of GovC and its subsidiaries to accurately record time and report time and labor, and that employees properly and accurately record the time they work as mandated by Federal Regulations. This policy establishes guidelines and requirements for the recording of Time and Labor.

Attachment A - Is the Time Reporting Employee Certification Form.

Basic Requirements

Employee Responsibilities

Primary responsibility for accurately recording time belongs to the individual employee performing the effort. Each employee working on a USG contract is personally responsible for maintaining a daily, accurate and complete record, of time spent on assigned projects. Each week the employee is to sign (and by signing, certifying that the information is correct) and submit to his/her supervisor. Time actually spent on a given task is to be charged only to that task. Similarly, all time spent on a particular task must be charged to that task and no other task.

Employees shall

• Understand proper time recording procedures
• Understand the cost objective that they are working on, and only charge that cost objective.
• Record time daily
• Sign/submit their electronic timesheet on the last day of the time reporting period. This submittal or signing shall be the certification that the time sheet is accurate, and reflects the actual work that was performed during the time period.
• Document time sheet corrections.
• Protect their passwords to the time keeping system and shall not share that password with other individuals.
• If you are asked or directed to mischarge, you should seek help from management or your local business ethics and compliance officer (BECO) or submit an inquiry on GovC’s helpline or call the Director, US Government Contracting Compliance, the Vice President & General Counsel, North America.

Employees Shall Not

• Falsify or submit a timesheet that is inaccurate.
• Record time in advance unless they have business travel, planned compensated absence, or leave-without-pay at the end of the pay period, or year-end processing makes it necessary.
• Complete a timesheet for another individual

Manager/Supervisor Responsibilities

The manager/supervisor, along with the employee, has responsibilities for ensuring accurate time recording.

Manager/Supervisors Shall

• Ensure that all employees under their supervision, especially new employees, know their correct classification as exempt, non-exempt (hourly) and the corresponding differences in reporting and have been instructed in labor codes/tasks.
• Ensure employees are timely submitting time cards for approval.
• Review and approve, on a timely basis, the time charging records of their employees.

ATTACHMENT A: GOVC TIME REPORTING EMPLOYEE CERTIFICATION FORM

As an employee who works directly or indirectly on contracts for the USG, I certify the following:

• I have worked all of the time represented on my time sheets for the period of X to Y;

• I am legally liable for misstatements on my timesheets.

• I have read GovC’s Time and Labor Policy

• I am obligated to report violations of time reporting.

• It is my responsibility to understand time keeping requirements and processes, and to seek assistance, guidance, and training on time reporting.

I understand that any employee who has engaged in improper charging of time may be subject to disciplinary action, which may include warning, reprimand, probation, reduction in compensation, demotion, suspension and/or dismissal.

_______________________________________________________________ Employee Name (Printed) Signature Date