Doc ID-number: APP-0330 Revision: 01 B Title: DBE Program Plan Purpose: The purpose of this procedure is to describe Bombardier Transportation’s DBE Program Plan as well as the calculation methodology for Bombardier Transportation’s Annual Goal. This document and its contents are the property of Bombardier Inc. or its subsidiaries. This document contains confidential proprietary information. The reproduction, distribution, utilisation or the communication of this document or any part thereof, without express authorisation is strictly prohibited. Offenders will be held liable for the payment of damages. Organization and BT process structure prefix : Doc ID-number : APP - 0330 Effective date: Revision : Original Language : © 2008 Bombardier Inc. or its subsidiaries. All rights reserved 2012-03-31 Proprietary 01 EN Page 1 of 16 Doc ID-number: APP-0330 Revision: 01 Revision log Revision Date 0 2008-12-15 1 Proprietary (yyyy-mm-dd) 2012-03-31 Description of changes First Issue - Update to definitions - Removal of Subcontractor definition - Update of Bidder’s list section - Update to DBE Liaison Officer (DBELO) section - Update to Directory section - Removal of Overconcentration section - Update to Overall goal section - Update to Contract goal section - Update to Re-certification section - Removal of “No change” affidavit and notices of change section - Update of Appendix 1 – Organizational chart Page 2 of 16 Doc ID-number: APP-0330 Revision: 01 Table of Contents Section 1 Subject Page SUBPART A – GENERAL REQUIREMENTS 5 1.1 INTRODUCTION (ref: 49 CFR 26.3) 5 1.2 POLICY STATEMENT (ref: 49 cfr 26.1 & 26.3) 6 1.3 DEFINITIONS (ref: 49 CFR 26.5) 7 1.4 NON-DISCRIMATION REQUIREMENTS (ref: 49 CFR 26.7) 9 1.5 RECORD KEEPING REQUIREMENTS (ref: 49 CFR 26.11) 9 1.6 BIDDER’S LIST (ref: 49 CFR 26.11) 10 1.7 FEDERAL FINANCIAL ASSISTANCE AGREEMENT (ref: 49 CFR 26.13) 10 1.7.2. Assurance (ref: 49 CFR 26.13 (a)) 1.7.2. Contract Assurance (ref: 49 CFR 26.13 (b)) 2 SUBPART B – ADMINISTRATIVE REQUIREMENTS 10 10 10 2.1 DBE LIAISON OFFICER (DBELO) (ref: 49 CFR 26.25) 10 2.2 DBE FINANCIAL INSTITUTIONS (ref: 49 CFR 26.27) 12 2.3 DIRECTORY (ref: 49 CFR 26.31) 12 2.4 MONITORING AND ENFORCEMENT MECHANISMS (ref : 49 CFR 26.37) 3 SUBPART C – GOALS, GOOD FAITH EFFORTS, AND COUNTING 12 12 3.1 SET-ASIDES OR QUOTAS (ref: 49 CFR 26.43) 12 3.2 OVERALL GOALS (ref: 49 CFR 26.45) 12 3.3 TRANSIT VEHICLE MANUFACTURERS GOALS (ref: 49 CFR 26.49) 13 3.4 BREAKOUT OF ESTIMATED RACE-NEUTRAL & RACE CONSCIOUS PARTICIPATION (ref: 49 CFR 26.51 (a-c)) 13 3.5 CONTRACT GOALS (ref: 49 CFR 26.51 (d-g)) 13 3.6 GOOD FAITH EFFORTS PROCEDURES 14 3.6.1. Demonstration of good faith effort (ref: 49 CFR 26.53 (a) & (c)) 14 3.6.2. Information to be submitted (ref: 49 CFR 26.53 (b)) 14 3.6.3. Good faith effors when a DBE is replaced on a subcontract (ref: 49 CFR 26.53 (f)) 14 3.6.4. Counting DBE participation towards goals (ref: 49 CFR 26.55) 4 SUBPART D – CERTIFICATION STANDARDS 14 14 4.1 CERTIFICATION PROCESS (ref; 49 CFR 26.61 – 26.73) 5 SUBPART E – CERTIFICATION PROCEDURES 14 15 5.1 UNIFIED CERTIFICATION PROGRAMS (ref 49 CFR 26.81) 15 5.2 PROCEDURE FOR CERTIFICATION DECISIONS (ref: 49 CFR 26.83) 15 5.2.1. Re-certification (ref: 49 CFR 26.83) 6 SUBPART F- COMPLIANCE AND ENFORCEMENT 6.1 INFORMATION, CONFIDENTIALITY, COOPERATION (ref: 49 CFR 26.109) Proprietary 15 15 15 Page 3 of 16 6.2 MONITORING PAYMENTS TO DBEs APPENDIX 1. Organizational Chart 15 16 Doc ID-number: APP-0330 Revision: 01 1 SUBPART A – GENERAL REQUIREMENTS 1.1 INTRODUCTION (ref: 49 CFR 26.3) Bombardier Transit Corporation (“Bombardier”) is a Transit Vehicle Manufacturer (“TVM”), therefore receives no direct funding from the FTA. Through its contractual relationship with FTA Recipients (Federal transit funds authorized by Titles I, III, V, and VI of ISTEA, Pub. L. 102-240 or by Federal transit laws in Title 49, U.S. Code, or Titles I, III, and V of the Transportation Equity Act for the 21st Century (TEA-21), Pub. L. 105-178.) and in accordance with requirements of 49 Code of Federal Regulations Part 26 (“49 CFR 26”) , Bombardier has developed a DBE Program Plan (“DBE Program”) for the purpose of leveling the playing field for DBEs with respect to projects funded in whole or part by the U. S. Department of Transportation (“U.S.D.O.T” or “DOT”). The provisions of Bombardier’s DBE Program shall apply to all subcontractors. This program document supercedes any previously issued policy or procedural statements that may conflict with its content. In the event that any language within this program document conflicts with the regulations found at 49 CFR Part 26, the regulations shall have primary authority. Proprietary Page 5 of 16 Doc ID-number: APP-0330 Revision: 01 1.2 POLICY STATEMENT (ref: 49 cfr 26.1 & 26.3) Proprietary Page 6 of 16 Doc ID-number: APP-0330 Revision: 01 1.3 DEFINITIONS (ref: 49 CFR 26.5) NOTE: Additional definitions applicable to the DBE Program may be found in 49 CFR 26.5 (http://edocket.access.gpo.gov/cfr_2005/octqtr/pdf/49crf26.5) Affiliation has the same meaning the term has in the Small Business Administration (“SBA”) regulations, 13 CFR Part 121. (a) Except as otherwise provided in 13 CFR 121, concerns are affiliates of each other when, either or directly or indirectly: (i) (ii) (iii) One concern controls or has the power to control the other; or A third party or parties controls or had the power to control both; or An identity of interest between or among parties exists such that affiliation may be found. (b) In determining whether affiliation exists, it is necessary to consider all appropriate factors, including common ownership, common management and contractual relationships. Affiliates must be considered together in determining whether a concern meets small business size criteria and the statutory cap on the participation of firms in the DBE Program. Alaska Native means a citizen of the United States who is a person of one-fourth degree or more Alaskan Indian (including Tsimshian Indians not enrolled in the Metlaktla Indian Community), Eskimo, or Aleut blood, or a combination of those bloodlines. The term includes, in the absence of proof of a minimum blood quantum, any citizen whom a Native village or Native group regards as an Alaskan Native if their father or mother is regarded as an Alaskan Native. Alaska Native Corporation (“ANC”) means any Regional Corporation, Village Corporation, Urban Corporation, or Group Corporation organized under the laws of the State of Alaska in accordance with the Alaska Native Claims Settlement Act, as amended (43 U.S.C. 1601, et. seq). Contract means a legally binding relationship obligating a seller to furnish supplies or services (including, but not limited to, construction and professional services) and the buyer to pay for them. For the purpose of this part, a lease is considered a contract. Contractor means one who participates, through a contract or a subcontract (at any tier), in a DOTassisted highway, transit, or airport program. Department or (“DOT”) means the U.S. Department of Transportation, including the Office of the Secretary, the Federal Highway Administration (FHWA), the Federal Transit Administration (FTA) and the Federal Aviation Administration (FAA). Disadvantaged Business Enterprise or (“DBE”) means for a profit small business concern: (a) That is at least 51 percent owned by one or more individuals who are both socially and economically disadvantaged or, in the case of a corporation, in which 51 percent of the stock is owned by one or more such individuals; and (b) Whose management and daily business operations are controlled by one or more of the socially and economically disadvantaged individuals who own it. Good faith effort means efforts to achieve a DBE goal or other requirement of the 49 CFR Part 26 which, by their scope, intensity and appropriateness to the objective, can reasonably be expected to fulfill the program requirement. Proprietary Page 7 of 16 Doc ID-number: APP-0330 Revision: 01 Immediate family member means father, mother, husband, wife, son, daughter, brother, sister, grandmother, grandfather, grandson, granddaughter, mother-in-law or father-in-law. Indian Tribe means any Indian Tribe, band, nation, or other organized group or community of Indians, including any ANC, which is recognized as eligible for the special programs and services provided by the United States to Indians because of their status as Indians, or is recognized as such by the State in which the tribe, band, nation, group or community resides. See definition of “Tribally-owned Concern” in this section. Native Hawaiian means any individual whose ancestors were natives, prior to 1778, of the area that now comprises the State of Hawaii. Native Hawaiian Organization means any community service organization serving Native Hawaiians in the State of Hawaii which is a not-for-profit organization chartered by the State of Hawaii, is controlled by Native Hawaiians, and whose business activities will principally benefit such Native Hawaiians. Noncompliance means that a recipient has not correctly implemented the requirements of 49 CFR Part 26. Operating Administration or (“OA”) means any of the following parts of U.S.D.O.T.: The Federal Aviation Administration (“FAA”), Federal Highway Administration (“FHWA”) and the Federal Transit Administration (“FTA”). The “Administrator” of an operating administration includes his or her designees. Personal net worth (“PNW”) means the net value of the assets of an individual remaining after total liabilities are deducted. An individual’s personal net worth does not include: The individual’s ownership interest in an applicant or participating DBE firm; or the individual’s equity in his or her primary place of residence. An individual’s personal net worth includes only his or her own share of assets held jointly or as a community property with the individual’s spouse. Primary Industry Classification means the North America Industrial Classification System (NAICS) designation which best describes the primary business of a firm. The NAICS is described in the North American Industry Classification Manual – United States, 1997 which is available from the National Technical Information Service, 5285 Port Royal Road, Springfield, VA 22161; by calling 1 (800) 553-6847; or via the internet at http://www.ntis, gov/product/naics.htm. Primary Recipient means a recipient which receives D.O.T. financial assistance and passes some or all of it on to another recipient Principal place of business means the business location where the individuals who manage the firm’s day-to-day operations spend most working hours and where top management’s business records are kept. If the offices from which management is directed and where business records are kept are in different locations, the recipient will determine the principal place of business for the DBE Program purposes. Program means any undertaking on a recipient’s part to use D.O.T. financial assistance, authorized by the laws to 49 CFR Part 26. Race-conscious measure or program is one that is focused specifically on assisting only DBE’s, including women-owned DBEs. Race-neutral measure or program is one that is, or can be, used to assist all small businesses. For the purpose of 49 CFR Part 26, Race-neutral includes gender-neutrality. Recipient is any entity, public or private, to which D.O.T. financial assistance is extended, whether directly or through another recipient, through the programs of the FAA, FHWA, or FTA, or who has applied for such assistance. SBA certified firm refers to firms that have a current, valid certification from or are recognized by the SBA under the 8(a) BD or SDB programs. Secretary means the Secretary of Transportation or his/her designee. Set-aside means contracting practice restricting eligibility for the competitive award of a contract, solely to DBE firms. Proprietary Page 8 of 16 Small Business Administration (“SBA”) means the United States Small Business Administration. Small business concern means, with respect to firms seeking to participate as DBEs in DOT-assisted contracts, a small business concern as defined pursuant to section 3 of Small Business Act and Small Business Administration regulations implementing it (13 CFR part 121) that also does not exceed the cap on average annual gross receipts specified in § 26.65(b). Socially and economically disadvantaged individual means any individual who is a citizen (or lawfully admitted permanent resident) of the United States and who is (1) any individual who a recipient finds to be a socially and economically disadvantaged individual on a case-by-case basis; or (2) any individual in the following groups, members of which are rebuttably presumed to be socially and economically disadvantaged: (a) “Black American” which includes persons having origins of the Black racial groups of Africa; (b) “Hispanic Americans” which includes persons of Mexican, Puerto Rican, Cuban, Dominican, Central or South American, or other Spanish or Portuguese culture or origin, regardless of race; (c) “Native Americans” which includes persons who are American Indians, Eskimos, Aleuts or Native Hawaiians; (d) “Asian-Pacific Americans” which includes persons whose origins are from Japan, China, Taiwan, Korea, Burma (Myanmar), Vietnam, Laos, Cambodia (Kampuchea), Thailand, Malaysia, Indonesia, the Philippines, Brunei, Samoa, Guam, the U.S. Trust Territories of the Pacific Islands (Republic of Palau), the Commonwealth of the Northern Marianas Islands, Macao, Fiji, Tonga, Kiribati, Juvalu, Nauru, Federated states of Micronesia or Hong Kong; (e) “Subcontinent Asian Americans” which includes persons whose origins are from India, Pakistan, Bangladesh, Bhutan, the Maldives Islands, Nepal or Sri-Lanka; (f) Women; (g) Any additional groups whose members are designated as socially and economically disadvantaged by the SBA, at such times as the SBA designation becomes effective. Tribally-owned concern means any concern at least 51 percent owned by an Indian tribe as defined in this section. U.S.D.O.T.-assisted contract means any contract between a recipient and a contractor (at any tier) funded in whole or in part with DOT financial assistance, including letters of credit or loan guarantees, except a contract solely for the purchase of land. 1.4 NON-DISCRIMATION REQUIREMENTS (ref: 49 CFR 26.7) Bombardier will not exclude any person from participation in, deny any person the benefit of, or otherwise discriminate against anyone in connection with the award and performance of any contract covered by 49 CFR Part 26 on the basis of race, color, sex, or national origin. In administrating its DBE Program, Bombardier will not, directly or through contractual or other arrangements, use criteria or methods of administration that have the effect of defeating or substantially impairing accomplishment of the objectives of the DBE program with respect to the individuals of a particular race, color, sex, or national origin. 1.5 RECORD KEEPING REQUIREMENTS (ref: 49 CFR 26.11) Bombardier will continue to provide data about Bombardier’s DBE Program to the Department as directed by DOT OAs and will provide to DOT updates of any significant changes in Bombardier’s DBE Program. Bombardier will report DBE participation on a semi-annual basis, using DOT form 4630. These reports will reflect payments actually made to DBEs on DOT-assisted contracts. 1.6 BIDDERS LIST (ref: 49 CFR 26.11) BTNA will create a bidders list, consisting of information about all DBE and non-DBE firms that bid or quote on DOT-assisted contracts. The purpose of this requirement is to allow use of the bidders list approach to calculating overall goals. For every firm on the Bombardier bidders list, the following information will be included: a) b) c) d) Firm name; Firm coordinates (address, phone, fax, e-mail); Firm status as DBE or non-DBE; If the firm is a DBE, current certification. Every time a Request for Quote (“RFQ”) is sent out to potential DBE and non-DBE subcontractors, the above-mentioned data will be requested and only bidders will have to provide the information. 1.7 FEDERAL FINANCIAL ASSISTANCE AGREEMENT (ref: 49 CFR 26.13) Bombardier has signed the following assurances, applicable to all DOT-assisted contracts and their administration: 1.7.2. Assurance (ref: 49 CFR 26.13 (a)) Bombardier shall not discriminate on the basis of race, color, national origin, or sex in the award and performance of any subcontract related to a DOT-assisted contract or in the administration of its DBE Program or the requirement of 49 CFR Part 26. Bombardier shall take all necessary and reasonable steps under 49 CFR Part 26 to ensure nondiscrimination in the award and administration of such subcontracts. Bombardier’s DBE Program, as required by 49 CFR Part 26 and as approved by DOT, is incorporated by reference in those subcontracts. Implementation of this program is a legal obligation and failure to carry out its term shall be treated as a violation of this subcontract. Upon notification to Bombardier of its failure to carry out its approved program, DOT may impose sanction as provided for under Part 26 and may, in appropriate cases, refer the matter for enforcement under 18 U.S.C. 1001 and/or the Program Fraud Civil Remedies Act of 1986 (31 U.S.C. 3801 et seq.). 1.7.2. Contract Assurance (ref: 49 CFR 26.13 (b)) Each contract Bombardier signs with a subcontractor will include the following assurance: Subcontractor shall not discriminate on the basis of race, color, national origin, or sex in the performance of this subcontract. The subcontractor shall carry out applicable requirements of 49 CFR Part 26 in the administration of DOT assisted subcontracts. Failure by the subcontractor to carry out these requirements is a material breach of this subcontract, which may results in the termination of this subcontract or such other remedy as Bombardier deems appropriate. 2 SUBPART B – ADMINISTRATIVE REQUIREMENTS 2.1 DBE LIAISON OFFICER (DBELO) (ref: 49 CFR 26.25) Bombardier has designated the following individual as the DBE Liaison Officer: Sophie Moore, Project Leader, Bids & Proposal Address: 1101 rue Parent St-Bruno, Quebec Canada J3V 6E6 In that capacity, the DBELO is responsible for implementing all aspects of the DBE Program and ensuring that Bombardier complies with all provisions of 49 CFR Part 26. The DBELO has direct access to Mr. Raymond Bachant, President of Bombardier Transportation – North America concerning DBE Program matters. An organization chart displaying the DBELO’s position in the organization is found in Attachment 1 to this program. The DBELO is responsible for developing, implementing and monitoring the DBE Program. The duties and responsibilities include the following: 1. Gathers and reports data and other information as required by DOT. 2. Supports and brings expertise to the procurement team when reviewing third party contracts and purchase requisitions for compliance with this program. 3. Works with all departments to set overall annual goals. 4. Ensures that bid notices and requests for proposals are available to DBEs in a timely manner. 5. Identifies contracts and procurements so that DBE goals are included in solicitations and monitors results. 6. Analyzes Bombardier’s progress toward attainment and identifies ways to improve progress. 7. Participates in pre-bid meetings. 8. Advises the CEO/Governing body on DBE matters and achievement. 9. Plans and participates in DBE training seminars. 10. Maintains Bombardier’s directory on certified DBEs. Doc ID-number: APP-0330 Revision: 01 2.2 DBE FINANCIAL INSTITUTIONS (ref: 49 CFR 26.27) If expressly required by the DOT-assisted Recipient, Bombardier will investigate the full extent of services offered by financial institutions owned and controlled by socially and economically disadvantaged individuals in the community, will make reasonable efforts to use these institutions, and will encourage subcontractors on DOT-assisted contract to make use of these institutions. 2.3 DIRECTORY (ref: 49 CFR 26.31) Bombardier maintains a directory identifying all firms able to participate as DBEs. The directory lists the firm’s name, address, phone number, date of the most recent certification, and the type of work the firm has been certified to perform as a DBE. We revise the Directory on a regular basis. The Directory can be obtained by contacting Bombardier’s DBELO. Refer to section 2.1 for coordinates. 2.4 MONITORING AND ENFORCEMENT MECHANISMS (ref : 49 CFR 26.37) Bombardier will bring to the attention of the Department of Transportation any false, fraudulent, or dishonest conduct in connection with the program, so that DOT can take the steps (e.g., referral to the Department of Justice for criminal prosecution, referral to the DOT Inspector General, action under suspension and debarment or Program Fraud and Civil Penalties rules) provided in 26.109. Bombardier will also consider similar action including review of the subcontractor’s prequalification to bid and possible debarment actions. 3 SUBPART C – GOALS, GOOD FAITH EFFORTS, AND COUNTING 3.1 SET-ASIDES OR QUOTAS (ref: 49 CFR 26.43) Bombardier does not use set-asides or quotas in any way in the administration of the DBE Program 3.2 OVERALL GOALS (ref: 49 CFR 26.45) To make Bombardier’s DBE Program as useful as possible to the public, the amount of the annual overall goal and the method used to set that goal will be updated annually, if necessary. If the method of setting goals changes, the updated program will be submitted to DOT for review and approval. Proprietary Page 12 of 16 Doc ID-number: APP-0330 Revision: 01 In accordance with Section 26.45 (f) Bombardier will submit its overall goal to DOT for FY 2012 on March 31st, 2012 and thereafter on August 1st of each year for all upcoming FYs unless DOT requests otherwise. Bombardier will publish a notice of the proposed overall goals, informing the public that the proposed goal and its rationale are available for inspection during normal business hours at our principal office for 30 days following the date of the notice, and informing the public that Bombardier and DOT will accept comments on the goals for 45 days from the date of the notice. The notice will include an address to which comments may be sent, and will be published in Passenger Transport Magazine. 3.3 TRANSIT VEHICLE MANUFACTURERS GOALS (ref: 49 CFR 26.49) Bombardier, being a transit vehicle manufacturer, must establish and submit for FTA’s approval an annual overall percentage goal. In setting its overall goal, Bombardier is guided, to the extent applicable, by the principles underlying § 26.45. The base from which this goal is calculated corresponds to the amount of FTA financial assistance included in transit vehicle contracts Bombardier will perform during the fiscal year in question. The requirements and procedures of this section with respect to submission and approval of overall goals apply to Bombardier and its subcontractors. 3.4 BREAKOUT OF ESTIMATED RACE-NEUTRAL & RACE CONSCIOUS PARTICIPATION (ref: 49 CFR 26.51 (a-c)) The breakout of estimated race-neutral and race-conscious participation can be requested by contacting Bombardier’s DBELO. 3.5 CONTRACT GOALS (ref: 49 CFR 26.51 (d-g)) Bombardier reserves the right to establish contract goals to meet any portion of the overall goal. Contract goals are established so that, over the period to which the overall goal applies, they will cumulatively result in meeting any portion of our overall goal that is not projected to be met through the use of race-neutral means. Bombardier will establish contract goals only on those DOT-assisted contracts that have subcontracting possibilities. Bombardier will not establish a contract goal on every such contract, and the size of the contract goals will be adapted to the circumstances of each such contract (e.g., type and location of work, availability of DBEs to perform the particular type of work). Bombardier will express our contract goals as a percentage of the Federal share of a DOT-assisted contract. Bombardier will monitor DBE participation by gender and ethnicity. Proprietary Page 13 of 16 Doc ID-number: APP-0330 Revision: 01 3.6 GOOD FAITH EFFORTS PROCEDURES 3.6.1. Demonstration of good faith effort (ref: 49 CFR 26.53 (a) & (c)) The obligation of the bidder/offeror is to make good faith efforts. The bidder/offeror can demonstrate that it has been done by either meeting the contract goal or documenting good faith efforts. Bombardier will ensure that all information is complete and accurate and adequately documents the bidder/offeror’s good faith efforts before we commit to the performance of the contract by the bidder/offeror. 3.6.2. Information to be submitted (ref: 49 CFR 26.53 (b)) Each solicitation, for which a contract goal has been established, will require the bidders/offerors to submit the following information: 1. 2. 3. 4. 5. 6. The names and addresses of DBE firm that will participate in the contract; A description of work that each DBE will perform; The dollar amount of the participation of each DBE firm participating; Written and signed documentation of commitment to use a DBE subcontractor whose participation it submits to meet a contract goal; Written and signed confirmation from the DBE that it is participating in the contract as provided in the prime contractor’s commitment and; If the contract goal is not met, evidence of good faith efforts. 3.6.3. Good faith effors when a DBE is replaced on a subcontract (ref: 49 CFR 26.53 (f)) Bombardier will make good faith efforts to replace a DBE that is terminated or has otherwise failed to complete its work on a subcontract with another certified DBE, to the extent needed to meet the contract goal. 3.6.4. Counting DBE participation towards goals (ref: 49 CFR 26.55) Bombardier will count DBE participation toward overall and contract goals as provided in 49 CFR 26.55. 4 SUBPART D – CERTIFICATION STANDARDS 4.1 CERTIFICATION PROCESS (ref; 49 CFR 26.61 – 26.73) Bombardier, being a Transport Vehicle Manufacturer, will not be performing any certification of its own. Proprietary Page 14 of 16 Doc ID-number: APP-0330 Revision: 01 5 SUBPART E – CERTIFICATION PROCEDURES 5.1 UNIFIED CERTIFICATION PROGRAMS (ref 49 CFR 26.81) Not applicable 5.2 PROCEDURE FOR CERTIFICATION DECISIONS (ref: 49 CFR 26.83) 5.2.1. Re-certification (ref: 49 CFR 26.83) Not applicable 6 SUBPART F- COMPLIANCE AND ENFORCEMENT 6.1 INFORMATION, CONFIDENTIALITY, COOPERATION (ref: 49 CFR 26.109) Bombardier will safeguard from disclosure to third parties information that may reasonably be regarded as confidential business information, consistent with prime contract between Bombardier and the contracting authority, Federal, State and local law. Notwithstanding any contrary provisions of State or local law, we will not release personal financial information submitted in response to the personal net worth requirement to a third party without the written consent of the submitter. 6.2 MONITORING PAYMENTS TO DBEs Bombardier will require subcontractors to maintain records and documents of payments to DBEs for three years following the performance of the prime contract between Bombardier and the contracting authority. These records will be made available for inspection upon request by any authorized representative of Bombardier or DOT. This reporting requirement also extends to any certified DBE subcontractors. Bombardier could perform interim audits of contract payments to DBEs. The audit would review payments to DBE subcontractors to ensure that the actual amount paid to DBE subcontractors equals or exceeds the dollar amounts stated in the schedule of DBE participation. Proprietary Page 15 of 16 Doc ID-number: APP-0330 Revision: 01 APPENDIX 1. Proprietary Organizational Chart Page 16 of 16