Organizational
Conflicts of Interest (OCI)
New Developments in the U.S.
and Abroad
A Panel Discussion including:
Richard C. Bean, Attorney at Law
Peter J. Camp, Counsel, U.S. Air Force ESC
Joseph J. Kelley, Senior Counsel, Raytheon
On The Regulatory Front- OCI:
• FAR Case 2011-001: where are we now?
• Public comments from December 2010 still
under review by FAR Acquisition Ethics and
International Law Team
• Team tasked September 1, 2011 with drafting
final rule by October 26, 2011
• Second extension of due date has been
issued: March 28, 2012
2
On The Regulatory Front – PCI:
• Another related area in the regulatory arena
has been personal conflicts of interest (PCI) for
contractor employees performing acquisition
functions
• FAR Case 2008-025, effective December 2,
2011, see 76 Fed. Reg. 68017-68026,
November 2, 2011
• http://edocket.access.gpo.gov/2011/pdf/2011
-27780.pdf
3
On the Regulatory Front – PCI:
• Some companies are merging OCI and PCI
policies (and awaiting new OCI final rules)
• May be appropriate for contractors providing
support services, but maybe not for systems
or supply contractors
• However, inclusion of both OCI and PCI
compliance processes in an OCI mitigation
plan may show an agency that the company
has both areas addressed and resolved!
On the Regulatory Front – PCI:
• Final rule makes contractors responsible for:
– Having procedures to screen for potential PCI
– Informing covered employees of their obligations
with regard to these policies
– Maintaining effective oversight to verify
compliance
– Reporting any PCI violations to the contracting
officer
– Taking appropriate disciplinary action with
employees who fail to comply with these policies
On the Regulatory Front – PCI:
• Affects contractor employees supporting an
“acquisition function closely associated with
inherently governmental functions” means providing
advice or recommendations with regard to:
– Planning acquisitions, evaluating proposals
– Developing SOWs, evaluation criteria
• See FAR 3.1101 for comprehensive listing of affected
efforts and FAR 52.203-16 for new mandatory clause
for acquisitions exceeding the simplified acquisition
threshold for services
On the Regulatory Front – PCI:
• PCI - a situation in which a covered employee
has a financial interest, personal activity or
relationship that could impair the ability to act
impartially and in the best interest of the
Government when performing under the
contract
• Contractors must prohibit covered employees
from using non-public information for
personal gain
On the Regulatory Front – PCI:
• Requires use of nondisclosure agreement
• Violations will require not just reporting of the
incident but also the proposed actions to be
taken (implying contracting officer input into
those proposed actions) and follow-up reports
of corrective actions
• If contracting officer determines matter not
resolved, must consult with agency legal
counsel and take “appropriate” action
On the Regulatory Front – PCI:
• PCI policies are yet another compliance issue
for contractors which will require:
– Workforce training
– Implementing clearly understood PCI policies
– Tracking of executed NDAs of covered employees
– Tracking of disciplinary actions to establish
proportionality and reasonableness of actions
taken (to persuade contracting officer)
GAO Decisions
• AdvanceMed Corporation; TrustSolutions, LLC B404910.4; B-404910.5; B-404910.6; B-404910.9; B404910.10 January 17, 2012.
Protest that the award was tainted by an impaired
objectivity OCI is denied where the record showed
that the agency reasonably concluded that the
potential areas of concern either did not constitute
significant conflicts that warranted disqualification of
the awardee, or were significant conflicts that were
adequately mitigated.
10
AdvancedMed Decision
• HHS acquisition for Medicaid/Medicare fraud
prevention support; best value award
• Corrective action taken on first protest which
alleged OCI concerns – awardee was wholly
owned subsidiary of BC/BS
• Plan for divestiture was sufficiently detailed to
satisfy GAO that agency acceptance was not
arbitrary (26 page GAO decision)
GAO Decisions
• TriCenturion, Inc.; SafeGuard Services, LLC B406032; B-406032.2; B-406032.3; B-406032.4
January 25, 2012.
Protest that the award was tainted by
organizational conflicts of interest was denied
where the record shows that the agency
reasonably concluded that the potential areas
of concern were adequately mitigated.
TriCenturion Decision
• Another HHS acquisition for similar services in
a different geographical region
• The protest was sustained on other grounds
involving the evaluation process
(recommended reading!)
• Complex and detailed divesture process
contingent on contract award was identical to
that set forth in AdvancedMed decision
GAO Decisions
• Raytheon Technical Services Company LLC B404655.4; B-404655.5; B-404655.6, October 11,
2011.
Protest that awardee had “unequal access to
information” type of organizational conflict of
interest is denied where allegations were based upon
suspicion and not “hard facts,” agency’s
investigation was meaningful, and agency reasonably
concluded that awardee did not have access to
nonpublic information that would provide firm a
competitive advantage in procurement.
Raytheon Decision
• Protest was sustained on other grounds (and a
prior protest resulted in corrective action)
• The Department of State contracting officer
conducted a post-protest investigation which
concluded that certain named individuals did
not have access to any current nonpublic
information
• Rare GAO support for post-protest agency
investigation
GAO Decisions
• Enterprise Information Services, Inc. B-405152; B405152.2; B-405152.3 September 2, 2011.
Protest that the awardee’s subcontractor had an
unmitigated “unequal access” OCI arising from its
contract with the procuring agency is denied where
the contracting officer investigated the matter and
determined that the subcontractor’s work under its
contract did not directly involve the subject matter
implicated by the protested procurement and NDAs
were used in any event.
Enterprise Decision
• Air Force contracting officer concluded that a
subcontractor of the awardee was working in
a separate support area and even if it may
have had access to protester’s labor
information, each employee executed an NDA
• GAO held that while the NDA was not
“company-to-company,” this error was not
sufficient to sustain this issue without more
facts
GAO Decisions
• PCCP Constructors, JV; Bechtel Infrastructure Corporation B405036; B-405036.2; B-405036.3; B-405036.4; B-405036.5; B405036.6 August 4, 2011.
An agency’s investigation of the awardee’s alleged unequal
access to information organizational conflict of interest was
unreasonable, where the agency concluded that the
awardee’s hiring of a high-level government employee from
the office responsible for the project being procured created a
potential conflict, but limited its review to what responsibility
and role the government employee had in the procurement
prior to his retirement without any consideration of the
employee’s access to non-public, source selection
information, and where the record establishes the
employee’s continued daily contact with members of the
source selection team and access to inside information
concerning the agency’s build-to-budget concept.
PCCP Decision
• Army Corps of Engineers acquisition; protest
sustained on several grounds
• Agency investigation overlooked some aspects
of Corps former employee’s access to source
selection information
• Testimony of other Corps employees showed
his access to SSI outside of the source
selection in management meetings
GAO Decisions
• Unisys Corporation B-403054.2 February 8,
2011.
Protest that awardee's use of a former
government employee in the preparation of
its proposal provided the firm with an unfair
competitive advantage due to the employee's
access to proprietary information of the
protester is denied where the record reflected
that the information at issue was not
competitively useful
Unisys Decision
• Prior protest alleging OCI resulted in
corrective action being taken – investigation
• DISA contracting officer investigation
concluded that former employee had only
limited (1/3 of total requirement) and
outdated labor rate information and no access
to evaluation plans
• GAO found OCI allegation too speculative
GAO Decisions
• QinetiQ North America, Inc. B-405008; B-405008.2
July 27, 2011.
Protest that awardee has “biased ground rules” type
organizational conflict of interest (OCI) is denied
where record does not establish that awardee’s
prior contract performance put awardee in position
to materially affect competition.
Allegation that awardee has “unequal access to
information” type OCI is denied where record
reflects that any advantage arising from awardee’s
prior contract performance was normally occurring
incumbent advantage.
QinetiQ Decision
• DoT acquisition for IT services
• Technical Evaluation Team chair testified that
neither awardee or any other contractor had
involvement in requirements definition based
upon prior contract effort
• Great reliance by the GAO on two-day hearing
process with testimony by contracting officer
and other Government personnel
GAO Decisions
• The Analysis Group, LLC B-401726.3 April 18, 2011.
Protest that agency failed to give adequate
consideration to awardee’s potential impaired
objectivity OCI is denied, where record shows that
agency extensively investigated potential OCIs and,
after completing its investigation and concluding that
there was a remote possibility of an OCI, properly
executed a waiver of the residual OCI
Analysis Group Decision
• Prior sustained protest on multiple grounds
resulted in corrective action and OCI
investigation by GSA and Air Force
• Awardee was involved in selling certain
technology which would be evaluated to some
degree under proposed new support contract
• Increased agency oversight was deemed
sufficient as mitigation
Some Industry Perspectives
• Management support of OCI avoidance/mitigation (and PCI as
appropriate) through educational awareness. Everyone in
contracts, business development, sales, engineering,
administration, etc. can benefit from OCI training (note especially new hires!).
• Make training attendance 'MANDATORY‘
• For those who are on travel or at remote locations, provide an
alternate date or also consider a web-based training process.
• Establish realistic deadlines for the OCI sweep process so
organizational POCs have time for an appropriate review and
allow time for comprehensive OCI mitigation plan preparation
Some Industry Perspectives
• OCI sweep process and internal OCI training
should be addressed in the OCI mitigation
plan to give the government agency assurance
of thoughtful, ingrained OCI compliance
• Success or failure of OCI training (and new PCI
training?) may mean the difference between
being able to sustain a defense to a protest
allegation or jeopardize a contract award!
ERS
• Turner v. United States
Litigation History
• GAO
• B.L. Harbert-Brasfield & Gorrie, JV, B402229, February 16, 2010, 2010 CPD 69.
• McCarthy/Hunt, JV, B-402229.2, February
16, 2010, 2010 CPD ¶ 68.
• Court of Federal Claims
• Turner Const. Co. v. U.S., 94 Fed. Cl.
561 (Fed. Cl. 2010)
• Court of Appeals for the
Federal Circuit
• Turner Const. Co. v. U.S., 645 F.3d 1377
(Fed. Cir. 2011)
Business Relationships in Turner
AECOM
PRELIMINARY DESIGN
CONTRACT
Turner Construction
Sub K
HSMM
FINAL DESIGN &
CONSTRUCTION CONTRACT
Joint Venture
Partner
Ellerbe Becket
30
Joint Venture
Partner
GAO Decisions

Ellerbe-Becket & AECOM interests aligned in August 08

Sustained “unequal access” OCI.
•
No mitigation plan.

Sustained “biased ground rules” OCI.
•
Prejudice presumed.

Denied “impaired objectivity.”
•
Record established lack of prejudice.

Footnote noted Agency’s authority to waive OCIs.
31
COFC Decision


Standard of Review:
•
Agency decision irrational if GAO decision irrational.
Findings:
•
•

Actual or potential OCI must be established by “hard facts.”
Contracting Officer’s duty is to evaluate OCIs “as early as possible”
…but the earliest time might be post award.
•
GAO should have considered post-protest representations when
looking for “hard facts.”
•
GAO finding of alignment of interests was cursory and not based on
“hard facts.”
•
GAO finding of “unequal access” and “biased ground rules” not
based on “hard facts.”
Remedy:
•
Agency ordered to “restore the Hospital contract to Turner”
32
Federal Circuit Decision

CAFC held:
•
Standard of review used by COFC was correct.
•
COFC did not conduct de novo review but gave proper
deference to the Contracting Officer’s judgment.
•
Post award investigation can remove “any OCI taint” if no
significant OCI found.
•
GAO should have assessed the reasonableness of the
investigation.
•
•
Affirmed application of “hard facts” requirement.
Challenge to COFC remedy could only be raised by the
Government.
33
Netstar-1 Gov’t Consulting, Inc.
• __ Fed. Cl. __, NO. 11-294C (Oct. 17, 2011)
• Allegation: awardee used its previous access to
agency data – including Protester’s labor
categories, job categories, and labor rates – to
improperly craft a winning proposal
• Deficient mitigation/corrective action
–
–
–
–
CO failed to enforce FAR mitigation procedures
Mitigation plan grossly inadequate
Plain error in CO investigation
Awardee’s “willful blindness” + CO’s “blithe
assumptions”
OCI is a Way to Become
Unpopular at Work
OCI
PIA
PGE
OCI is a Way to Become
Unpopular at Work
• ALLEGATIONS (case is not yet proved/decided)
• Lt Col M, USAF Dep. Chief, IT Division, AF Medical Support Agency
• Retires, hired by BAH 4 Apr 11 (Sr. Associate); orientation 4-8 Apr 11
• 11 Apr 11: First day of work, meets his 2 bosses & 2 coworkers
• BAH interested in IT Modernization Services (ITMS) Contract
• 12 Apr 12: Emails boss incumbent’s contract (CLIN pricing, labor
mix, labor rates by labor category)
•
•
• Boss’ Reaction: forwards email, promotes Mr. M to ITMS Capture Lead
BAH Pricing Department Reports Incident, BAH Self Reports
SAF Suspends BAH’s San Antonio Office, Proposes for Debarment
OCI is a Way to Become
Unpopular at Work
San Antonio, TX Office
OCI
PIA
PGE
OCI is a Way to Become
Unpopular at Work
Take Away:
OCI & Ethics Plans, Superficial Compliance with
Revolving Door Restrictions are Insufficient
Ensure New Employee is not an SSI Typhoid Mary!!!
OCI Mitigation at ESC
Electronic Systems Center
Office of the Staff Judge Advocate
Hanscom AFB, MA
ESC OCI Review Panel
• ESC/CC Policy Memo #08-005, 16 Jun 08
- Established ESC OCI Review Panel to ensure
ESC OCI policy is consistently applied throughout
the Center
- Chaired by Senior members of
Contracting (ESC/PK), the Legal Office (ESC/JA),
the Acquisition Center of Excellence (ESC/AE), and
the Chief of Contracting for Plans and Programs
(ESC/XPK)
OCI Mitigation
• OCI Firewalls (5 Factor Mitigation)
- Isolate Work in Separate Business Unit
- Geographic & Physical Separation
- Independent Management & Reporting
Chains
- Prohibition Against Transfer of Personnel
- Prohibition Against Transfer of Information
Common Elements of OCI Plan
• Non-Disclosure agreements
• Controlled access to sensitive information
• Establishment of an employee OCI
awareness/compliance program
• Physical separation of contract employees from
sensitive data
• Organizational separation
• Management separation
• Limitation on personnel transfers
43
OCI Mitigation at ESC
ESC OCI Review Process
• OCI Plan from prime contractor to
Contracting Officer (prime contractor
incorporates all subcontractor OCI plans)
• Contracting Officer to program team
• Those inputs go to Program Attorney
• Consolidated comments go to
ESC OCI Review Panel
OCI Mitigation
• Organization Charts (Prime & Subcontractors)
- One chart showing current organization and
reporting chain up through parent company
- Second chart showing new corporate structure
and reporting chain if restructure of Organization
is proposed as mitigation
- Organization chart needed for each member of your
team (Prime & Subcontractors)
OCI Mitigation Plans
• Administrative Section
-
Definitions
OCI Training for new and existing employees
Employee Transfer Rules
Information Transfer Rules
OCI Enforcement
• Employee OCI reporting requirements
• Consequences for OCI violations
• Disclosure of violations to Government
- OCI Certification
- Nondisclosure Agreement
OCI Mitigation Plans
• OCI Mitigation Section
- Separate Section for Prime and each Subcontractor
- Organization Chart
- Agree to Adopt Administrative Section
(or explain any deviations)
- Identify and Mitigate Potential OCIs
Identify & Mitigate Potential OCIs
• Identify All Divisions or Business Units
(Combine within by Systems / A&AS Contracts)
- Location
- Explain the Management and Reporting Chain
- Identify & Explain Contracts in the Division or
Business Unit with Potential OCIs
Identify & Mitigate Potential OCIs
• Identify the Potential OCIs
- Analyze work under specific contracts for actual
or potential conflicts of interest and conclude
whether a conflict of interest exists
Identify & Mitigate Potential OCIs
• Propose Mitigation Strategies
- Propose concrete solutions for mitigating any
conflicts of interest that have been identified
• Firewalls (5 Factor Mitigation Analysis)
• Restructure of organization and reporting chains
• Other steps the contractor will take to preclude
the perception that it will favor its own products
or services
OCI Summary
• OCI = Show Stopper
• Important to avoid, neutralize, and/or mitigate
OCIs before contract award
• Start early with discussion of OCI at industry
day
• See new ESC Policy 14 June 2008
55
OCI in the International Arena
OCI in the International Arena
Conceptual Basis of Understanding
International Law
– Common Misconceptions
• “Our” rules apply everywhere – in exactly the
same way as they do here
• No other country is sophisticated enough to have
similar rules to ours
– A Better Approach
• “Our” rules were developed to solve a problem.
Other nations have likely developed similar, but not
necessarily the same rules.
Sources of International Law
• Understanding international law requires
knowledge of the sources of the law, rules
• The “tier” concept
• Primary law - Generally treaties and overarching
laws
– WTO GPA, Free Trade Agreements, UN Conventions etc.
• Secondary law – Constitutions, Statutes
• Tertiary – Regulations, Directives
• Qaternary – Contract provisions, Advisory letters
Origins of OCI Rules
• OCI rules have developed out of a desire to keep procurement
fair, transparent and impartial.
• 3 basic types of OCI
– Biased Ground Rules Cases, where the primary concern is
that a government contractor could have an opportunity
to skew a competition in favor of itself. ie; “You prepared
the specs so you cant build the system” In Europe these
are sometimes called “Distortion” cases.
• This is the type most focused on outside of the USA.
– Unequal Access to Information Cases, where the primary concern is
that a government contractor has access to nonpublic information that
would give it an unfair competitive advantage in a competition for
another contract.
• This is an emerging concept in international law.
– Impaired Objectivity Cases, where the primary concern is that a government
contractor would be in a position of evaluating itself or a related entity (either
through an assessment of performance under a contract or an evaluation of proposals
in a competition), which would cast doubt on the contractor’s ability to render
impartial advice to the government.
WTO Agreement on Government
Procurement (GPA)
• The GPA is based on the principles of openness,
transparency and non-discrimination, which apply to
Parties' procurement covered by the Agreement
• OCI RULE - (GPA) - Article VI “4. Entities shall not
seek or accept, in a manner which would have the
effect of precluding competition, advice which may be
used in the preparation of specifications for a specific
procurement from a firm that may have a commercial
interest in the procurement.”
– Adopted by 15 Parties, 22 Observers, 4 international org observers
– http://www.wto.org/english/tratop_e/gproc_e/memobs_e.htm
The European Union OCI Laws
• Directive 2009/81/EC (Defense works)
• (49) Before launching a procedure for the award of
a contract, contracting authorities/entities may,
using a technical dialogue, seek or accept advice
which may be used in the preparation of
specifications, provided, however, that such advice
does not have the effect of precluding competition.
• Directive 2004/18/EC (Public Works general procurement) – Same provision
Fabricom
• “Fabricom” is the leading European case on OCI.
– Belgian law provided that firm involved in preparatory
work on a contract, such as by assisting in preparing
specifications (called the “technical dialogue”) may not
compete for awarded contract to provide the work
(“inflexible approach”).
– ECJ ruled that Belgian rule was too restrictive. Said
agency must give bidder chance to explain why there is
no bias “flexible approach”.
– The burden of proof of no distortion of competition is
generally on the bidder. Possibility of using firewalls as
part of argument.
NATO
• 3. 7. ORGANIZATIONAL CONFLICTS OF INTEREST
– An organizational conflict of interest may exist, in the realm of the private sector
providing services to NATO, where the same corporation may provide two types
of services to the Organization that have conflicting interest or appear
objectionable (i.e.: manufacturing parts and then participating on a evaluation
team comparing parts manufacturers).
– Organizational conflicts of interest implications are not limited to any particular
kind of procurement action. However, organizational conflicts of interest are
more likely to occur in contracts involving:
•
•
•
•
Management support services;
Consultant or other professional services;
Contractor performance or assistance in technical evaluations; or
Systems engineering and technical direction work performed by a contractor that
does not have overall contractual responsibility for development or production.
– An organizational conflict of interest may result when factors create an actual or
potential conflict of interest on an instant contract, or when the nature of the
work to be performed on the instant contract creates an actual or potential
conflict of interest on a future procurement. In the latter case, some restrictions
on future activities of the contractor may be required.
Canada
– Sources of Law: Treasury Board Manual, Financial
Administration Act and Government Contracts
Regulations; Department of Public Works and
Government Services Act, Defence Production Act,
Court Precedence.
• Common theme of ensuring open fair and honest
procurement.
– Department of Public Works and
Government Services Canada
http://www.tpsgc-pwgsc.gc.ca/appacq/dpa-ppd-eng.html
• Canadian national procurement agency
DPWG - Standard Acquisition Clause
17 Conflict of Interest - Unfair Advantage
– 1. In order to protect the integrity of the procurement process, bidders are advised that
Canada may reject a bid in the following circumstances:
– (a) if the Bidder, any of its subcontractors, any of their respective employees or former
employees was involved in any manner in the preparation of the bid solicitation;
– (b) if the Bidder, any of its subcontractors, any of their respective employees or former
employees had access to information related to the bid solicitation that was not available
to other bidders and that would, in Canada's opinion, give the Bidder an unfair
advantage.
– 2. The experience acquired by a bidder who is providing or has provided the goods and
services described in the bid solicitation (or similar goods or services) will not, in itself, be
considered by Canada as conferring an unfair advantage or creating a conflict of interest.
This bidder remains however subject to the criteria established above.
– 3. Where Canada intends to reject a bid under this section, the Contracting Authority
will inform the Bidder and provide the Bidder an opportunity to make representations
before making a final decision. Bidders who are in doubt about a particular situation
should contact the Contracting Authority before bid closing. By submitting a bid, the
Bidder represents that it does not consider itself to be in conflict of interest nor to have
an unfair advantage. The Bidder acknowledges that it is within Canada's sole discretion
to determine whether a conflict of interest or unfair advantage exists.
Mexico
• Article 50, Section VIII of Mexican Procurement
Law
• Government Agencies and entities may not
receive bids from, or award contracts to a person
or entity if:
– (a) That person or entity directly or indirectly
participated, pursuant to another contract, in preparing
the following documents for the current contracting
procedure
• (i) analytical and quality control works;
• (ii) specification drafting; or
• (iii) budgets preparation; AND
– (b) the bidder in question obtained privileged
information from the Prior Engagement; AND
– (c) the Government Agency or entity does not share such
privileged information with other bidders with respect to
the preparation of their proposals/bids.
Singapore
• Government Procurement Regulations (under the Govt Procurement Act) -
– Regulation 5(4) - A contracting authority shall not seek or accept, in a manner which will
have the effect of precluding competition, advice which may be used in preparing
technical specifications, from a person who has or who is likely to have a commercial
interest in the procurement in question.
– Regulation 5(5) - In this regulation — "technical specifications" means technical
requirements of a procurement and includes —
• (a) the quality, performance, safety requirements, dimensions, symbols, terminology,
packaging, marking and labeling of the goods or service to be procured;
• (b) the production processes or methods of the goods or service; and
• (c) any requirement relating to any conformity assessment procedures for the goods or
service;
– Regulation 9 - Prohibition against preclusion of competition
• A contracting authority shall not provide a supplier any information regarding a
particular procurement where such provision will or is likely to have the effect of
precluding competition.
Citations
•
•
WTO
– Agreement on Government Procurement
http://www.wto.org/english/docs_e/legal_e/gpr-94_e.pdf
EU
– Directive 2009/81/EC (Defense works)
– http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:216:0076:0136:en:PDF
•
NATO
– Staff Procurement Manual
http://www.nato.int/structur/procurement/doc/NATO%20IS%20Procurement%20Manual_
2_187.pdf
– http://www.nato.int/structur/procurement/gac.html
•
Canada
– http://www.canlii.org/en/index.php
•
Mexico
– https://compranet.funcionpublica.gob.mx/web/login.html En Espanol
Citations (continued)
•
•
•
Singapore
– Government Procurement Act
– http://statutes.agc.gov.sg/aol/search/display/view.w3p;page=0;query=CompId%3A2244a5cc2a39-48da-a0d7b127685744ce;rec=0;resUrl=http%3A%2F%2Fstatutes.agc.gov.sg%2Faol%2Fbrowse%2FtitleResults.
w3p%3Bletter%3DG%3Btype%3DactsAll
– http://www.singaporelaw.sg/
– http://statutes.agc.gov.sg/aol/home.w3p
Germany
– http://www.linguee.com/english-german/translation/commencement+of+procedure.html
Articles
– Arrowhead – EC Procurement law
http://www.nottingham.ac.uk/pprg/documentsarchive/fulltextarticles/pclj_evolution_arrowsmit
h.pdf
– The Draft OCI Rule - New Directions and the History of Fear
http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1832743
– CONFLICT AND INTRIGUE IN GOVERNMENT CONTRACTS: A GUIDE TO IDENTIFYING AND MITIGATING
ORGANIZATIONAL CONFLICTS OF INTEREST
http://www.sheppardmullin.com/assets/attachments/103.pdf
– Guide to Procurement Law http://www.legalink.ch/xms/files/Publications/Legalink-PublicProcurement-Law-3rd-edition-final.pdf
Conclusion
• Thank you for your participation today!
• Time for any questions for the panel members
(time permitting)?
• Also, talk with us later in the day as well!