Sample OCI Program Training Slides

Report
[Program Name]
ORGANIZATIONAL
CONFLICT OF INTEREST
TRAINING
[Name]
[Position]
[Date]
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/xxxx
General stats about program, value, POP, etc
OCI 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 Separation
NDAs
 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 XX
Sign OCI Training Certification – Attachment XX
Sign OCI Exit Interview – Attachment XX
Protect all Program generated information per program directives
Disclose 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
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Program Mgmt:
HR:
Contracts:
Subcontracts:
Security:

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