Hnba Master File (13 May 08) English

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Establish a variety of businesses in a secure area to provide services and products to the Coalition

Establish a variety of businesses in a secure area to provide services and products to the Coalition

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  • 1. Host Nation Business Advisor (HNBA) Brief Joint Contracting Command - Iraq HNBA Team
  • 2.
    • HNBA - Responsibilities
    • Where are We
    • Iraqi First Program
    • Contracting Basics
    • Sources for obtaining solicitations
    • Registration & Forms
    • The Solicitation
      • Regulations
      • Uniform Contract Format (UCF)
      • Forms SF1449 & SF1442
      • Solicitation Questions
      • Response Deadline
      • Amendments
      • Responsive and Responsible Proposals
      • Discussions After Submission of Proposal
      • Evaluation Criteria
      • Helpful Hints
    • Electronic Funds Transfer (EFT)
      • Payment Process Chart
      • Standard Steps for EFT Payment
      • EFT – Capable Iraqi Banks
      • EFT – Data Sheet & Benefits
      • Time Line
    • Defense Base Act (DBA) Insurance
      • Where/To Whom Does DBA Apply?
      • What does DBA do
      • Additional information
      • DBA Points of Contact
    • DD250
    • Quotations, Invoices & Delivery Documents
    • Business Ethics
    • Questions
  • 3. HNBA Responsibilities
    • Interface with local Iraqi Government leaders
    • Conduct monthly vendor training:
      • Contracting basics for vendors
      • Joint Contingency Contract System (JCCS) database registration and forms
      • Electronic Funds Transfer (EFT)
      • Defense Base Act (DBA) Insurance
      • DD Form 250
      • Quotations, Invoices & Delivery Documents
      • Business Ethics
    • Iraqi owned business verification
    • Translation
    • Regional Contracting Center (RCC)/HNBA command policy implementation
    • Support RCC Chief
    • HNBA’s have ABSOLUTELY NO CONTROL or INFLUENCE in selecting vendors for contract awards
  • 4. Kirkuk Baghdad Mosul Tallil Balad Kuwait City KUWAIT Al Kut Najaf/Kufah Sulaymaniyah An Nukhayb Nasiriyah Safwan Qurnah Al Amarah Samawah SYRIA Diyala Dahuk Karbala Bayji Tall Afar Ramadi Ar Rutbah Husaybah Al Asad Tanif N. Babil SAUDI ARABIA Samarra Irbil Umm Qasr Hadithah As Samawah IRAN JORDAN Diwaniyah Fallujah Taji Basrah Mr. Laith Mohammed HNBA RCC Mosul [email_address] DSN: 318-821-966 Cell: 07703983281 Mr. Jasim Al Sarraf HNBA RCC Balad [email_address] DSN: 318-433-2537 Cell: 07905252985 Mr. Ahsan J. Zaiyouna HNBA RCC Taji [email_address] DSN: 318-834-3878 Mr. Ali Al-Hathaf Senior HNBA JCC-I (IZ) [email_address] DSN: 318-852-1815 Cell: 07904283988 Mr. Adeeb Saleh RCC Tikrit [email_address] DSN: 845-6304 Cell: 0770 853 1600 Mr. Haider Hadi HNBA RCC Fallujah [email_address] DSN: 318-3405-380 Cell: 07902338671 MAJ Kerry Clements (Head of the Program) DSN: 318-239-8525 Commercial: 703-544-6504 Cell: 914-822-9114 [email_address] [email_address] Mr. Sam Kafil HNBA RCC Baghdad [email_address] DSN: 31-822-8189 Cell: 07904583741 Dr. Ali Al-Khaalidi HNBA MSD (IZ) [email_address] DSN: 318-852-1833 Cell: 07906641329 Dr. Imran Farid HNBA RCC Basrah [email_address] DSN: 318-858-1426 Cell: 07904283983 Mr. Hussain Hussain HNBA RCC Talill [email_address] DSN: 318-833-2028 Cell: 07803170147 Mr. Mohammad Ali HNBA RCC Echo [email_address] DSN: 302-242-0926 Cell: 07801052902 Mr. Ray Ishaq HNBA TWR (IZ) [email_address] VOIP: 703-544-1530 Cell: 07901907786 Mr. Abbas Khan HNBA RCC Victory [email_address] DSN: 318-822-4722 Cell: 07904402137 Mr. Zaid Al-Hassak HNBA RCC Kirkuk [email_address] DSN: 318-444-2857 Cell: 07706651122 Mr Mustafa Salman HNBA RCC Delta [email_address] DSN: 318-822-9924 Cell: 07805029548 Tikrit
  • 5. Iraqi First Program Joint Contracting Command - Iraq HNBA Team
  • 6. Iraqi First Program Purpose of the program: To promote and develop the capacity of the Iraqi economy thru greater utilization of Iraqi vendors in fulfilling coalition requirements Objective: Provide a dramatic transformation of procurement practices to maximize Iraqi awards
  • 7.
    • Assist Iraq to transition to a vibrant self-sustaining free market economy
    MNF-I / JCC I/A - Contracting Strategies Support for the Iraqi First Program started at the top with General Casey! MNFI Commanders Goal
    • Shift towards Direct Contracting
    • Consider positive impact on Iraqi economy
      • Iraqi ownership of firm
      • Iraqi participation in contract performance
      • Employment of Iraqi citizens
    • Use of Host Nation Business Advocates (HNBA)
    Contracting Officers will make every reasonable attempt to award to Iraqi Firms Iraqi First Program
  • 8. Iraqi First Economic Impact By Province (01 AUG 07 – 30 APR 08) It is my intent to leverage all of this command’s activities and resources, including contracting, to provide increased opportunities for economic expansion, entrepreneurship, and skills training for the people of Iraq. -David H. Patraeus, General, USA, Commanding Iraqi First Program Policy Memorandum, March 2007 RCC Taji Babil Salah Al-Din RCC Basrah Camp Bucca RCC Tallil RCC Echo RCC Mosul RCC Kirkuk RCC Tikrit RCC Fallujah RCC Balad RCC Taji RCC Victory RCC Baghdad TWR MSD Camp Delta $1,474,530,906 9,952 Grand Total $42,682,725 232 Wassit $32,239,474 590 Thi-Qar $27,712,042 11 Sulaymaniyah $300,594,817 3266 Salah Al Din $6,583,838 203 Qadissiya $37,453,323 408 Ninewa $1,646,751 9 Najaf $849,759 10 Muthanna $1,195,479 3 Missan $23,595,799 521 Tamim $3,219,185 8 Karbala $1,537,615 20 Erbil $21,059,849 124 Diyala $761,435 12 Dahuk $142,085,951 296 Basrah $607,811,045 3433 Baghdad $18,981,246 280 Babil $191,810,425 473 Anbar Award Amount Contract Actions Province
  • 9. Contracting Basics Joint Contracting Command - Iraq HNBA Team
  • 10. There are several sources for obtaining tenders from the US Government Sources on the Internet
    • Rebuilding Iraq
    • Federal Business Opportunities
  • 11. Joint Contingency Contracting System (JCCS)
  • 12. Help and Training Web Site: JCCS Visit Select Help and Training any time if you have a problem
  • 13. Register Your Company Web Site: JCCS Visit Register your company OR LOGON (if you’re registered)
  • 14. Register Your Company Select “Next” to continue with registering your company Web Site: JCCS
  • 15. Register Your Company Fill the required information for the Company Select Save to Save information n Web Site: JCCS Please fill out each box completely
  • 16. Do the Services & Identification Codes Choose the type of services you want to provide Fill out the details of the Jinsia, planning & trade ministry then press Save Web Site: JCCS
  • 17. Press on Search and a window will pop up offering more choices to be saved, then other choices can be selected and saved Do Classification Codes Web Site: JCCS
  • 18. After you choose the first option you must Save it Do Classification Codes You can choose several specialty fields, more pages are available offering various fields Web Site: JCCS
  • 19. Register Your Company Fill the required information for POC Select Save to Save information n Web Site: JCCS
  • 20. Search for Solicitations Search for Solicitation Web Site: JCCS
  • 21. Press the Search with no option selected will list all available Solicitations on the System Web Site: JCCS Search for Solicitations
  • 22. Search Solicitations by: Title or Number Web Site: JCCS Search for Solicitations
  • 23. Web Site: JCCS Search for Solicitations Search Solicitations by: Classification Code or Province
  • 24. Search Solicitations by Sector/RCC Web Site: JCCS Search for Solicitations Search Solicitations by Close Date
  • 25. Search for Open Solicitations in Baghdad Search for Solicitations Number of pages Click on the Solicitation to select it Web Site: JCCS Specify the range for Closing Dates
  • 26. Information about Province, Close and Award date Search for Solicitations Information about the Solicitation Web Site: JCCS
  • 27. Registration & Forms
  • 28. After the registration of the vendor in the web site ( ) we need the following document to approve vendors application As defined by Major General Scott memorandum regarding the Iraqi-Owned Business definition Registration & Forms 1 – Registration With Ministry of Trade
  • 29. Registration & Forms 2 – First Co-Operation Meetings Papers
  • 30. Registration & Forms 3 – New Iraq Jenssya or the Passport copy
  • 31. Registration & Forms 4 – Application form we send to you.
  • 32. Solicitations (The Solicitations is not a contract)
  • 33.
      • Federal Acquisition Regulations (FAR)
      • Defense Federal Acquisition Regulation Supplement (DFARS)
      • Army Federal Acquisition Regulation Supplement (AFARS)
    Regulations The Joint Contracting Command – Iraq/Afghanistan (JCC-I/A) uses the following regulations. All clauses referenced within the solicitation or resulting contract are taken from one of these regulations Note: Please use these web links as a tool to familiarize yourself with the Governments regulations Solicitations
  • 34.
    • Business Relationships
    • Contracting Officer (the person who signs the award document)
      • Provides direction for work to be performed.
      • Contact him during the Solicitation (awarding) time.
      • May direct changes to the scope of work in the contract. It is recommended that the contractor first obtain a modification to the contract
    • Contracting Officer’s Representative (COR)
      • Provides direction for work to be performed.
      • Contact him during the after the Solicitation (awarding) time.
      • May not direct changes outside the scope of work in the contract
    • Have the approval of the Contracting Officer’s before carry any work outside the scope of the SOW.
    • Performance
    • Compliance with Statement of Work (SOW)
    • Successful or unsuccessful performance is evaluated for future contract awards
    Always communicate in writing! Solicitations
  • 35. Vendor searches for solicitations on JCCS website Vendor submits quote to KO (can post or e-mail) KO receives quote from vendor (can post or e-mail) KO has verify top 3 quotes KO awards contract Solicitation Process - Solves the vendor rotation issue - Increases competition - Removes bias from the selection of competition - Meets the CG's intent 1 2 3 4 5 6 KO posts a solicitation on JCCS website HNBA verify Business Legitimate 7
  • 36. Uniform Contract Format (UCF) The contract provisions in Parts I, II, and III of the Uniform Contract Format (UCF) will constitute a complete contract except for the prices or costs and fee in Part B. The offeror must fill out Part B when the offer is submitted. Solicitations for basic contracts, as well as solicitations on existing contracts must be in the following order: Once a contract has been awarded, sections A-K of the solicitation will become a part of the basic contract, while sections L & M will not be part of the resulting contract, but will remain in the pre-award documentation For more information on the UCF, visit: (L) Provides instructions to contractors on how to submit their proposal (M) Identifies how the contractor’s proposal will be evaluated Solicitations Part IV – Representations and Instructions K - Representations and Certifications, and Other Statements of Offerors L - Instructions, Conditions, and Notice to Offerors M - Evaluation Factors for Award Part III - List of Documents, Exhibits, and Other Attachments J - List of Attachments Part II - Contract Clauses I - Contract Clauses Part I – The Schedule A - Solicitation / Contract Form B - Products or Services and Prices / Costs C - Description / Specifications / Statement of Work D - Packaging and Marking E - Inspection and Acceptance F - Deliveries or Performance G - Contract Administration Data H - Special Contract Requirements
  • 37. Solicitation/Contracts/ Order for Commercial/Supplies Items -- SF 1449 Please Complete Blocks 12,17,23,24,& 30 Discount Terms (Government discounts your total amount by a certain percentage if paid within the specified time that you indicate here). * 17a. Contractor/Offeror (Your Name, Company Information, e-mail & Telephone Number, { if you are a Iraqi based business then you don’t need a Code & Facility Code}) * 17b. Check if address is different * 23. What is the Unit Price * 24. Amount (total amount) * 30a. Signature of Offeror/Contractor * 30b. Name and Title (Position in Company) of Signer ( individual responsible) * 30c. Dated Signed (must be filled in) Solicitations
  • 38. Solicitation/Contracts/ Order for Commercial/Supplies Items – SF 1449 (continued) Blocks 23 & 24 Continue Government Use Only (Do not enter anything in this section) Solicitations
  • 39. Solicitation, Offer, and Award -- SF 1442 Complete Blocks 14-20 (Please see next slide) * 14. Print; Name, Company Address and e-mail of your company * 15. Telephone NO (Include area code) * 16 Remittance Address (Where to send payment) -- Include only if different than Item 14 * 17. Indicate the number of calendar days that the total Price will remain in effect * 18. This is not required, please leave blank * 19 Acknowledgment of Amendments – During the bidding process amendments (RFP Changes) are sometimes executed. If so, please note amendment number and date for each change C heck the web-site daily in order to acknowledge any changes to the RFP. * 20a. Name and title of person authorized to sign offer (Type or Print) *20b. Signature *20c. Offer Date Solicitations
  • 40. Solicitation, Offer, and Award SF 1442 Construction, Alteration, or Repair Government Use Only (Do not enter anything in 1-13) Solicitations
  • 41. SF 1449 Solicitations
  • 42.
    • Section B - Products or Services and Prices / Costs
    • Identifies the products or services required
    • Ensure you understand the description of the requirement
    • References are often made to the Statement of Work (SOW) or Performance Work Statement (PWS). Read these
    • Use two decimal places for dollar values
    • All proposals are to be submitted in US Dollars
    • Verify all calculations
    • Do not round values in the ‘Amount’ column
  • 43.
    • Section C - Description / Specifications / Statement of Work
    • Statement of Work (SOW)
      • FAR 8.405-2(b) All Statements of Work shall include the work to be performed; location of work; period of performance; deliverable schedule; applicable performance standards; and any special requirements (e.g., security clearances, travel, special knowledge). To the maximum extent practicable, agency requirements shall be performance-based statements (see Subpart 37.6)
    • Performance Work Statement (PWS)
      • Describe the work in terms of the required results rather than either “how” the work is to be accomplished or the number of hours to be provided (see 11.002(a)(2) and 11.101)
      • Enable assessment of work performance against measurable performance standards
      • Rely on the use of measurable performance standards and financial incentives in a competitive environment to encourage competitors to develop and institute innovative and cost-effective methods of performing the work
    • The SOW covers the work requirements and in conjunction with applicable performance/design requirements contained in specifications is used for contractual agreements
    • Thoroughly read Section C of the solicitation
  • 44.
    • Section D - Packaging and Marking
    • Identifies special packaging and marking requirements for delivery of products
    • Section E - Inspection and Acceptance
    • Identifies inspection criteria for products being delivered or services being performed
    • Identifies whether a Quality Assurance Plan is required
    • Section F - Deliveries or Performance
    • Identifies the period of performance, place of performance, and location for deliveries.
    • Delivery on time is very important for us; the speed in delivery we like and the late delivery we don’t.
    • Section G - Contract Administration Data
    • Points of contact for the contract.
    • Payment office and Invoicing instructions
    • Section H - Special Contract Requirements
    • Special provisions required in the contract
    • It is very important to read and understand these requirements
  • 45.
    • Section I - Contract Clauses
    • This section includes the clauses required by the federal and agency regulations mentioned earlier
    • Clauses are incorporated
            • in full text – the entire clause in included in the solicitation
            • by reference – only the clause number and title are included in the solicitation
          • It is the responsibility of the contractor to understand all clauses in the solicitation, whether it is in full text or by reference. Ask for clarification from the Contracting officer if there is something you don’t understand.
  • 46.
    • Section J - List of Attachments
    • Lists all attachments included in the solicitation
    • Section K - Representations and Certifications, and Other Statements of Offertory
    • The contractor is required to complete this section and submit with their proposal
    • The contractor is providing representations and certifications about their company.
      • Have they been debarred
      • Company size
      • etc.
    • Section L - Instructions, Conditions, and Notice to Offerors
    • Provides instructions to contractors on how to submit their proposal.
    • It is important for all contractors to read this section.
    • Make sure you understand this section very well and read it more than once.
    • Section M - Evaluation Factors for Award
    • Identifies how the contractor’s proposal will be evaluated
  • 47.
    • Solicitation Questions
    • Section L of the solicitation will normally provide a deadline for submitting questions. The responses will be provided in an amendment to the solicitation
    • What should you ask
    • Do you understand the requirement
    • Does something not make sense
    • Do you feel something is missing from the requirement
    • If you do not understand, ask the question to the Contracting Officer.
  • 48.
    • Response Deadline
    • The response deadline is identified in block #8 of the SF 1449 and block #13a of the SF 1442
    • Section L of the RFP may also indicate the response deadline
    • Section L will indicate where to submit your proposal
    • Submit your proposal on time. Do not be late.
    • The electronic copy (through email) needs to be submit to the Contracting Office 24 Hours before the Deadline; the hardcopy needed to be with us on the deadline.
    • Amendments
    • Be aware of amendments to the solicitation. Amendments may
    • Change the response deadline
    • Change other provisions within the solicitation
    • Check each of the sources from which you obtained the solicitation to ensure an amendment has not been issued.
    • ** Even if it’s the day before the solicitation is due, check it out
  • 49. Electronic Fund Transfer (EFT) (JCC-I Support Banking in Iraq)
  • 50. Electronic Fund Transfer (EFT) Electronic Fund Transfer (EFT)- Capable Iraqi Banks Choose the Bank which suit your business (and your needs) (964) 1 717-4182 Warka Bank (+964 -1) 5433561/2/3 Trade Bank of Iraq Baghdad /Babil area/ Arasat Alhindia Iraqi Middle East Investment Bank (+964) 1 7180996 Investment Bank of Iraq +964 66 2227557 Emerald Bank [email_address] Baghdad / Tunis street / Distict 101 St. No. 23 / Building No.39/1 Dar As-Salaam Investment Bank 964-1-7196020 Credit Bank of Iraq Baghdad / Al-wehda area / Kawla Bint Al-azwar Street Commercial Bank of Iraq Street 6, near sports stadium, Erbil 964.750.478.440 Byblos Bank Baghdad / Karada Kharge / District 902 (964) 1 717-4182 Bank of Baghdad Web Site / email HQ Phone Bank Name
  • 51. Electronic Funds Transfer (EFT)
    • Contract is awarded indicates the paying office.
    • The Contract is sent to the Paying office by the contracting office.
    • Vendor agrees and performs the work.
    • The vendor sends an invoice to the paying office.
    • The customer provides a DD250 to the paying office.
    • The payment must be made NLT 30 days after the date on the invoice or the date of the DD250 which ever is later.
    • The Commercial Vendor Services section prepares the payment. If it is an Wire Transfer payment the voucher is sent to the main disbursing office.
    • The payment is accepted into the disbursing system.
    • The payment is processed through ITS (International Treasury Service) manually. This is manual because our Disbursing System does not accept SWIFT codes (essentially routing numbers) for the international banks.
    • The payments are released in ITS in a batch file. We get acknowledgement back if it processes or rejects. We work the rejects as required.
    • The payment typically takes 42 days once it is in the system and depending on the weekends/holidays covered.
    Standard Steps for EFT Payment
  • 52. Defense Base Act (DBA) Insurance
  • 53. Where/To Whom Does DBA Apply?
    • Enacted in 1941 to provide a consistent level of coverage to civilian employees of private companies doing work on US military installations or US Gov’t. projects outside of the USA including:
      • military, air or naval bases outside of USA
      • lands in territories, possessions outside of USA used for military or naval purposes
      • US Gov’t. contract for public work outside the continental United States (direct or indirect)
      • Mutual Security Act of 1954 - outside continental USA
      • American employers providing services funded by US Gov’t for benefit or Armed Forces
      • Contracts with US Gov’t. or Gov’t. agency governed by Federal Acquisition Regulation (FAR)
  • 54. What Does DBA Do?
    • Modifies workers compensation benefits due to injured employees to levels dictated by the US Longshore & Harbor (USL&H) Workers Act:
      • supercedes any other statutory workers compensation law
      • benefit level higher than most state schemes
      • extends coverage to all employees regardless of nationality
      • holds prime/letting contractor responsible for provision of DBA benefits to its employees as well as employees of all subcontractors
      • coverage interpretation over time has extended scope of coverage beyond “in the course of employment” (not 24 hour)
      • provides the employer with means for “exclusive remedy” in the event of injury or death to an employee
  • 55. DBA Points of Contact
    • ACE Insurance
      • Giles Ward
      • 304 Government Ave.
      • Manama, Bahrain EC3A3BP
    • Email: [email_address]
    • Phone: 973 (17) 211845 ext. 101
    • CNA Insurance
      • Meng C. Fan Underwriting Manager CNA International 40 Wall Street, 9th Floor New York, NY 10005
    • E-Mail: [email_address]
    • PH: 212-440-7207 FX: 312-894-2608
    • AIG Insurance
      • Osama Abdeen B.A (LAW), A.C.I.I
      • Executive Vice President - Middle East Region
    • AIG American International Group Floor 11, Dubai International Financial Centre, The Gate Building, West Wing DUBAI, UNITED ARAB EMIRATES
    • E Mail: [email_address]
      • Tel.No. +971 (4) 214-3452
      • Mobile: +971 (50) 659-1396
      • Fax No: +971 (4) 266-8319
  • 56. DD250 (Ask for signed copy from the Contracting Officer or his Representative)
  • 57. Instructions for Completing the DD Form 250 Block 1 13 digit contract number, and four digit call/order number, where applicable Block 2 Shipment number. Example: ABC0001 or ABC0001Z Block 3 Actual or estimated shipment date Block 4 Government or commercial bill of lading transportation control number Block 5 Discount terms in percentages and days allowed Block 6 Invoice number and actual or estimated date of submission Block 7 Consecutive page numbers Block 8 Enter “S” for source acceptance point or “D” for destination acceptance point Block 9 Contractor name, address and CAGE code Block 10 Contract Administration Office address and DoD Activity Address Directory (DoDAAC) code number Block 11 Address, FOB and code of “Shipped from” location Block 12 Payment office name, address and code as stated in contract Block 13 “Shipped to” address and code from contract Block 14 “Marked for” address and code from contract Block 15 CLIN, SUBCLIN, and ELIN item number as cited in contract Block 16 Item name, stock and/or part number and description Block 17 Quantity Shipped Block 18 Abbreviated unit of measure Block 19 Unit Price Block 20 Extended amount Block 21 To be completed by Quality Assurance Representative Block 22 To be completed by receiving activity Block 23 Contractor use only DD250
  • 58. Quotations, Invoices & Delivery Documents (Please check where to send these before sending them)
  • 59. Quotation
  • 60. Invoice
  • 61. Delivery Document
  • 62. Business Ethics Joint Contracting Command - Iraq HNBA Team
  • 63. Business Ethics
    • Who is Responsible:
      • All Vendors are responsible to become familiar with, follow and promote compliance with this Business Ethics Code
    • Guidelines:
      • These Guidelines are intended to assist you in understanding the ethical standards to which you must adhere in conducting business with the Government.
      • Avoid putting Government employees in conflicts of interest: Gifts, job offers, or arrangements giving Government employees financial incentives or interests in a private sector contractor are almost always improper.
      • Remember that: paying foreign officials to influence their decisions regarding contracts is illegal under U.S. law, even if such payments are an acceptable practice in the foreign country
      • Keep in mind : you may freely hire Government employees, but those employees may be subject to disqualification and reporting requirements if you contact them regarding nonfederal employment. In addition, Government employees face some restrictions on their activities after leaving Government service. Former Government employees may not “switch sides” to represent you before the Government in matters in which they had some level of personal or official involvement while Government employees.
  • 64. Business Ethics
      • Be aware: Government employees may not reveal source selection information or proprietary or confidential information of other contractors. Government employees must be scrupulous to avoid giving an unfair competitive advantage to one contractor over another.
      • Recognize that: Government officials must identify and attempt to mitigate potential organizational conflicts of interest. This means you generally cannot prepare work descriptions and then compete for the work because you would have an unfair competitive advantage.
      • Understand that: you may use consultants, agents, and representatives, but you must ensure that their activities are within legal bounds all the time. Otherwise, their activities may lead to sever consequences for you.
      • Bear in mind: that paying or receiving any kickback is illegal. Kickbacks improperly inflate the costs of Government contracts, and you must promptly report any suspected kickback violations to the Government in writing.
    (Please ask the Contracting Office if you have a questions or concerns about the Business Ethics)
  • 65.
    • Questions ?