Attachment 6 - OCI Mitigation Plan Checklist.pdf

ORGANIZATIONAL CONFLICT OF INTEREST MITIGATION PLAN CHECKLIST

Contractor: Solicitation/Contract Number:

The contractor shall enter the page and line numbers from their OCI Mitigation Plan corresponding to each requirement listed on this form and submit the completed form to the Contracting Officer (CO) along with each new and revised OCI Mitigation Plan. If subcontractor or other teammate OCI Mitigation Plan(s) is submitted, each Plan shall include a completed checklist. Mark items that are not applicable “N/A.”

1.0 General Considerations Page/Line

1.1 Clear statement of corporate commitment and sensitivity of OCI for this acquisition.

1.2 Parent organization chart (to include division, sector, subsidiary, affiliate, etc) is included in the Plan, if applicable.

1.3 List all contracts/task orders that contractor has (to include division, sector, subsidiary, affiliate, etc.) with DHA.

2.0 Management of OCI Mitigation Plan

2.1 Individual responsible for oversight and administration of the Plan is identified by name and place in company/business unit organizational structure.

2.2 Any corporate policies and procedures referenced in the instant Plan are in writing and attached to the Plan.

2.3 Processes and procedures to execute the Plan are clearly described in the Plan.

2.4 Process for advance notification to Government PCO of addition, deletion, or change to

Plan team members is described and complies with the contract.

2.5 Process for timely notification to Government PCO of OCI Plan violation or appearance of violation is described and complies with contract.

2.6 Document marking procedures are clearly described to control program/project reports and products, as well as sensitive information of the Government or other contractors.

2.7 Procedures are described for safeguarding program/project material and sensitive information of the Government or other contractors.

3.0 Management of Personnel

3.1 OCI training and awareness briefings of all personnel working on the program/project are identified in the Plan.

3.2 Plan describes frequency of training and awareness briefings (not less than annually).

3.3 Plan describes how training completion is documented and where maintained.

3.4 Plan describes requirements for program/project personnel to execute Non-Disclosure

Agreements (NDA) to protect proprietary and other sensitive information.

3.5 Plan describes process for determining personal conflicts of interest of individuals.

3.6 Plan describes requirements for debriefing personnel who executed NDAs upon transfer, reassignment, change of employers, or retirement.

3.7 NDA remains in effect from the date of signature until the end of each respective option period, then a new annual NDA is required.

4.0 OCI Mitigation Plan Reviews

4.1

Plan requires annual certification of compliance with the terms of the Plan, signed by a senior corporate official.