Exhibit 1 - Vetting.pdf

EXHIBIT 1 – Vetting

Contractor Vetting Process

Contractor responsible for maintaining situational awareness of and planning in accordance with so as not to conflict with:

1. Michigan Army National Guard (MIARNG) priorities and initiatives at the installation

2. Legal and regulatory responsibilities of the installation commander

3. Installation commander’s operational duties and responsibilities

4. Installation priorities between all resident, tenant, and supported units

5. Installation operations support as dictated by DoD, HQDA, or in alignment with its priorities, and approved MIARNG standard and minimum capability levels

6. Authority of the installation’s Protection Threat Working Group (“PTWG’) and/or

Operational Security (“OPSEC”) Working Group’s oversight of installation sensitive information, training and exercises, and force protection pursuant to Army Regulations 525-1 and 530-1

Participation in extremist organizations and activities by installation personnel is inconsistent with the responsibilities of military service. It is thus the Contractor(s) responsibility to take appropriate actions to align its business operations, programs, and personnel, as well as the same for any and all Industry Users whose presence on the installation is authorized, with this objective.

Extremist organizations and activities are ones that advocate:

1. Racial, sex (including gender identity), sexual orientation, or ethnic hatred or intolerance

2. Creating or engaging in discrimination based on race, color, sex (including gender identity), national origin, religion, or sexual orientation

3. The use of force or violence or unlawful means to deprive individuals of their rights under the United States Constitution or the laws of the United States, or any State

4. Support for terrorist organizations or objectives

5. The use of unlawful violence or force to achieve goals that are political, religious, discriminatory, or ideological in nature

6. Expressing a duty to engage in violence against DoD or the United States in support of a terrorist or extremist cause

7. Support for persons or organizations that promote or threaten the unlawful use of force or violence or criminal activity

8. Encouraging military or civilian personnel to violate laws or disobey lawful orders or regulations for the purpose of disrupting military activities (subversion)

9. Participating in activities advocating or teaching the overthrow of the U.S.

Government by force or violence, or seeking to alter the form of government by unconstitutional means (sedition)

Individuals or groups may be denied access to the installation upon credible evidence of the following actions in support of extremist organizations or activities.

1. Participating in public demonstrations or rallies.

2. Attending a meeting or activity with the knowledge that the meeting or activity

a. involves an extremist cause

b. whether during work hours or personal time

c. whether in a foreign country

d. if it constitutes a breach of law and order

e. if it is likely to result in violence

f. if it is violation of off-limits sanctions, or

g. Fundraising activities

3. Recruiting or training members (including encouraging soldiers or civilians to join). Creating, organizing, or taking a visible leadership role in such an organization or activity.

4. Distributing literature on or off a military installation, the primary purpose and content of which concerns advocacy or support of extremist causes, organizations, or activities; and it appears that the literature presents a clear danger to the loyalty, discipline, or morale of military personnel or the distribution would materially interfere with the accomplishment of a military mission.

5. Receiving financial assistance from a person or organization who advocates terrorism, the unlawful use of force or violence to undermine or disrupt U.S.

military operations, engage in subversion, or commit sedition.

The State Program Manager has the authority to prohibit Contractor and/or Industry Users personnel from engaging in or participating in any other activities upon the installation that the State Program Manger determines will adversely affect readiness, good order and discipline, or morale within the command. This includes, but is not limited to, the authority to order the removal of symbols, flags, posters, or other displays from the installation, or to place off-post areas or activities off-limits.

State Program Manager Vetting Process

The following checklist includes key controls for obtaining permission to operate, maintaining proper documents for oversight and good standing, and taking prudent actions to avoid situations injurious to DoD, MIARNG, and installation interests. This checklist is not intended to cover all controls.

1. Does the Industry User operating on the installation have permission to do so from the Program Manager?

2. Do the Contractor and Program Manger maintain documents needed for oversight and necessary to attest that Industry User operations are in good standing?

3. Does the installation adhere to restriction on use of army personnel, military and civilian?

4. Are there instances that could be construed as soldiers or civilian personnel working for Industry Users, as part of their official duty?

5. Are instances of inappropriate or questionable Industry User activities or government employee behavior corrected when detected?

6. Does Industry Users use of installation real estate conform to MIARNG and installation directorate requirements?

7. When Industry Users are given logistical support for activities, is there a process for approving Industry Users support requests, including GJA reviews, to ensure compliance with DOD 5500.7–R?

8. Do Industry Users comply with audit and other oversight requirements such as installation PTWG and OPSEC requirements set forth in AR 525-2 and AR 530-1 and to which it is expressly subject?

9. Is there command and personnel compliance with rules governing Government employee participation in Industry Users activities?

10. Do local ethics classes for MIARNG personnel include discussions about proper relationships with Industry Users?

11. Are there periodic inspections of Industry Users documentation maintained by the Contractor and Program Manger to determine accuracy and compliance?

12. Are there periodic inspections to determine military and civilian personnel compliance with rules of ethics governing interactions with Industry Users?

13. Is there comprehensive enforcement of recommendations resulting from management control evaluations?