Tab_2_-_Description_of_Services.pdf

Proposal Submitted to:

Arizona Department of Corrections

Request for:

750 Minimum and Low Custody Contract Beds Solicitation Number BPM004542 August 03, 2022

Jennifer Houston 4955 Technology Way Boca Raton, Florida 33431 Tel: 866.301.4436/561.893.0101 jhouston@geogroup.com

R

TAB 2

Florence West Correctional & Rehabilitation Facility

Description of Services

Title Page Table of Contents Scope of Work

1. Introduction

2. Definitions

3. Licensing and Additional Requirements

a. State of Arizona License

- Security Agency License

- Authorization to Transact Business

- Certificate of Good Standing

4. Investigations

5. Contract Monitoring Activities

6. Performance and Monetary Offsets

7. Contractor’s/Subcontractor’s Qualifications

a. GEO History & Experience

b. Certificate of Good Standing & Authorization to Transact Business

c. Leadership Resumes

d. Population Classification Chart

e. Facility Administrator Resume

f. Security Agency License

g. Client Reference Sheets

h. Deficiencies & Monetary Offset

i. Pending Litigation

Occurrence Charts - Provided in Tab 10

TAB 2

Description of Services

Proposal Submitted to:

Arizona Department of Corrections

Request for:

750 Minimum and Low Custody Contract Beds Solicitation Number: BPM004542 August 03, 2022

TAB 2

8. Facility Management

a. Facility Organizational Chart

b. Florence West Emergency Operations & Response Plan

c. PREA Coordinated Response Plan

d. Building Schedule

e. Religious Services Calendar

f. Policy 11.2.3 Sample Emergency Response Plan

g. Policy 11.2.2 Mutual Aid Agreements

h. Policy 1.1.14 Anti-Retaliation

i. Policy 11.2.13 Transportation Policy

j. Florence West Escape Annex

9. Financial

a. Audited Financial Statements

b. Pro-Forma Statements

Attachment 9 - Provided in Tab 5 Attachment 10 - Provided in Tab 6

10. Staf fing

a. Staff Deployment Chart

b. Current vs. Proposed Staffing Analysis

c. Florence West Staffing Plan

Job Descriptions - Provided in Tab 12

Proposal Submitted to:

Arizona Department of Corrections

Request for:

750 Minimum and Low Custody Contract Beds

TAB 2

11. Correctional Services

a. Building Schedule

b. Policy 11.2.8 Key and Lock Control

c. Policy 11.2.3 Sample Emergency Response Plan

d. Florence West Emergency Operations & Response Plan

e. PREA Coordinated Response Plan

f. Policy 11.2.2 Mutual Aid Agreements

g. PREA Audit Tool h.Religious Services Calendar

i. Chaplain Resume

j. Emergency Medical Response Policy

12. Medical Services

13. Physical Plant/Structure Design

a. Maintenance Plan

14. Invoicing/Payments

15. Reports

Special Instructions to Offerors Special Terms and Conditions

Proposal Submitted to:

Arizona Department of Corrections

Request for:

750 Minimum and Low Custody Contract Beds

1. Introduction

August 3, 2022 750 Minimum and Low Custody Contract Beds – Solicitation BPM004542

Tab 2 – Section 1: Introduction page 1 of 7

Tab 2. Description of Services

1. Introduction

GEO Secure Services LLC, a wholly owned subsidiary of The GEO Group, Inc.

(collectively referred to as GEO) has read, understands, and will comply with the requirements of Section 1: Introduction and all subsections contained therein.

GEO’s Corporate and Regional Resources GEO is a Florida-based company with its Corporate Office located in Boca Raton, FL, and has a staff of approximately 442 employees. Our corporate and regional staff includes experts in prison design, finance, human resources, contract compliance, construction, administration, security, health services, education, vocational training, counseling, substance abuse treatment, food service, maintenance, procurement, and professional accreditation.

Corporate Correctional Management Team The GEO Secure Services Business Unit is led by GEO Senior Vice President and President of GEO Secure Services, James Black, with more than 37 years of correctional experience. He is supported at the Corporate Office by nearly three dozen subject matter experts in corrections, administration, security, food services, and training. On a daily basis, they oversee the three U.S. Regional Offices and operations in the United Kingdom, Australia, and South Africa. GEO Secure Services oversees the management and operation of approximately 74,000 beds in 57 correctional and detention facilities around the world.

This department currently provides services on behalf of the Federal Bureau of Prisons, U.S. Marshals Service, and U.S. Immigration and Customs Enforcement, as well as seven state correctional clients and various county and city jurisdictions around the country.

GEO’s proposal includes the continued service of current Florence West Facility Administrator, Ronald Credio, who began his career with ADCRR in 1994 as a Correctional Officer. Mr. Credio was continuously promoted to positions of increasing responsibility with ADCRR and brought his expertise to GEO in 2020.

GEO Regional Office Oversight The three GEO Regional Offices provide facility oversight and support, ensuring immediate and direct assistance to the facility management teams. The GEO Western Regional Office, located in Los Angeles, CA, has nearly 20 staff who are responsible for daily operational oversight of Florence West. It is staffed with subject matter experts in security, health services, physical plant maintenance, risk management, contract compliance, business management, and information systems. The Western Regional Office is led by Regional Vice President Paul Laird, with 35 years of correctional experience.

Tab 2 – Section 1: Introduction page 2 of 7

Contract Administration The GEO Contract Administration department is located in the Boca Raton, FL Corporate Offices. It is led by Executive Vice President Amber Martin with over 30 years of experience in corrections, contract administration and compliance, and legal administration. She is supported by 13 subject matter experts in contract management, policy development, client correspondence, contract finance, equitable adjustments, contract analysis, and negotiations. This department ensures that all GEO’s operations are conducted in accordance with contract provisions, applicable court orders, and in compliance with national standards.

Correctional Health Care The GEO Health Services department is led by Executive Vice President Lisa Krueger with 20 years of experience in health care administration and operations, and Chief Medical Officer Dr. John Christakis, with 40 years of experience in clinical medicine. They are supported in the Corporate Office by 16 subject matter experts in correctional health care, administration, dental services, mental health services, quality control, utilization management, and off-site health care claims management, as well as clinical care support.

On a continuous basis, the Corporate Health Services department supports and monitors staff vacancies, clinical outcomes, special incidents, clinical encounters, outside patient care, medication management, and updates clinical guidelines.

Contract Compliance GEO has dedicated considerable resources to the development of an independent Contract Compliance (CC) department responsible for monitoring and validating operations at each of our facilities to meet the needs of the client. The CC department is an independent corporate department headed by Executive Vice President (EVP) Daniel Ragsdale with over 20 years of legal and law enforcement experience. The EVP reports directly to the Chief Executive Officer of GEO. There are over 70 experienced employees in CC, including a Vice President (VP), several Directors, and more than two dozen Managers.

All Directors and Managers are overseen by the VP and the EVP of CC.

Acknowledging the importance of full medical compliance reviews by medically licensed professionals, GEO employs a team of six medical compliance specialists: two Medical Doctors with over 50 years of combined operational experience, three Registered Nurses with a range of operational and compliance experience in health care delivery, and one Licensed Practical Nurse specializing in NCCHC accreditation. This ensures thorough, independent, and effective medical reviews. A Senior Director is responsible for the ACA accreditation process and PREA initiative for all applicable facilities. In GEO’s Western Regional Office, a Director of Contract Compliance and two Managers provide regional compliance oversight, periodically visiting each facility, and participating in Annual Corporate and Follow-Up Audits, and during accreditation preparations.

Tab 2 – Section 1: Introduction page 3 of 7

Risk Management The Department of Risk Management reports to GEO’s Chief Financial Officer, and provides support to the entire organization in identifying, controlling, and mitigating financing and insuring the organization’s risks. The department is led by a Vice President of Risk who holds several Risk Management Certifications and has over 25 years of experience in safety and risk management. The department is supported by a Director of Safety, Director of Claims, three Regional Safety Managers, three support staff members and oversight of approximately 42 facility-based Fire & Safety Managers.

Physical Plant and Design Oversight The GEO Design and Construction department is located in the Boca Raton, FL Corporate Offices. It is led by Senior Vice President Richard “Kent” Long with over 30 years of development and life-cycle management experience. He is supported by one dozen subject matter experts in facility design, project management, maintenance and repair, and physical plant support. They have been responsible for the life cycle maintenance of 141 GEO-managed facilities, comprising 17.7 million square feet, and valued at over $5 billion.

Human Resources The GEO Human Resources department is led by Executive Vice President Chris Ryan with over 30 years of human resources experience. He is supported by 65 subject matter experts in recruitment, compensation and benefits management, HR information systems and reporting, employee onboarding including orientation and training, and labor relations.

GEO Care The GEO Care Business Unit is led by GEO Senior Vice President & President of GEO Care, Dr. Ann Schlarb. GEO Care is the world’s largest service provider of in-prison rehabilitation, community reentry, and electronic monitoring services. The in-prison rehabilitation services are overseen and delivered through the GEO Continuum of Care department which includes approximately 31 staff with subject matter experts in education, cognitive behavioral treatment, and substance abuse treatment. This department is led by Executive Vice President Dr. Derrick Schofield and provides enhanced in-prison rehabilitation programs including evidence-based treatment, integrated with post-release support services through the “GEO Continuum of Care” in the U.S. and Australia.

Management of Existing Facility GEO assumed operations of the Florence West Correctional and Rehabilitation Facility (Florence West) after our acquisition of Correctional Services Corporation (CSC) in November 2005. For more than 16 years, GEO has worked in close partnership with the Arizona Department of Corrections, Rehabilitation and Reentry (ADCRR), providing not just housing and care for inmates, but also a wide variety of life skills and self-improvement programs designed to support successful community reintegration for an inmate’s post-release. Partnership with GEO provides ADCRR inmates with access to GEO’s award-

Tab 2 – Section 1: Introduction page 4 of 7 winning Continuum of Care services, which are unmatched by any other organization in our industry.

GEO works to be a good corporate citizen in the communities where we operate. In the last year, Florence West staff have provided volunteer hours, donations, and support to the Pinal County Humane Society, the Oasis Nursing Home, and the local food bank. Florence West has also granted scholarship funds to students in the Pinal County School District. In 2020, the inmates of the facility organized a fundraiser and donated more than $2,000 to the Breast Cancer Foundation. Other fundraisers have benefited the Special Olympics, the Christian Counseling and Education Foundation (CCEF), and Hope Women’s Shelter.

GEO looks forward to continuing and building upon our existing partnership, with programs and services strategically aligned to further ADCRR’s goal of improving inmate outcomes using evidence-based practices.

Submission Requirements and Format GEO’s Proposal is arranged in accordance with the submission requirements provided in Special Instructions to Offerors.

Qualifications to Provide Services GEO’s operations include the management and/or ownership of approximately 104 secure facilities, processing centers, and community reentry centers encompassing approximately 84,000 beds, including idle beds in inventory and projects under development in the United States, Australia, South Africa, and the United Kingdom. GEO understands the importance of providing an environment that is safe, secure, and humane for those in the custody of our care and the safety of the staff and public. Under a new contract, GEO will ensure the safe and secure operation of the Florence West facility, ensuring that all security and operational requirements are fulfilled as a means to eliminate the potential for unfavorable occurrences. GEO will comply with the requirements in accordance with Arizona Revised Statutes (A.R.S.) §41-1609, §41-1609.01, §41-1609.02, §41-1609.03, and §41-1609.04.

Our corporate staff includes experts in secure facility design, finance, contract compliance, construction, administration, security, health services, education, vocational training, counseling, substance abuse treatment, food service, maintenance, procurement, and professional accreditation.

Fifty-three of GEO’s correctional/detention facilities are in the United States, encompassing over 67,000 beds. GEO currently operates four correctional facilities in Arizona – providing services exclusively to ADCRR.

GEO is committed to high-quality, meaningful inmate treatment and work programs in order to maintain the integrity of security operations and maximize the impact of behavioral programs on the recidivism rate. By utilizing evidence-based and innovative programs, we

Tab 2 – Section 1: Introduction page 5 of 7 strive to improve the health and welfare of inmates and instill in them a strong work ethic to develop attitudes essential for becoming productive citizens after release from incarceration.

Systemic, Evidence-based Approach GEO made a historic change in its mission statement to include the provision of evidence-based programs that have shown to enhance an offender’s success upon release and reduce recidivism. GEO is not only committed to providing safe and secure facilities, but is also fully committed to assisting offenders in a successful and lasting return to the community.

The GEO Group offers a full continuum of corrections solutions, and we are committed to providing leading, evidence-based rehabilitation programs to individuals while in-custody and post-release. GEO’s programs and services target the underlying causes that motivate criminal behavior and are supported by a corporate structure that provides rigorous training of its employees, guarantees program fidelity, and ensures results.

GEO’s commitment to evidence-based interventions requires that we use curriculum and approaches supported by empirical evidence. Examples of those approaches include the use of validated assessment instruments, individual treatment plans targeting dynamic needs, cognitive behavioral action-oriented groups, motivational interviewing, skills building and role playing, and the use of behavior modifications stressing positive rewards.

Examples of evidence-based curriculum include technology-driven Academic Programs, Self-Development and Reentry Programming, as well as the Changing Offender Behavior Program. In recognition of the special needs of the adult learner, the facility programs and services allow for individual differences in the learning style of students. In addition, the education program will offer programs to meet the needs of students without regard to the length of stay. Program entry and exit are tied to the achievement of clear and measurable learning goals.

With this comprehensive continuum of care model, GEO provides evidence-based programming thus easing consistency in treatment and promoting effectiveness in reducing recidivism.

All staff at the Facility will receive training to support the provision of effective in-custody programs. Core Correctional Practices (CCP) is an evidence-based curriculum focusing on recidivism reduction. The 16-hour training program will focus on professional alliance, effective reinforcement, effective disapproval, and effective use of authority. Skills developed in CCP promote effective behavior change among inmates. Staff will also receive 16 hours of training in Motivational Interviewing techniques, an evidence-based intervention tactic used by Facility staff to assist the inmate in identifying discrepancy between their current behavior and their future goals.

Tab 2 – Section 1: Introduction page 6 of 7

Inmate Engagement GEO not only understands the high programmatic standards set by ADCRR but has a performance record of consistently meeting these standards on program content and participation. As an example, all of the Arizona facilities that GEO has managed (Kingman, Florence West, Central Arizona and Phoenix West) have consistently met the program participation levels set by ADCRR and continue to add new and innovative programs to meet the needs of the population. GEO has demonstrated that we can provide a wide variety of programs to meet and exceed the requirements of our contracts, not only in Arizona but in the other 8 states where we manage programs.

Rehabilitation and Reentry Preparation GEO is committed to high-quality, evidence-based treatment and work programs in order to maintain the integrity of security operations and maximize the impact of behavioral programs on the recidivism rate. By utilizing evidence-based and innovative programs, we strive to improve the health and welfare of participants and instill in them a strong work ethic to develop attitudes essential for becoming productive citizens after release from incarceration.

GEO has a rich history of providing quality education and treatment services, understanding that the program services can reduce recidivism and help participants become productive members of society. On any given day, more than 30,000 individuals participate in programs at GEO facilities around the U.S. In the past 10 years, GEO has awarded more than 19,000 high school equivalency (HSE) diplomas. Participants have the opportunity to enroll in programs at GEO facilities around the U.S., ranging from academic and vocational classes to Cognitive Behavioral and Substance Abuse treatment programs.

GEO believes a participant’s preparation for release begins at initial commitment and continues throughout incarceration and until final release to the community. GEO plans to implement enhanced case management to assist participants with a seamless transition to society. Interventions are developed during sessions. These interventions include social skills, thinking reports, behavior chains, problem solving, and cost-benefit analysis, while targeting individual criminogenic needs, and emphasizing skills building. A release plan is developed for each participant.

GEO will offer the facility a systems approach where all functional areas (i.e., operations staff, Program Counselors, Job Assignment Supervisor, Recreation, Chaplaincy, Case Manager and facility leadership) work with community advisory members, and together, address each individual need.

GEO provides work programs and cognitive behavioral programming to prepare individuals for reentry into society and help them become productive, contributing citizens in their respective communities upon release. GEO has received positive feedback from staff working in ADCRR’s parole unit regarding how prepared inmates releasing from

Tab 2 – Section 1: Introduction page 7 of 7

GEO facilities are in comparison to inmates releasing from other locations. GEO’s programming provides inmates with the tools necessary for a successful transition and reentry.

All of GEO’s programs are designed around adult learners, with the understanding that adults have specific learning requirements. The best learning environments are the ones that are collaborative and utilize a problem-based approach.

GEO insists that each of its facilities be a model of modern correctional management and inmate programs. We believe that while incarcerated, each inmate must be given the greatest opportunity to change his or her life. For this reason, GEO strives to provide all qualified inmates at our correctional facilities with innovative programs that are proven to reduce relapse, revocation and recidivism and promote responsibility, motivation, practice pro-social thinking civil behavior, and positive decision making. These types of programs (i.e., counseling, work opportunities, academic education, vocational education, life skills, and other treatment programs) are beneficial in providing inmates with the knowledge and skills needed to realize a successful future as a contributing member of a free society.

GEO believes that each individual inmate is capable of positive and productive change. An individual corrections plan will be developed for each inmate beginning the first day of incarceration following through the end of the post release supervision. GEO is dedicated to developing lifelong learners who will become contributing members of society by providing the necessary tools, ideals, and support to encourage this capacity for change.

Providing our inmates with a comprehensive educational program is the Programs department’s main focus. This focus includes critical thinking and communication skills that will prepare them for success in the community.

Programs strive to continually motivate inmates to realize their full potential by establishing goals and setting parameters. The Administrative, Security, Support, and Education staff members dedicate themselves to the preparation of inmates as productive and responsible citizens. Teamwork and good communication are essential for success, and essential to ensuring that the program will make a difference in the lives of inmates.

2. Definitions of Terms

Tab 2 – Section 2: Definition of Terms page 1 of 1

2. Definition of Terms

GEO Secure Services LLC, a wholly owned subsidiary of The GEO Group, Inc.

(collectively referred to as GEO) has read, understands, and will comply with the definitions and requirements provided in Section 2: Definition of Terms, as well as those provided in Special Terms and Conditions and Uniform Terms and Conditions of Solicitation No. BPM004542.

3. Licensing and Additional Requirements

Tab 2 – Section 3: Licensing and Additional Requirements page 1 of 2

3. Licensing and Additional Requirements

GEO Secure Services, LLC, a wholly owned subsidiary of The GEO Group, Inc.

(collectively referred to as GEO) has read, understands, and will comply with the requirements outlined in Section 3: Licensing and Additional Requirements, and all subsections contained therein.

GEO Operational Excellence – Contract Administration The GEO Contract Administration department is located in the Boca Raton, FL Corporate Offices. It is led by Executive Vice President Amber Martin with over 30 years of experience in corrections, contract administration and compliance, and legal administration. She is supported by 13 subject matter experts in contract management, policy development, client correspondence, contract finance, equitable adjustments, contract analysis, and negotiations. This department ensures that all GEO’s operations are conducted in accordance with contract provisions, applicable court orders, and in compliance with national standards.

All required licenses are in place and valid for the continued operation of the Florence West Correctional and Rehabilitation Facility (Florence West). The GEO Proposal presents the least risk to ADCRR in transitioning Florence West to a new contract.

Security Agency License GEO is currently a licensed security agency in the State of Arizona in accordance with A.R.S. Title 32, Chapter 26, Article 2, and will continue to renew the license throughout the terms of all GEO contracts with the State of Arizona. Copies of the required license and GEO’s Arizona Certificate of Good Standing showing our adopted name TGG, Inc., have been provided as attachments at the end of this section.

See State of Arizona Licensure – attached

GEO will ensure that the requirements under A.R.S Title 32, Chapter 26, Article 2 will in no way limit the insurance requirements required under this contract. GEO understands that non-compliance of this requirement constitutes an Event of Default.

Compliance with ADCRR Written Instructions GEO understands and acknowledges the requirement to comply with all ADCRR Written Instructions, state statutes, and federal laws as applicable fulfilling the obligations outlined in the contract. As new and/or revised ADCRR Written Instructions, State Administrative Rules, Court Orders/Decrees, case law, state statutes, and federal laws are issued that impact this contract, GEO will provide revised/new written institution orders or post orders

Tab 2 – Section 3: Licensing and Additional Requirements page 2 of 2 for the approval of the ADCRR Contract Beds Operations Director or designee, and implement changes in full in a timely manner.

GEO understands and acknowledges that as the Contract Facility Operator, GEO is responsible for all costs to implement in full the new or revised ADCRR Written Instructions, and applicable Court Order/Decrees or new case law or statute occurring after execution of this Contract. Should a change in scope of services occur as a result of new and/or revised ADCRR Written Instructions, state statutes, and federal laws as to increase or decrease the cost of operating and managing the facility or performing other services contemplated in this contract, either party may present documentation to the other to support and increase or decrease in the per diem. The parties will use their best efforts to arrive at a mutually acceptable increase or decrease in the per diem as a result of the change in services.

Milestone Chart GEO is the current operator of the facility subject to this solicitation and has successfully partnered with ADCRR to manage Florence West since 2005. Florence West is currently equipped with a qualified, trained staff and is fully operational. A new contract will require relatively few operational transition activities, to include recruiting staff for new positions;

submission of any updated policies, procedures, and emergency plans; and implementation of new requirements in accordance with the Scope of Work (SOW). GEO is prepared to work with ADCRR to implement the use of Electronic Health Records (EHR). In accordance with Amendment 2, GEO acknowledges that the State’s new inmate correctional healthcare provider, NaphCare, will cover costs for the new Electronic Health Records (EHR) at the Florence West Facility, to include costs associated with equipment, installation, and user/seat licensing. Accordingly, operations will continue with minimal disruption during the transition between the contracts.

As the incumbent provider, GEO does not anticipate a need for a transition period and plans to provide continuation of the facility's full services upon the service commencement date.

Security License

4. Investigations

Tab 2 – Section 4: Investigations page 1 of 1

4. Investigations

GEO Secure Services LLC, a wholly owned subsidiary of The GEO Group, Inc.

(collectively referred to as GEO) has read, understands, and will comply with the requirements outlined in Section 4: Investigations, and all subsections contained therein.

5. Contract Monitoring Activities

Tab 2 – Section 5: Contract Monitoring Activities page 1 of 6

5. Contract Monitoring Activities

GEO Secure Services LLC, a wholly owned subsidiary of The GEO Group, Inc.

(collectively referred to as GEO) has read, understands, and will comply with the requirements of Section 5: Contract Monitoring Activities, and all subsections contained therein.

GEO Operational Excellence – Contract Compliance GEO has dedicated considerable resources to the development of an independent Contract Compliance (CC) department responsible for monitoring and validating operations at each of our facilities to meet the needs of the client. The CC department is an independent corporate division headed by Executive Vice President (EVP) Daniel Ragsdale, with over 20 years of legal and law enforcement experience. The EVP reports directly to the Chief Executive Officer of GEO. There are over 70 experienced employees in CC, including a Vice President (VP), several Directors, and more than two dozen Managers. All Directors and Managers are overseen by the VP and the EVP of CC.

Acknowledging the importance of full medical compliance reviews by medically licensed professionals, GEO employs a team of six medical compliance specialists: two Medical Doctors with over 50 years of combined operational experience, three Registered Nurses with a range of operational and compliance experience in health care delivery, and one Licensed Practical Nurse specializing in NCCHC accreditation.

This ensures thorough, independent, and effective medical reviews. A Senior Director is responsible for the ACA accreditation process and PREA initiative for all applicable facilities. In GEO’s Western Regional Office, a Director of Contract Compliance and two Managers provide regional compliance oversight, periodically visiting each facility, and participating in Annual Corporate and Follow-Up Audits, and during accreditation preparations.

GEO’s draft internal monitoring program is as follows:

Monitoring & Evaluation GEO acknowledges the ADCRR requirement to monitor performance to validate compliance with all contract provisions, including A.R.S. §§ 41-1609, 41-1609.01, 41- 1609.02, 41-1609.03, and 41-1609.04, ADCRR instructions and all applicable standards including ACA, PREA, NCCHC, ADCRR guidelines, specifications of the Contract, court orders and decrees. GEO will grant ADCRR and the ADCRR contract monitor reasonably prompt access to records to examine the facility’s operation, including financial books and records, maintenance records, and employee and inmate records generated by the facility

Tab 2 – Section 5: Contract Monitoring Activities page 2 of 6 and its subcontractors, or independent contractors, in connection with the performance of this Contract. GEO understands ADCRR’s monitoring activities will include subcontractors. GEO will receive all inspection activities generated by the ADCRR Contract Monitor and specifically address all identified issues through corrective action plans to achieve compliance within the specified time frame.

ADCRR Contract Monitor GEO acknowledges the ADCRR Contract Monitor or designated ADCRR staff will monitor GEO’s compliance and performance with all contract provisions and applicable policies and standards to include, but not limited to, Security; Inmate Management and Control; Inmate Programs and Services; Facility Safety and Sanitation; Administration;

Food Service; Personnel Practices and Training; Inmate Health Services; Inmate Discipline; Maintenance; and other matters relating to services as determined by ADCRR.

Self-Monitoring GEO acknowledges its responsibility to continually conduct self-monitoring and to test compliance, identify areas of non-compliance, construct corrective action plans, and verify necessary improvements have been made. GEO acknowledges the requirement for Facility-level self-monitoring and corporate-level self-monitoring. GEO will provide reports and/or documentation of all self-monitoring to the ADCRR Contract Monitor no later than the fifth day or third workday of each month. GEO will provide the ADCRR Contract Monitor with copies of the Quality Control Program (QCP).

GEO’s CC department is responsible for, and committed to, implementing the QCP, conducting reviews during the year, training facility Compliance Administrators (CAs), and assisting with internal quality control reviews at the facility. Dedicated corporate staff continuously develop, update, and improve audit tools to remain current with operational issues, GEO policies, and ADCRR guidelines.

All major functional areas will be audited regularly by CC corporate and facility staff. This systematic monitoring will consist of continuous facility-level audits, at least two (2) corporate reviews annually and ad hoc reviews as needed.

Internal On-site Self-Monitoring The Facility Administrator and facility staff are charged with the primary self-monitoring responsibilities and maintaining compliance with applicable standards. The Facility Administrator is responsible for ensuring the leadership and resources necessary for total commitment to the QCP are provided, guaranteeing maximum benefit to the facility and client.

The CC department creates and provides the CA with training covering compliance and quality assurance techniques and audit procedures. The CA is responsible for the coordination and execution of the facility-level self-monitoring assessments. The CA trains

Tab 2 – Section 5: Contract Monitoring Activities page 3 of 6 and directs a cadre of subject matter experts (SMEs) to conduct self-monitoring assessments. The SMEs consist of facility department heads, supervisors, and staff with experience in the areas to be audited.

Internal on-site, self-monitoring assessments will be coordinated throughout the calendar year by the CA utilizing the same audit tools as the external annual corporate audit.

Monitoring includes reviews of all operational areas, compliance with ADCRR requirements, and adherence to contract provisions. All audit findings are entered into the CC audit compliance database by the end of the monitoring month. The intervening months consist of follow-up reviews of items previously identified as non-compliant. Follow-up reviews enable on-site staff and management, as well as corporate management, to ensure CAPs are sustainable and effectively prevent repeat deficiencies. Non-compliant findings and CAPs are also reviewed during the annual corporate audit, follow-up audit, and ad hoc audit (when necessary).

External Annual Contract Compliance Department Audit GEO will conduct an Annual Corporate Audit led by corporate CC staff with assistance from SMEs. The audit will be a full-scope review and utilizes a spectrum of audit tools to validate all contractual, federal, state, and local requirements. Neither facility staff nor any operational staff with oversight of the facility being audited will be permitted to participate as auditors in this audit to ensure complete independence.

The Chair of the Annual Corporate Audit Team, working with the Director of CC, is typically responsible for:

Conducting the audit in an objective, efficient, effective, and professional manner

Thoroughly and fairly reviewing all audit findings and arbitrating finding disputes

Providing the Facility Administrator and staff with a thorough out-briefing at the conclusion of the audit

Conducting a Post Audit Workshop to review audit findings, discuss requirements, and assist in the development of viable CAPs

Preparing and issuing a Summary Report

Providing oversight to address all findings identified during the audit with a CAP in accordance with established timelines

The CC Directors and Managers will be responsible for verifying success of the CAPs through discussions, reviewing facility updates in GEO’s audit compliance database, remote document review, and the Follow-Up Audit.

a. Post Audit Workshop At the close of the Annual Corporate Audit, the audit Chair conducts a Post Audit Workshop (PAW). The PAW consists of multiple, consecutive meetings between CC staff, Tab 2 – Section 5: Contract Monitoring Activities page 4 of 6 the Facility Administrator, relevant facility leadership, and other staff pertinent to the findings. Collectively, participants will review the findings, supporting working papers, and applicable policies/procedures to develop effective CAPs with designated responsible parties.

The benefits of the Post Audit Workshop are:

To continue the focus on non-compliant findings immediately after conclusion of the audit and create effective solutions expeditiously.

The CA has the support of facility leadership to assist Department Heads in the creation of effective and sustainable CAPs.

Discussion of tough issues with all pertinent staff present instills ownership of CAP requirements on every level.

The facility receives the benefit of the Chair’s expertise in explaining the expectations and intent of policies/standards. The Chair is also able to provide examples of proven solutions implemented at other facilities. With all pertinent staff present during the workshop (if the issue involves staff work), the information from the Chair is communicated to staff directly without Department Head interpretation.

Each Facility Administrator and CA are provided the guidance and direction needed to implement CAPs with great likelihood of sustained compliance.

b. Follow-Up Audits and Ad Hoc Audits Within approximately six months of the Annual Corporate Audit, a Follow-Up Audit may be conducted by CC to verify the annual audit findings have been corrected. If necessary, Ad Hoc Audits will be conducted to target specific areas of concern or interest raised outside the formal audit process. Ad Hoc Audits could also be scheduled to address any concerns identified in Annual Corporate Audits, Client Audits, and/or Center audits to address start-up issues of a new operation or deficiencies originating from audit activity or client observation. The content and method of the Ad Hoc Audits will be tailored to the specific issues identified.

c. Quality Control Measures for Subcontractors The CC department audits work performed by GEO’s subcontractors with the same schedule and audit tools that apply to work performed by GEO itself. GEO holds its subcontractors to the same level of performance and all applicable contractual requirements

American Correctional Association (ACA) Accreditation GEO’s CC department will work with the facility to achieve and maintain ACA accreditation. Accreditation is obtained through training, oversight, and includes a mock ACA Audit 2-3 months prior to the accreditation audit. GEO employs a CC Senior Director and managers at the corporate level who are responsible for working with GEO facilities in preparation for the ACA accreditation process. GEO has moved to automate

Tab 2 – Section 5: Contract Monitoring Activities page 5 of 6 accreditation documents and the audit process with success and regularly receives compliments from ACA auditors.

Safety & Emergency Procedures In all matters relating to safety and health, GEO’s policy and practices will comply fully with recognized occupational safety and health standards and codes. The Fire Safety Manager (shared position with Central Arizona Correctional Facility) works directly with the Facility Administrator for the establishment and maintenance of a comprehensive safety program for the Facility. GEO requires Facility staff to ensure comprehensive physical plant inspections are conducted on a scheduled basis to ensure the integrity of the facility, the safety of all individuals in our care, and that the safety of our valued employees, suppliers, vendors, and visitors.

The Fire Safety Manager is responsible for making recommendations to the Facility Administrator concerning compliance with applicable federal, state, and local regulations relative to health and safety, and for establishing and implementing regular safety inspections at the Facility. Any alteration, construction, renovation, occupancy classification, or use condition changes of the Facility will not impact GEO’s ability to maintain high quality fire safety standards and procedures.

No employee or inmate will be exposed to known safety or health hazards. Compliance with accepted safety practices is the responsibility of each employee. Facility management and staff will implement appropriate mechanisms for the identification and timely correction of violations, hazards, or deficiencies.

The Facility Administrator will ensure the Facility is inspected at least annually by a qualified State of Arizona fire official. Facility staff will conduct weekly fire and safety inspections. Each fire inspection will be documented. All fire detection, communication, alarm, annunciation, suppression, and related equipment shall be operated, inspected, maintained, and tested in full compliance with all applicable codes. Inspections will be thoroughly documented and maintained for review at any time.

Compliance with Prison Rape Elimination Act (PREA) GEO will adhere to the federal Prison Rape Elimination Act (42 U.S.C. §§ 15602—15609, Public Law 108-79). GEO understands ADCRR requires GEO to provide ADCRR with a copy of all PREA reports at the Facility involving inmates, staff, contractors, or volunteers.

GEO understands ADCRR reserves the right to review any report, substantiated or unsubstantiated, of sexual contact that occurs at the facility, including sexual misconduct by GEO’s employees.

Federal Prison Rape Elimination Act (PREA) Compliance GEO’s zero-tolerance policy prohibits sexual conduct between employees, volunteers, contractors, and offenders, regardless of consensual status. Sexual conduct between

Tab 2 – Section 5: Contract Monitoring Activities page 6 of 6 offenders is also prohibited, regardless of consent. Such conduct is subject to administrative as well as criminal and disciplinary sanctions.

GEO employs a Senior Director to act as the dedicated PREA Coordinator. The PREA Coordinator reports to the VP and EVP of the corporate CC department. The PREA Coordinator is responsible for implementation of PREA monitoring systems and policies as well as developing, implementing, and overseeing GEO’s compliance with the National DOJ PREA Standards in all its required facilities. In addition, the PREA Coordinator provides guidance and resources in all matters related to PREA training, reporting, allegations, and investigations.

GEO also employs five corporate CC PREA Managers with extensive investigative experience, who are charged with reviewing and assisting in investigations of PREA incidents as well as operating as a resource to all facilities. An additional corporate staff member, the PREA Compliance Specialist, is dedicated to collecting and analyzing PREA statistical data, preparing required reports, and tracking investigations. In addition to the corporate PREA team, a PREA Compliance Manager will be designated at the facility to work closely with the corporate team to ensure PREA compliance at the facility level.

This team, as part of the corporate CC department, will work with staff at the facility to implement GEO’s extensive training program for all employees, volunteers, and contractors. Specialized training will also be provided for investigators and medical personnel. Upon employment, all staff receive a three-hour initial training course specifically covering DOJ PREA guidelines, with two hours of annual in-service training thereafter. All inmates will receive PREA education as part of the intake/admissions process and are screened within 24 hours of arrival for any indication of current sexual vulnerability or sexually aggressive behavior before determining housing, programming, and classification assignments.

To ensure PREA certification is achieved and maintained, the National PREA standards, referenced in 28 C.F.R. Part 115, are addressed in GEO’s Quality Control Program and are assessed during both Facility self-monitoring audits and annual corporate audits utilizing comprehensive auditing tools.

6. Performance and Monetary Offsets

Tab 2 – Section 6: Performance and Monetary Offsets page 1 of 1

6. Performance and Monetary Offsets

GEO Secure Services LLC, a wholly owned subsidiary of The GEO Group, Inc.

(collectively referred to as GEO) has read, understands, and will comply with the requirements outlined in Section 6: Performance and Monetary Offsets and all subsections contained therein.

7. Contractor’s/ Subcontractor’s Qualifications

Tab 2 – Section 7: Contractor’s/Subcontractor’s Qualifications page 1 of 19

7. GEO & Subcontractor Qualifications

GEO Secure Services LLC, a wholly owned subsidiary of The GEO Group, Inc.

(collectively referred to as GEO) has read, understands, and will comply with the requirements of Section 7: Contractor’s/Subcontractor’s Qualifications and all subsections contained therein.

GEO’s Organizational Qualifications GEO specializes in the design, financing, development, and operation of secure facilities, processing centers, and community reentry centers in the United States, Australia, South Africa, and the United Kingdom. GEO is a leading provider of enhanced in-custody rehabilitation, post-release support, electronic monitoring, and community-based programs. GEO’s worldwide operations include the ownership and/or management of 104 facilities totaling approximately 84,000 beds, including idle facilities and projects under development, with a workforce of approximately 18,000 professionals.

GEO is publicly traded and listed on the New York Stock Exchange (NYSE: GEO) and has an enterprise value exceeding $3.3 billion. GEO’s domestic and international revenues for 2021 were approximately $2.3 billion, with credit facilities exceeding $1.6 billion.

GEO is a Florida-based company with its Corporate Office located in Boca Raton, FL, and has a staff of approximately 442 employees. Our corporate and regional staff includes experts in prison design, finance, contract compliance, construction, administration, security, health services, education, vocational training, counseling, substance abuse treatment, food service, maintenance, procurement, and professional accreditation.

Corporate Correctional Management Team The GEO Secure Services Business Unit is led by GEO Senior Vice President & President of GEO Secure Services, James Black, with more than 37 years of correctional experience.

He is supported at the Corporate Office by nearly three dozen subject matter experts in corrections, administration, security, food services, and training. On a daily basis, they oversee the three U.S. Regional Offices and operations in the United Kingdom, Australia, and South Africa. GEO Secure Services oversees the management and operation of approximately 74,000 beds in 57 correctional and detention facilities around the world.

This Division currently provides services on behalf of the Federal Bureau of Prisons, U.S.

Marshals Service, and U.S. Immigration and Customs Enforcement, as well as seven state correctional clients and various county and city jurisdictions around the country.

Tab 2 – Section 7: Contractor’s/Subcontractor’s Qualifications page 2 of 19

GEO Regional Office Oversight The three GEO Regional Offices provide facility oversight and support, ensuring immediate and direct assistance to the facility management teams. The GEO Western Regional Office, located in Los Angeles, CA, has nearly 20 staff who are responsible for daily operational oversight of Florence West. It is staffed with subject matter experts in security, health services, physical plant maintenance, risk management, contract compliance, business management, and information systems. The Western Regional Office is led by Regional Vice President Paul Laird with 35 years of correctional experience.

Contract Administration The GEO Contract Administration department is located in the Boca Raton, FL Corporate Offices. It is led by Executive Vice President Amber Martin with over 30 years of experience in corrections, contract administration and compliance, and legal administration. She is supported by 13 subject matter experts in contract management, policy development, client correspondence, contract finance, equitable adjustments, contract analysis, and negotiations. This department ensures that all GEO’s operations are conducted in accordance with contract provisions, applicable court orders, and in compliance with national standards.

Correctional Health Care The GEO Corporate Health Services department is led by Executive Vice President Lisa Krueger with 20 years of experience in health care administration and operations, and Chief Medical Officer Dr. John Christakis with 40 years of experience in clinical medicine. They are supported in the Corporate Office by 16 subject matter experts in correctional health care, administration, dental services, mental health services, quality control, utilization management, and off-site health care claims management, as well as clinical care support.

On a continuous basis, the Corporate Health Services department supports and monitors staff vacancies, clinical outcomes, special incidents, clinical encounters, outside patient care, medication management, and updates clinical guidelines.

Contract Compliance GEO has dedicated considerable resources to the development of an independent Contract Compliance (CC) department responsible for monitoring and validating operations at each of our facilities to meet the needs of the client. The CC department is an independent corporate department headed by Executive Vice President (EVP) Daniel Ragsdale with over 20 years of legal and law enforcement experience. The EVP reports directly to the Chief Executive Officer of GEO. There are over 70 experienced employees in CC, including a Vice President (VP), several Directors, and more than two dozen Managers.

All Directors and Managers are overseen by the VP and the EVP of CC.

Tab 2 – Section 7: Contractor’s/Subcontractor’s Qualifications page 3…