1. [Program Name] ORGANIZATIONAL CONFLICT OF INTEREST TRAINING
[Position]
[Date]

2. Overview Organizational Conflict of Interest - Defined
[Program Name] OCI Mitigation Plan Measures
Employee Responsibilities
Questions/Comments
[Program Name] POCs

3. 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.

4. 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

5. [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 ……….

6. [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

7. (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)

8. (Sample 2) [Program Name] NDAs

9. 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

10. 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.

11. Any Questions?

12. [Program Name] POCs Program Mgmt: HR: Contracts: Subcontracts:
Security: