Ethical Business Practices – Engagement with Prime Contractors

Diane G. DempseyBAE Systems, Inc.

Intelligence & Security Sector

Overview

• Inaccurate Capabilities Statement• Deceptive Pricing• Employee Prostelization• Size Standard Misrepresentation• Gratuities• Incorrect Invoicing Practices

Size Standards

• Understand how size standards apply and use them correctly.

• Stating your company is small when it is actually large in the NAICS Code under which the work is being performing is grounds for suspension/debarment.

• Primes rely on self certification from SBs. If the size is misrepresented the result is TD.

Inaccurate Capabilities Statement

• Overstating capabilities is misleading. • Correctly state relationship – prime or sub –

both are of interest.• Listing agencies or primes as customers when

no work has been awarded.

Deceptive Pricing

• Services focused – providing rates but cannot provide resumes or staff to support the position. Buying In.

• Offering to fill slots at higher rates.• Products – upselling by offering ECNs or other

modifications that increase pricing. A higher priced product or service in lieu of what was initially proposed.

Employee Prostrolization

• Refer to your subcontract agreement: Both parties agree not to prostrolize – offer employment to the other parties employees (seduce/steal).• Government/LB/SB are all guilty of this

practice.• It undermines trust in the relationship.

Gratuities

• Understand the government and prime contractors policy related to gratuities.

• Prime contractors vary in their policy’s; however, it is important that a SB understand and abide by the policies.

• Not observing government or company policy can place a contractor on a suspended/debarred list.

Incorrect Invoices

• Understand and abide by your customer’s invoicing policies:– Review invoices for accuracy.– Only invoice for work performed or product

received.– Invoice in accordance with required format.– Submit invoices in a timely manner.

Summary

• Customers continue to do business with ethical company’s that provide quality products/services at competitive prices.

• A trusted subcontractor is a valued resource.• Ethical small businesses are the recipients of

good references.

WE TALK !!!!!!!