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Green Book - Booz Allen Hamilton

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Consequently, we are committed<br />

to providing subcontracting<br />

opportunities to the full range of<br />

small businesses and in particular<br />

small disadvantaged businesses<br />

such as:<br />

oo<br />

oo<br />

oo<br />

oo<br />

oo<br />

Historically Underutilized<br />

Business Zone (HUBZONE)<br />

small businesses<br />

Women-owned small businesses<br />

(WOSB)<br />

Service-disabled veteran-owned<br />

small businesses (SDVOSB)<br />

Historically black colleges and<br />

universities (HBCU)<br />

Minority institutions<br />

Payments to Nonprofit Entities<br />

All firm payments to nonprofit<br />

entities—regardless of whether<br />

they are a donation or a payment<br />

made pursuant to a contract—must<br />

be processed via the Contributions<br />

Portal, which is managed by the<br />

Community Partnerships team within<br />

Marketing and Communications.<br />

Such processing supports accurate<br />

reporting of the payment for tax<br />

purposes.<br />

Truthful Negotiations In dealing with<br />

current or potential suppliers, each of<br />

us must be candid and truthful about<br />

our requirements, accurate in our<br />

statements, and fair in negotiations,<br />

ensuring that all competitors for<br />

the opportunity have equal access<br />

to the same pertinent information.<br />

We also do not share proprietary<br />

information of other vendors, engage<br />

in technical leveling, or otherwise<br />

engage in practices that do not<br />

comply with applicable laws, rules,<br />

and regulations.<br />

Key policy related to this Code<br />

section:<br />

oo<br />

Procurement Policy<br />

2. Boycotts<br />

<strong>Booz</strong> <strong>Allen</strong> does not conduct any<br />

operations or activities that are<br />

restricted under US anti-boycotting<br />

laws and regulations.<br />

Understanding Boycotts “Boycotts”<br />

are activities that are designed to<br />

limit trade with certain countries,<br />

entities, or individuals. US antiboycott<br />

laws and regulations restrict<br />

US firms from participating in<br />

foreign boycotts or other restrictive<br />

international trade practices that the<br />

US Government does not support.<br />

Prohibited Actions You are prohibited<br />

from taking any action that furthers<br />

or supports a boycott against a<br />

country that is friendly to the United<br />

States and/or a boycott that the US<br />

Government does not sanction. The<br />

anti-boycott laws and regulations<br />

include prohibitions on the following:<br />

oo<br />

Agreements to refuse or actual<br />

refusal to do business with<br />

boycotted countries or companies<br />

organized under the laws of<br />

boycotted countries<br />

Q: I received a draft contract<br />

from a prospective client<br />

that requires us to provide<br />

information concerning the<br />

firm’s business with the<br />

government of Israel. If I<br />

know the firm has no current<br />

business with the Israeli<br />

government, may I report that<br />

information in our proposal<br />

and accept the clause in any<br />

resulting contract<br />

A: No. United States antiboycott<br />

laws prohibit us from<br />

agreeing to any such clause.<br />

Moreover, we may be required<br />

to report the fact that the<br />

prospective client included<br />

such a clause in its contract.<br />

The clause must be removed<br />

from the contract before we<br />

can execute it, and you should<br />

contact the Law Department<br />

regarding our disclosure<br />

obligations.<br />

Q&A<br />

44<br />

THE GREEN BOOK | The <strong>Booz</strong> <strong>Allen</strong> <strong>Hamilton</strong> Code of Business Ethics and Conduct

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