Complying With the ProcurementIntegrity Act (PIA) The PIA is afederal statute meant to ensurefair competition for US Governmentcontracts. It does so by regulating(1) employment discussions withcertain government employees, (2)the hiring <strong>of</strong> certain <strong>of</strong>ficials by primecontractors, 1 and (3) the handling<strong>of</strong> “source selection information”and “contractor bid or proposalinformation.”You must carefully reviewinformation that you receive toensure compliance with PIAinformation-related provisions.Source selection information isrelated to the US Government’sevaluation <strong>of</strong> proposals (e.g.,contractor selection plans, technicalor cost evaluations, competitiverange determinations, proposalrankings, and selection boardreports). Contractor bid or proposalinformation is non-public informationthat an <strong>of</strong>feror provides, such as costor pricing data, technical information,or other proprietary data. Informationthat falls into one <strong>of</strong> these categoriesmay or may not be marked as such.You must not solicit either <strong>of</strong> thesetypes <strong>of</strong> information. Just as withimproperly received competitorproprietary information, if you receiveit, you must retain it along withany e-mail or other means used totransmit it, not provide it to anyoneelse, and immediately contact theLaw Department for direction.The only exception to this ruleis when you are required bycontract to receive PIA-covereddata in connection with renderingprocurement advice. If you are1 Our Post-Government EmploymentPolicy protects against violations <strong>of</strong> theemployment-related provisions <strong>of</strong> thePIA. See Section VI.5–Post-GovernmentEmployment.performing such an engagement,you must safeguard the PIA-coveredinformation, use it for only yourassignment, and not disclose it toother employees.The PIA does not apply to competingfor non-US Government contracts.When competing for such work, youare expected to adhere and complywith the terms and conditions includedin any applicable request for proposalor any agreement executed by thefirm in connection with the competition.Complying With Antitrust LawsAntitrust laws prohibit Booz Allenfrom entering into agreements orother arrangements to eliminatecompetition or restrain trade.Other than teaming agreementsand subcontracts negotiated andexecuted in accordance with thefirm’s policies, such as the ContractReview and Approval Policy, you maynot enter into any formal or informalarrangement with a competitorunder which either the firm or itscompetitor agrees to not pursue abusiness opportunity. We do notenter into teaming agreements totake a potential competitor “<strong>of</strong>f thestreet”; rather, we do so only tocomplement our capabilities. Underno circumstances may you enter intoany arrangement or understandingwith a competitor involving pricefixing,client term-setting, bid-rigging,bid-rotating, or market-dividing.Respecting Organizational Conflict<strong>of</strong> Interest and Non-DisclosureCommitments For certain clientengagements, we enter into anorganizational conflict <strong>of</strong> interest(OCI) mitigation plan that may includefirewalls or other protections so thatour performance <strong>of</strong> the engagementdoes not threaten the firm’s eligibilityto compete for future work. Similarly,certain clients require that eachemployee working on an engagementexecute a personal NDA that restrictstheir future business activities.(Section VI.1–Organizational Conflicts<strong>of</strong> Interest discusses OCI mitigationplans and NDAs in further detail.)When you work on a project thatincludes a mitigation plan or you signan NDA, you must review and strictlyadhere to any restrictions. This mightmean that you are restricted fromcertain project pursuit and captureactivities to preserve the firm’seligibility to participate.Key policies related to thisCode section:ooooOrganizational Conflicts <strong>of</strong> InterestProcurement Integrity ActCompliance2. AcceptingEngagementsIn accepting work, Booz Allen carefullyweighs all pertinent risks and rewardsto act in the best interests <strong>of</strong> the firmand its clients, shareholders, andemployees. Only those <strong>of</strong>ficers andemployees who have been <strong>of</strong>ficiallydelegated authority to bind Booz Allenand execute contractual documentsmay accept work for the firm. Priorto signing a proposal or contract onbehalf <strong>of</strong> the firm, all reviews andapprovals required by the firm’s RiskMatrix must be obtained. Writtendocumentation <strong>of</strong> compliance withthe Risk Matrix is mandatory.Weighing Engagement RisksWhenever you are involved in helpingthe firm obtain work, you also musthelp it evaluate associated risks.In deciding whether to acceptwork, we take into account allrelevant information—for example,personnel safety, pr<strong>of</strong>itability, type<strong>of</strong> work involved, strategic impact<strong>of</strong> assignment, legal and regulatoryconstraints, contractual termsand conditions, potential financialexposure and risk, reputationalimpact <strong>of</strong> the work, potentialconflicts <strong>of</strong> interest, and other ethicalconsiderations. You must candidly14THE GREEN BOOK | The Booz Allen Hamilton Code <strong>of</strong> Business Ethics and Conduct
provide our leadership with allrelevant information so that the firmcan make an informed decision.We conduct business with onlyreputable organizations thatbehave ethically and legally. Webase decisions to perform servicesin particular countries primarilyon business rather than politicalconsiderations while taking intoaccount social and other nonbusinessfactors.We do not accept work from the USGovernment that would require us toperform an inherently governmentalfunction or that is otherwise notappropriately performed by the firm.We accept only assignments that weare qualified to undertake and thatcan be conducted under conditionsthat do not impair our objectivity,independence, and integrity.Accepting a Subcontracting RoleWorking as a subcontractor requiresthe same due diligence as workingfor the ultimate client. You mustweigh the risks and rewards,obtain the same approvals, andimpose the same quality standardsas we impose when we are theprime contractor. We serve as asubcontractor only in situations inwhich we maintain control over thecontent and presentation <strong>of</strong> ourservices, deliverables, findings, andrecommendations. We accept workonly with prime contractors that shareour commitment to business <strong>ethics</strong>and integrity.Contractually Binding Our Firmand Risk Matrix Compliance Theauthority to accept work is limited toemployees who are designated asfinal approvers and signatories onthe firm’s Risk Matrix and SignatureMatrix. You may not sign a clientproposal or contract on the firm’sbehalf unless authorized to do so bythese documents.“When I joined the firm, I was looking for stability.I found so much more. On day one, it was clear Booz Allenrespects its people and sets the highest standards.With a Marine for my father, I realized I was ‘home’ quickly.Now, 13 years later, it’s these same standardsthat keep me here.“Saying all the Core Values mean so much sounds likean easy answer. The fact is, the Core Values are myway <strong>of</strong> life at work, at home, and beyond. My work inthe community is testament that many, many people inHuntsville see us this way too. It’s why we have such agreat reputation here. ”—Jennifer IckesVIP Award Winner 2012 (Huntsville, AL)RESPECTThe Booz Allen Hamilton Code <strong>of</strong> Business Ethics and Conduct | GREEN BOOK 15Chapter II
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