Quick Reference A-56, Conflict of Interest Inside this procedure …

Quick Reference
A-56, Conflict of Interest
Inside this procedure …
This procedure provides guidance and requirements for Laboratory personnel regarding personal conflicts of
interest, organizational conflicts of interest, and scenarios that create an appearance of impropriety. The purpose
of this guidance is (1) to define each of these conflicts, (2) to explain why their recognition and resolution is
required under MIT Lincoln Laboratory’s contract with the Federal Government, and (3) to provide Laboratory
staff with information about when and how to engage Laboratory Management, the Technology and Contracts
Office, and the Laboratory Ethics Officer for assistance.
Take-Away Checklist …
Important take-away points in this procedure:
 The Federal Acquisition Regulation and the DoD FFRDC Management Plan and Sponsoring
Agreement for Lincoln Laboratory require Lincoln Laboratory to conduct its business in a manner
befitting its special relationship with the Government, to operate in the public interest with
objectivity and independence, to be free from organizational conflicts of interest, and to have full
disclosure of its affairs to the sponsoring agency.
 Conflicts of interest must be avoided or eliminated. Mitigation is not an option.

The Technology and Contracts Office, within the Contracting Services Department, is designated as
the office responsible for implementation of the Laboratory’s Conflict of Interest Program.

An organizational conflict of interest arises when, because of other activities or relationships with
other persons, a person is unable or potentially unable to render impartial assistance or advice to the
Government, or the person’s objectivity in performing the contract work is or might be otherwise
impaired, or a person has an unfair competitive advantage.
 A personal conflict of interest occurs when a Laboratory employee, or a member of the employee’s
family, possesses a financial interest that may benefit by or through the Laboratory employee’s
performance of his or her Laboratory work. An appearance of impartiality issue arises when a
reasonable third party may believe that a Laboratory employee’s impartiality in the conduct of his or
her Laboratory duties could be influenced by certain personal or business relationships.

Laboratory employees who are in a position to materially affect the conduct of, or direction of, a
research program or a procurement are required to file a confidential Annual Statement of Financial
Interests with the TCO.
 All Laboratory staff are required, on an annual basis, to successfully complete the Laboratory’s
online ethics training module.
MASSACHUSETTS INSTITUTE OF TECHNOLOGY
LINCOLN LABORATORY
Subject: Conflict of Interest
Administrative Procedure
A-56 (Rev. 1)
Date: 8 January 2014
Point of Contact: Contracting Services Department
Code of Conduct
Travel Policy and Procedure
Acquisition Procedures
Guidelines for Outside
Employment and Other
Activities
A-20, Guidelines for Contracted
Labor
AN-10, Non-Disclosure Agreement
Procedure/Policy
See also A-1,
A-6,
A-8,
A-14,
ABSTRACT
This administrative procedure provides guidance on how to recognize and avoid
situations that could create actual or apparent conflicts of interest. Conflicts of interest
must be avoided in order for Lincoln Laboratory to maintain its credibility as a trusted
and impartial technical advisor to the federal government.
SUMMARY OF CHANGES
1. The addition of citations to the legal authorities underlying the A-56.
2. The addition of example scenarios where personal conflicts of interest, appearance of
impropriety issues, and organizational conflicts of interest can arise.
3. The identification of an attorney from MIT’s Office of General Counsel as the Laboratory
Ethics Officer.
4. The inclusion of Appendix 1, providing an overview of the review process for Annual
Statement of Financial Interests.
AUTHORITIES
Authority for the provisions of A-56 is found in:
 FAR Part 3.10
 FAR Part 35.017
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
Conflict of Interest
Department of Defense (DoD) Sponsoring Agreement for Massachusetts Institute
of Technology Lincoln Laboratory
DoD FFRDC Management Plan
SCOPE
This administrative procedure applies to all Laboratory employees, Advisory Board
members, Intergovernmental Personnel Act assignees, subcontractors, consultants,
vendors, interns, Lincoln Scholar students, student advisers, and research assistants,
wherever located and whether full or part time.
I.
INTRODUCTION
A. As a Federally Funded Research and Development Center (FFRDC) under contract
with the U.S. Air Force, Lincoln Laboratory is placed in special position of trust. Under the
Federal Acquisition Regulation (FAR), FFRDCs have access to sensitive Government and private
sector proprietary data “beyond that which is common to the normal contractual relationship.” 1
B. As a result, the FAR states that each FFRDC “is required to conduct its business in a manner
befitting its special relationship with the Government, to operate in the public interest with objectivity and
independence, to be free from organizational conflicts of interest, and to have full disclosure of its affairs
to the sponsoring agency.” 2
C. The Department of Defense Sponsoring Agreement for Lincoln Laboratory incorporates the
FAR provisions into the contract. Under the terms of the Sponsoring Agreement, MIT agrees that “work
performed by MIT LL shall be characterized by a need for unquestioned objectivity, divorced from all
conflicting interest, financial or commercial. FFRDC work shall be only in the U.S. public interest” and
further that the Laboratory will “[a]void any action that will put it or its personnel in perceived or actual
conflict of interest positions regarding either unfair competition or objectivity;” and that it will “[c]onduct
its business in a manner consistent with its special relationship with the DoD and, upon request, fully
disclose these affairs to the Sponsor or other DoD/U.S. Government oversight bodies.” 3
D. This administrative procedure defines organizational and personal conflicts of interest
(COIs), outlines the Laboratory’s annual process for identifying and resolving COIs, and provides
resources for Laboratory personnel who seek personalized guidance.
E. Consistent with the Laboratory’s Code of Conduct and contract with the U.S. Air Force, as a
general rule Laboratory staff are obligated to avoid and disclose ethical, legal, financial, or other COIs
involving the Laboratory and to recuse themselves from any matters that create, or appear to create, a
conflict of interest (COI).
F. All new programs, including sponsor funded, Technology Office, and off-contract activity
must be reviewed for COIs in accordance with this procedure.
1
FAR 35.017(a)(2).
FAR 35.017(a)(2).
3
Department of Defense Sponsoring Agreement for Massachusetts Institute of Technology Lincoln Laboratory
(24 July 2009).
2
A-56
II.
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Conflict of Interest
ADMINISTRATION OF THE COI PROGRAM
A. The Technology and Contracts Office (TCO) is designated as the office responsible for
implementation of the Laboratory’s COI program. Within TCO, an individual who is appointed as
Assistant Laboratory Ethics Officer will be delegated the responsibility for serving as the official focal
point for the Laboratory’s COI Program, managing various components of the program, and responding
to questions or concerns from Laboratory personnel.
B. TCO coordinates the COI Program and obtains legal counsel from MIT’s Office of General
Counsel (OGC). OGC’s on-site representative to Lincoln Laboratory serves as the Laboratory Ethics
Officer (LEO), independently reports to the MIT General Counsel and Vice President, and is the decision
authority on COI determinations.
III.
ORGANIZATIONAL CONFLICTS OF INTEREST
A. Each staff member, subcontractor, and consultant must avoid all activities that could create
the perception or appearance of an organizational conflict of interest (OCI). Additionally, under its
contract, the Laboratory must disclose to the Air Force the existence of any OCI it becomes aware of.
B. The term “organizational conflict of interest” means that “because of other activities or
relationships with other persons, a person is unable or potentially unable to render impartial assistance or
advice to the Government, or the person’s objectivity in performing the contract work is or might be
otherwise impaired, or a person has an unfair competitive advantage.” 4
C. Identifying OCIs. While OCIs can occur in any business relationship, they are more likely in
certain situations. Asking the following three specific questions will help to identify if a particular activity
is at an increased risk of an OCI:
D.
1.
Has the Laboratory or one of its employees, affiliates, or its subcontractors obtained
proprietary, source selection, or other nonpublic information that may create the
appearance that the Laboratory is using its position as an FFRDC in a way that creates
an unfair competitive advantage? If so, this can create an OCI based upon unequal
access to information.
2.
Has the Laboratory or one of its employees, affiliates, or its subcontractors provided
information, such as specifications or systems engineering and technical advice, to the
Government that will serve to establish criteria for a particular current or future
procurement? If so, this could create an OCI based upon biased ground rules.
3.
Does the Laboratory or one of its employees, affiliates, or its subcontractors have an
incentive to provide biased advice to the Government? If so, this could create an OCI
based upon impaired objectivity.
Special Consideration for Subcontractor Work Assignments
1.
4
FAR 2.101
Laboratory Division Heads and Group Leaders must carefully scrutinize proposed work
that calls for subcontractors or consultants to advise, consult, or evaluate in areas that
will materially influence recommendations to Government sponsors. Laboratory staff
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Conflict of Interest
shall not discuss the COI or its potential resolution with the subcontractor or consultant
without prior coordination with the TCO.
2.
E.
IV.
In order to minimize the potential for COIs, requests for subcontractor or consultant
support will be coordinated with the TCO prior to issuance of any purchase order. The
COI review process will include a review of the subcontractor’s or consultant’s other
business activities and portfolio, and a certification to the Laboratory from the
subcontractor or consultant that no COI exists based on such a review. Further
guidance on this process is contained in Administrative Procedures A-8 and A-20.
Practical Examples of Organizational Conflicts of Interest
1.
Before an acquisition for information technology is conducted, Company A is awarded
a contract to prepare data system specifications and equipment performance criteria to
be used as the basis for the equipment competition. Since the specifications are the
basis for selection of commercial hardware, a potential COI exists. Company A should
be excluded from the initial follow-on information technology hardware acquisition.
2.
The Laboratory has been directed to develop a system for evaluating and processing
components for a larger project. Contractor B helps develop the system and process the
components. Contractor B should be prohibited from acting as a consultant to any of
the component suppliers during its period of performance and for a reasonable period
thereafter.
PERSONAL CONFLICTS OF INTEREST AND THE APPEARANCE OF IMPROPRIETY OR
LACK OF IMPARTIALITY
A. A personal COI occurs when a Laboratory employee, or a member of the employee’s close
family, has a financial interest, personal activity, or relationship that could impair the employee’s ability
to act impartially and in the best interest of the Government when performing his or her Laboratory work.
Sources of personal COIs can include:
1.
Financial interests of the employee, or the employee’s spouse and close family,
including wages, salary, investments, equity, intellectual property interest, business
ownership interests, and gifts;
2.
Non-Laboratory employment, positions, or other professional activities (see
Administrative Procedure A-14, Guidelines for Outside Employment and Other
Activities); or
3.
Seeking employment.
B. The appearance of lack of impartiality arises when a reasonable third party may believe that
a Laboratory employee’s impartiality in the conduct of his or her Laboratory duties could be influenced
by certain personal or business relationships.
1.
Laboratory employees should be mindful about the appearance of impropriety or a lack
of impartiality when interacting with family members as part of their Laboratory work.
This is especially important when family members are fellow Laboratory coworkers or
employees of Laboratory vendors and suppliers. Employees should notify their
supervisors and the TCO if they find themselves in this situation.
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C.
D.
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Conflict of Interest
Practical Examples of Personal COIs
1.
A Laboratory employee would like to interview for a job opening at ABC Corp, a DoD
contractor who is substantially involved in the employee’s program. Prior to submitting
an application or beginning discussion, the employee must recuse himself from any
matter that could affect that company, until such time as he is no longer seeking
employment with that company.
2.
A Laboratory employee has been asked to serve on the technical evaluation panel to
review proposals for a new Laboratory computer system. ABC Corp, a company in
which he and his wife own stock valued at $16,000, has submitted a proposal. Because
the outcome of this source selection will have a direct and predictable effect on his
financial interests, his participation would be considered a COI. He must immediately
divest the stock or recuse himself from participation.
3.
A Laboratory employee learns in the course of her duties that a small corporation will
be awarded a large subcontract for electrical test equipment. She may not take any
action to purchase stock in the corporation or its suppliers and she may not advise
friends or relatives to do so until after public announcement of the award. Such actions
could violate Federal securities statutes as well as create a COI.
4.
A Laboratory employee also has a position at University ABC, which is seeking a
research contract with the Laboratory. The Laboratory employee may not be involved
with the proposal, decision to award, or execution of that contract on behalf of the
Laboratory or on behalf of University ABC. In addition to being a personal COI, this
situation also creates an OCI for the Laboratory. In situations such as this, the Group
must consult with TCO regarding the potential for COI.
5.
A Laboratory employee has an equity interest and a royalty agreement for her patents
in a small startup firm that is primarily made up of former Laboratory employees. The
Laboratory is interested in purchasing from that company. The employee should recuse
herself and disclose the matter to the Group, Division, and TCO for review. Situations
such as these require determinations based on review of all the relevant facts, such as
the level of the employee’s involvement, any MIT interest in the patent or company,
and consideration of other options that may be available.
Laboratory Rule on Gifts
1.
Laboratory employees cannot, directly or indirectly, solicit or accept a gift from
Laboratory suppliers or subcontractors (prohibited sources) unless it meets one of the
exceptions below. Indirect receipt of a gift includes a situation in which a prohibited
source gives a gift to an employee’s spouse or other household member.
2.
Staff may accept an unsolicited gift of a value of $20 or less per source, per occasion,
provided that the aggregate market value of all individual gifts received from any one
source in a calendar year does not exceed $50.
i.
Example. A Laboratory supplier has offered a Laboratory employee a ticket to a
charitable event consisting of a cocktail reception to be followed by an evening of
live music. Even though the food, refreshments, and entertainment provided at the
event may be worth only $20 each individually, the combined value of the event is
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Conflict of Interest
$60. Such a gift would violate both the individual gift ceiling of $20 (because the
limit is “per occasion”) and the annual ceiling from a single source of $50. The gift
should not be accepted.
3.
Staff may accept a gift when the facts make it clear that the gift is motivated solely by a
family or personal friendship and not because of their position or responsibilities at the
Laboratory. Relevant factors to consider in making the determination include the origin
and length of the relationship, the occasion, and who is paying for the gift. If the gift is
from a Laboratory vendor or supplier, the gift must be disclosed to your supervisor or
TCO for approval, regardless of circumstances.
i.
Example 1. A Laboratory program manager moves into a new house, and his next
door neighbor, who happens to be a vendor to the Laboratory, brings over a gift
basket worth $60 as a welcome present. This gift may generally be accepted.
ii. Example 2. A Laboratory staff member works closely with a subcontractor on a
project, and the two develop a friendship. After the project is completed, the
subcontractor offers to purchase dinner (valued at over $20) for the Laboratory
staff member. This gift may not be accepted.
4.
Staff may accept a gift of free attendance at all or appropriate parts of a widely attended
gathering, such as a contractor-hosted information day, under certain circumstances.
Factors favoring attendance include the event is open to members throughout the
industry/profession; the Laboratory has determined that it has an interest in the
employee’s attendance; a large number of individuals will be attending from diverse
backgrounds; and the event will provide meaningful opportunity to interact with many
different people. Sporting events, such as golf outings or professional sports viewing,
do not qualify as widely attended gatherings; however, social events prior to or
following the event may qualify. The TCO makes the determination of whether an
event qualifies as “widely attended.”
i.
Example. A local charity is hosting a Golf Tournament and Reception that will be
attended by Government employees and members of industry and has offered
Group Leader free attendance to both. It would not be appropriate for Group
Leader to accept free or reduced golf; however, it may be appropriate to accept
attendance at the reception (provided it meets the criteria above, which generally
does not include seated or formal meals because such events do not allow “a
meaningful opportunity to interact with many different people”).
5.
Staff members who regularly interact with Government employees should be aware
that there are strict regulations governing the ability of Government employees to
accept gifts and entertainment from organizations that have a business relationship with
the Government, including FFRDCs such as Lincoln Laboratory. Questions on the
advisability of a gift to a Government employee should be submitted to the TCO.
6.
Bribes, gratuities, and kickbacks are strictly prohibited and may violate Federal and
State law.
A-56
V.
-7-
Conflict of Interest
STANDARDS OF REVIEW AND PROCESS FOR RESOLUTION OF POTENTIAL
CONFLICTS OF INTEREST
A. The TCO review and resolution process uses a totality of the circumstances approach,
considering all the relevant issues and facts. Some factors may include:
1.
The individual’s particular division/group/work scope/assigned program
2.
Review of other technical areas in which the Laboratory is active
3.
Assets and income, relationships, and outside positions or interests of the individual or
that individual’s spouse, children, or close family.
B. Because of the FAR requirements on FFRDCs and the obligations of the Sponsoring
Agreement, as well as direction from the Laboratory’s Administrative Agent and Contracting Officer, the
Laboratory’s standard for resolving conflicts and impartiality concerns is elimination and avoidance. The
Laboratory does not engage in conflict mitigation. Resolution options may include disqualification from
duties, reassignment, and/or divestiture of the conflicting interest.
C. If there is conflict, or the appearance of a conflict, the TCO will discuss with the individual
to obtain any additional facts needed for resolution and will explain the facts, COI, regulation, issue, or
law giving rise to the concern. The TCO will then issue a resolution recommendation.
D. If the recommendation does not fully resolve the concern or the individual does not agree
with the recommendation, the matter will be addressed with the individual’s Division Head.
E. If the Division Head determines the issue is a potential COI, then the Division Head would
recommend divestiture of the asset, ceasing the activity, or reassignment to a nonconflicting role.
Alternatively, the Division Head may state reasons why there is no potential COI, or may refer the matter
to the Director’s Office for resolution. The TCO may accept the Division Head’s recommendation, or
may also refer the matter to the Director’s Office.
F. If a matter is submitted to the Director’s Office, then the Assistant Director of Operations
will review the matter, either alone or with a panel, and give due consideration to any analysis or
recommendations provided by either the LEO, TCO, or the Division Head. The Director may defer the
matter to MIT General Counsel, or may make a final determination on the applicability of the relevant
policy (at his or her discretion).
G. In extremely rare situations, based on exceptional circumstances, the Laboratory may seek a
waiver from the Government. Waiver requests must be submitted to the TCO for review and
recommendation, and approved by the Director of Operations.
VI.
FINANCIAL DISCLOSURE
A. The Laboratory has committed to a financial disclosure program in its FFRDC contract.
Annual Statements of Financial Interest (ASFI) forms will be submitted by individuals for review by the
TCO.
B. Any individual who can materially affect a Program or a Procurement, including all
management, all staff (e.g., Associate, Assistant, Technical, Senior, etc.), Contracting Services
Department, and other identified individuals, will be required to submit an ASFI at least annually, and to
keep it up to date throughout the year.
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Conflict of Interest
1.
“Materially affect” in this section should be construed broadly and includes any action
that contributes to or influences research, findings, or reports; making
recommendations; signing documents; or otherwise having an impact on the
performance or outcome of any program. “Materially affect” also includes making or
influencing any procurement decision.
2.
ASFIs will be collected from all subcontractors and consultants prior to contract award
or renewal through collaboration with the subcontractor company.
3.
ASFIs will also be updated and reviewed whenever an individual will participate in a
Government Source Selection, sign an NDA, or enter into an off-contract agreement.
C. The TCO will review the ASFI forms for compliance with A-56, A-14, and any potential
Intellectual Property Concerns that may be present. If a potentially conflicting financial interest is
identified, the Assistant Laboratory Ethics Officer will identify and resolve the situation per Part V of this
procedure. An overview of the ASFI review process is provided in Appendix 1 of this procedure.
D. The U.S. Office of Government Ethics (OGE) has set thresholds for when certain financial
holdings of an individual (including their spouse and dependent children) must be disclosed, and when
they create a COI that would prohibit participation in activities that could have a material effect on a
program or procurement. These thresholds are incorporated in the Laboratory’s Prime contract and are as
follows:
1.
Publicly Traded Stocks and Bonds. Holdings valued at over $15,000 must be disclosed
and can create a COI.
2.
Privately Held Stocks or Bonds. Any holding, at any amount (including negative
equity), must be disclosed and has potential to create a conflict.
3.
Publicly Traded Widely Held Diversified Mutual Funds. These are mutual funds that
do not have a stated policy of concentrating its investments in one industry, business, or
single country other than the United States. They do not have to be reported and do not
have the potential to cause a COI at any amount.
4.
Sector Mutual Funds. Holdings valued at over $50,000 must be disclosed and can
create a COI. These are mutual funds that concentrate its investments in an industry,
business, single country other than the United States, or bonds of a single state within
the United States. Holdings valued at less than $50,000 do not create a conflict.
5.
Questions regarding reporting or thresholds, or asset categories should be directed to
the TCO.
E. A Cautionary Letter will be issued for assets or positions that do not presently cause a COI
but could create one if the facts of the matter change. The letter is not intended to be disciplinary and does
not require divestiture or reassignment. Its function is to serve as a reminder of the relevant procedures
and as documentation that the individual was given notice.
1.
Example. If a Laboratory staff member has a large investment in Company ABC, who
is a DoD contractor, but ABC is not involved in any of the programs that the staff
member supports, he or she would receive a Cautionary Letter because there is no
present or perceived COI.
A-56
F.
VII.
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Special Considerations for Laboratory Support of Sponsor Source Selections
1.
The Laboratory supports Government sponsor source selections by assigning technical
staff to advise the source selection, assist with the drafting of requirements, and prepare
solicitation documents among other technical activities.
2.
As any source-selection support can directly affect a procurement, the Laboratory must
take special care that its employees, subcontractors, and staff are free from any COIs.
Any individual participating in activities for a U.S. Government source selection must
submit an updated ASFI.
3.
Before anyone can participate in a Government source selection, the cognizant Group
Leader will support a TCO review for COI, and a recommendation through the TCO
will be provided to the Division Head for approval/disapproval. Participation as a
voting member on a Government Source-Selection Board requires approval by the
Laboratory Director. In the case of subcontractors or consultants, participation in a
source selection is generally not permitted and must be approved by the Division Head
and the Director’s Office.
CONFLICT OF INTEREST DISCLOSURE PROCEDURES
A.
B.
Disclosure to the Laboratory
1.
Consistent with the terms of the Laboratory’s FFRDC contract, Laboratory staff must
disclose conflicts quickly and fully to Laboratory management, as well as any situation
that has the potential to create a COI or be viewed by others (including other
Laboratory staff, Government sponsors, technical collaborators, suppliers,
subcontractors, or the public at large) as creating a COI or the appearance of
impropriety.
2.
Depending upon the particular facts unique to each situation, appropriate actions must
be taken by Laboratory management in coordination with the affected Laboratory Staff
if an appearance of impropriety or actual COI exists. The staff member involved in the
conflict situation must report any conflicts and work cooperatively with his/her
manager, the TCO, and the LEO to achieve a resolution of the conflict issue that serves
the best interests of the Laboratory in its capacity as an FFRDC.
Disclosure to the Sponsor
1.
VIII.
Conflict of Interest
The prime contract requires the Laboratory to disclose all verified COI situations to the
cognizant Contracting Officer along with the proposed resolution. At the close of each
calendar year, the TCO will prepare a report for the Contracting Officer, detailing all
verified COIs and their resolutions.
TRAINING REQUIREMENTS
A. All new Laboratory personnel will receive a COI orientation briefing from the TCO during
the newcomers program or will complete the online ethics training within 30 days of commencing
employment.
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Conflict of Interest
B. All Laboratory staff are required, on an annual basis, to successfully complete substantive
Annual Ethics and Compliance Training, either in person from the TCO or via the Laboratory’s online
ethics training module.
C. All Subcontractors are required to complete Laboratory online COI training on an annual
basis. In the case of consultants and resident research subcontracts, the training should be taken if the
contract effort exceeds fifty-two (52) days per year. This training is supplemental and is not a substitute
for training by the employing company. (See Administrative Procedure A-20, Guidelines for Contracted
Labor).
KJL:dag
Distribution: All Personnel
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Conflict of Interest
APPENDIX 1
TCO ASFI REVIEW OVERVIEW
Assets Listed Contain
No Conflict Based on
Disclosure
Examples
Entities that are not MIT
LL, DoD, or other USG
Agency Contractors, and
do not operate in one of
Lincoln's functional areas
Initial Review
TCO Reviews and Signs Report
Subsequent Review
Final Review
None
None
Entities that do significant TCO Reviews and Signs Report None
business with the DOD or
USG, in areas unrelated to May follow up with individual or
present MIT LL work
may issue cautionary letter as
appropriate
Ex. GE, Kraft, Exxon, etc
None
Entities that do business
with the DOD or USG, in
Lincoln's functional areas
After Consultation with Division,
TCO will either:
Ex. McDonalds, Wal-Mart,
Hershey, etc.
DoD Contractor
Not Related to
Lincoln's Functional
Areas
DoD Contractor
Related to Lincoln's
Functional Areas
TCO Follows up with individual
regarding duties and asset(s)
Ex. Boeing, G-D, Raytheon,
etc.
If individual or group does not
have duties which involve
contractor, and no conflict is
apparent, issue cautionary letter
and Sign Report
If questions remain, provide
name/question to Division
Entities that do business
with Lincoln Laboratory
Lincoln Lab
Subcontractor
TCO Follows up with individual
regarding duties and asset(s)
Ex. Agilent, Quantech,
Apex, Dell, Lockheed, etc.
If individual or group does not
have duties which involve
contractor, and no conflict is
apparent, issue cautionary letter
and Sign Report
If questions remain, provide
name/question to Division.
Other Entities in
Lincoln Laboratory's
Functional Area
Entities that are scientific TCO Follows up with individual
or technical, but not
regarding duties and asset(s)
Lincoln, DoD, or other USG
agency contractors
If individual or group does not
have duties which involve
contractor, and no conflict is
apparent, issue cautionary letter
and Sign Report
Ex. Apple, Google, etc.
If questions remain, provide
name/question to Division.
1. Sign report
2. Request employee divestiture
and/or reassignment
3. Issue cautionary letter, or
4. Forward to Directors Office
After Consultation with Division,
TCO will either:
1. Sign report
2. Request employee divestiture
and/or reassignment
3. Issue cautionary letter, or
4. Forward to Directors Office
After Consultation with Division,
TCO will either:
1. Sign report
2. Request employee divestiture
and/or reassignment
3. Issue cautionary letter, or
4. Forward to Directors Office
Note: These categories are not mutually exclusive; it is possible for one company to be designated as more than one type for analysis purposes.