Organizational Conflicts of Interest (OCI) Policy
KDM Consortium's framework for identifying, disclosing, mitigating, and avoiding organizational conflicts of interest in all federal procurement activities.
Policy Statement
KDM & Associates and the KDM Consortium are committed to maintaining the highest standards of integrity in federal procurement. We comply with the organizational conflicts of interest requirements set forth in FAR Subpart 9.5 and applicable agency-specific OCI regulations. We do not seek, accept, or use non-public procurement-sensitive information or source-selection information to gain unfair competitive advantage.
All KDM Consortium members, partners, and staff are expected to identify and disclose any actual, potential, or perceived organizational conflict of interest. Failure to disclose a known OCI may result in suspension or removal from the Consortium.
Types of OCI We Screen For
A situation in which a firm, by virtue of its current or prior work, has had access to non-public information regarding a competitor's proposal, pricing, or technical approach that may provide an unfair competitive advantage.
A situation in which a firm's objectivity in performing work for one client could be compromised by its relationship to another client or by its own self-interest.
A situation in which a firm has helped prepare or shape a procurement (e.g., drafting specifications, statements of work, or evaluation criteria) and may later compete for the resulting award.
Mitigation Process
Identification
KDM screens member firms, teaming arrangements, and consulting engagements for potential OCIs before participating in or supporting a procurement opportunity.
Disclosure
KDM requires full disclosure of any actual, potential, or perceived OCI to the relevant contracting officer, client, or teaming partner as soon as it is identified.
Mitigation
Where an OCI is identified, KDM implements mitigation measures including but not limited to: firewalls, access restrictions, recusal from specific procurement activities, withdrawal from teaming arrangements, or declining to support the affected procurement.
Avoidance
In cases where mitigation is not feasible or sufficient, KDM will decline the engagement or opportunity to avoid the conflict entirely.
All KDM Consortium members are required to:
- • Disclose any current or prior engagements that could create an OCI with a procurement opportunity they seek through the Consortium.
- • Refrain from using non-public information obtained through prior work to gain advantage in a competing procurement.
- • Notify KDM immediately upon becoming aware of a potential OCI.
- • Cooperate with KDM's OCI screening and mitigation processes.
- • Comply with any mitigation plan developed, including firewalls, recusals, or withdrawal from affected procurements.
This policy is provided for informational purposes and does not constitute legal advice. KDM & Associates is a private-sector firm and is not affiliated with, endorsed by, or sponsored by any government agency. Members should consult their own legal counsel regarding OCI compliance in specific procurement matters. For questions about this policy, contact legal@kdm-assoc.com.