Policies

Procurement Integrity & Information Handling

KDM Consortium policies governing organizational conflicts of interest, procurement integrity, and information handling.

Organizational Conflicts of Interest (OCI)

Policy Statement

KDM & Associates is committed to identifying, mitigating, and disclosing any organizational conflicts of interest that may arise in the course of its operations. KDM does not simultaneously represent conflicting interests in the same procurement.

Mitigation Measures

When a potential OCI is identified, KDM will: (1) promptly disclose the conflict to the affected parties, (2) implement mitigation measures such as firewalls or recusal, (3) decline the engagement if the conflict cannot be adequately mitigated, and (4) document the conflict and resolution.

Member Obligations

KDM Consortium members are responsible for disclosing any actual or potential OCI to KDM and to relevant contracting officers. Members must not use non-public information obtained from a government source for private gain.

Procurement Integrity

Standards of Conduct

KDM and its consortium members adhere to the procurement integrity standards established by 41 U.S.C. Chapter 21 and FAR Subpart 3.1. KDM does not solicit, accept, or use source selection information or contractor bid or proposal information obtained from a government source.

Prohibited Activities

KDM and its members must not: (1) obtain or use non-public source selection information, (2) engage in unauthorized discussions with government personnel regarding pending procurements, (3) offer or accept gratuities to or from government personnel, or (4) engage in any activity that creates an unfair competitive advantage.

Reporting Requirements

Any suspected violation of procurement integrity standards must be reported immediately to KDM leadership and, where appropriate, to the relevant agency Inspector General or contracting officer.

Information Handling & Data Security

Platform Classification

The KDM platform is a private-sector commercial platform. It is not authorized to store, process, or transmit classified information, Controlled Unclassified Information (CUI), export-controlled technical data, source-selection information, or procurement-sensitive information.

Prohibited Uploads

Users must not upload: classified information of any kind, CUI, export-controlled technical data subject to ITAR or EAR, source-selection information, non-public procurement-sensitive information, proprietary proposal information belonging to other companies, or any data requiring handling controls beyond the platform's security posture.

User Responsibility

Users are solely responsible for ensuring all uploaded information is appropriately cleared for commercial-platform use. KDM reserves the right to remove any content that appears to violate these restrictions. KDM does not assume liability for improper uploads by users.

Compliance & Enforcement

Member Agreement

All KDM Consortium members agree to abide by these policies as a condition of membership. Violations may result in suspension or termination of membership and removal from the consortium.

Government Cooperation

KDM cooperates fully with government investigations and audits. KDM will report known or suspected violations of federal procurement law to appropriate authorities.

Policy Updates

These policies are reviewed annually and updated as needed to reflect changes in applicable laws, regulations, and best practices. Members will be notified of material changes.

These policies are provided for informational purposes and do 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 for compliance guidance specific to their circumstances.