NNS Supplier And Ethics Compliance

The terms and conditions of all NNS contracts provide requirements regarding ethics and compliance including for DoD contracts flowdown of FAR and DFAR clauses on this topic. NNS expects suppliers to have management systems in place to support compliance with laws, regulations, and the expectations related to or addressed expressly within the Supplier Code of Conduct.

To assist suppliers in having a robust ethics and compliance plan, Newport News Shipbuilding (NNS) is providing the following tools that can be used as reference material and/or starting point for your own comparable documents. You are free to use and update these documents to support your program

Please click the links to access the content described below:

DoD Hotline Poster – DoD Instruction 7050.01, “DoD Hotline Program,” December 17, 2007, outlines the requirement to publicize the DoD Hotline Program and encourage the DoD community to identify and report suspected fraud, waste and mismanagement in DoD programs and operations. The different poster styles, along with informative brochures and business cards, can be used to assist with your unit’s or agency’s fraud prevention programs.
DoD Whistleblower Poster – The Defense Contractors and Subcontracts have Whistleblower Rights. A Reprisal compliant can filed with the DoD Hotline or HII Openline.
Other DoD Hotline Resources
Example of a Mandatory Disclosure Procedure – This template is for reference only and to be used at the consumer’s own risk. This template is a policy designed to establish the process by which a company will comply with the Mandatory Disclosure requirements established by the Federal Acquisition Regulation (FAR)
Example of a Case Management Procedure – This template is for reference only and to be used at the consumer’s own risk. This template is a guide that describes the life cycle of the case management process from intake of concerns to the implementation of corrective and/or disciplinary actions.
Example of a Non-Retaliation Procedure – This template is for reference only and to be used at the consumer’s own risk. This template is a policy designed to confirm a company’s commitment to non-retaliation and providing an environment that supports any individual who in good faith seeks advice, raises a concern, or reports perceived or observed misconduct.
Example of a Code of Ethics or Conduct Policy – This template is for reference only and to be used at the consumer’s own risk. A code has value as both an internal guideline and an external statement of corporate values and commitments. This is a guide to developing a code of conduct or ethics.
Example of a Code of Conduct or Ethics – This template is for reference only and to be used at the consumer’s own risk. This template is a document designed to confirm a company’s commitment to conduct business ethically and compliantly and to ensure all ethics and compliance issues are resolved appropriately according to our stated values, Code of Conduct, corporate policies, laws and regulations throughout our operations.
Determining Company Values – This document is for reference only and to be used at the consumer’s own risk. These slides are provided to assist in determining your company’s values which are the foundation of your ethics program.
What every supplier needs to know about Cybersecurity?

DFARS clause 252.246-7007 Contractors Counterfeit Electronic Part Detection and Avoidance System, addresses unlawful or unauthorized reproduction, substitution, or alteration that has been knowingly mismarked, misidentified, or otherwise misrepresented to be an authentic, unmodified electronic part from the original manufacturer, or a source with the express written authority of the original manufacturer or current design activity, including an authorized aftermarket manufacturer. Unlawful or unauthorized substitution includes used electronic parts represented as new, or the false identification of grade, serial number, lot number, date code, or performance characteristics. This clause applies to all electronic parts – even commercial items, and down supply chain to electronic parts suppliers.

Due to the risk of receiving Counterfeit Electronic Parts, HII conducts due diligence to detect and avoid any potential acquisition of this unlawful material.

Human trafficking is illegal. It involves actions where the victim is often lured by force, fraud, or coercion to compel the person into a situation of sexual exploitation; labor without compensation, which could include forced or bonded labor; or participation in other unlawful activities.
The United States Government has adopted a zero-tolerance policy that prohibits contractors and contractor employees from engaging in or supporting severe forms of trafficking in persons, procurement of commercial sex acts, or the use of forced labor both domestically and abroad.
To that end, HII prohibits its employees and contract labor that directly support contracts containing the FAR Clause 52-222.50 from engaging in activities that support or promote illegal trafficking in persons such as:

Severe forms of trafficking in persons, including:

Sex trafficking in which a commercial sex act is induced by force, fraud, or coercion, or in which the person induced to perform such act has not attained 18 years of age
Recruitment, harboring, transportation, provision, or obtaining of a person for labor or services through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, debt bondage, or slavery
Procurement of a commercial sex act, i.e., any sex act where anything of value is given to or received by any person
Use of forced labor in the performance of company business

Those involved in such activity will be subject to disciplinary action including, but not limited to, removal from the customer’s contract or termination of employment.

Additional Human Trafficking Resources:

Cybersecurity promotes effective security strategies while adapting to the challenges of increasing external threats and vulnerabilities. HII promotes cybersecurity as a collaborative effort of all personnel and company organizations with access to information assets and information networks.

The new DFARS clause 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting, must be included in all new Department of Defense (DoD) prime contracts, including contracts for commercial items. The contract clause must also be flowed down to all subcontractors regardless of size and to all tiers of the DoD supply chain.

Key definitions defined by DFARS 252.204-7012:

“Covered contractor information system” means an information system that is owned, or operated by or for, a contractor and that processes, stores, or transmits covered defense information.
“Controlled technical information” means technical information with military or space application that is subject to controls on the access, use, reproduction, modification, performance, display, release, disclosure, or dissemination. Controlled technical information would meet the criteria, if disseminated, for distribution statements B through F using the criteria set forth in DoD Instruction 5230.24, Distribution Statements on Technical Documents. The term does not include information that is lawfully publicly available without restrictions.
“Cyber incident” means actions taken through the use of computer networks that result in an actual or potentially adverse effect on an information system and/or the information residing therein.

The new clause contains two principal requirements that apply to all contractors at every tier:

Implement adequate security measures to safeguard unclassified controlled technical information within contractor information systems from unauthorized access and disclosure
Report cyber incidents within 72 hours of the event

We encourage you to begin the process necessary to assess your information system security so that you will be prepared to certify your compliance with the clause when you respond to a future procurement solicitation or submit the annual certifications and representations.

On August 22, 2012, the U.S. Securities and Exchange Commission (“SEC”) adopted final rules implementing Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. These rules impose disclosure and due diligence requirements on publicly-traded companies that manufacture products containing certain minerals designated as “conflict minerals”: gold, columbite-tantalite (coltan), cassiterite, wolframite, and their derivatives, tantalum, tin and tungsten, that have been mined or smelted in the Democratic Republic of the Congo (the “DRC”), Republic of Congo, Angola, Burundi, Central African Republic, Rwanda, South Sudan, Tanzania, Uganda or Zambia.

As a result of these rules, HII is required to conduct due diligence inquiries of its supply chain regarding conflict minerals that are included in any products, materials or supplies that are delivered to HII after, and were not “outside of the conflicts minerals supply chain” prior to, January 31, 2013.

Reference Materials

Conflict Minerals Frequently Asked Questions (FAQs) (Nov 4, 2014)

Supplier Notification Letter (Jan 2, 2013)

Forms

Conflict Minerals Reporting Template

NNS Supplier And Ethics Compliance

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Reference Materials

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