Current and Post-Government Employment Reporting Policy
Current and Post-Government Employment Reporting Policy
Applicability
Current and former federal government employees (military officers, enlisted personnel, and civilians) seeking employment with Sabel Systems, LLC that have participated personally and substantially (gave advice and made decisions and recommendations) in any particular matter (procurement, contracts, task-orders, source selection and asset sales) that has a direct and predictable effect on Sabel Systems' financial interest fall in one of two categories:
- You fall outside of the "Bans and Restrictions" below and can provide Sabel Systems an ethics letter indicating approval from the Designated Agency Ethics Officer (DAEO) or,
- You still fall within the "Bans and Restrictions" listed below and/or are unable to obtain DAEO approval. Kindly reject further discussion surrounding employment until approval is obtained by the DAEO.
Enlisted personnel on terminal leave regardless of personal and substantial participation in any particular matter (as listed above), must provide Sabel Systems with an ethics letter indicating approval from the DAEO.
To continue with Sabel Systems' recruitment process, once DAEO approval is obtained, the ethics letter along with where you fall in the "Bans and Restrictions" below should be submitted to [email address removed] who will work with HR and legal counsel for approval and further consideration, as appropriate.
Bans and Restrictions
The Lifetime Representation Ban 18 U.S.C 207 (a)(1)
Q: Are you a current/former federal government employee who has participated in personal and substantial matters on a contract?
A: You may work for Sabel Systems; however, may never act as a negotiator or representative before any federal agency on that contract. This ban applies to military officers and civilians but not enlisted personnel. "Lifetime" refers to the life of the contract.
The Two-Year Representation Ban 18 U.S.C 207 (a)(2)
Q: Are you a current/former government employee who has/had a contract under your official responsibility during your last year in the government?
A: You may work for Sabel Systems; however, may not work as a negotiator or representative before any federal agency on that contract for at least two (2) years. This ban applies to military officers and civilians but not enlisted personnel.
The One-Year No Contact Rule 18 U.S.C 207 (c)
Q: Are you a current/former senior federal government employee?
A: You may not, for one (1) year, communicate with, or appear before, any employee of your former agency on behalf of Sabel Systems in connection with any matter on which Sabel Systems seeks official action by your former agency. This ban applies to General/Flag Officers (O-7 to O-10), Senior Executive Employee (SES) at levels 5 and 6 and SES equivalent employees.
The One-Year Compensation Ban 41 USC 423 (d)
Q: Are you a current/federal government employee who made decisions on a contract(s) over $10M?
A: The one (1) year ban refers to accepting compensation from Sabel Systems as a W2 employee or independent consultant (1099). You may not accept compensation from Sabel Systems for one (1) year from the date of last service or decision if you served in the following positions: Procuring Contracting Officers, Source Selection Authority, Members of the Source Selection Evaluation Board, Chief of Financial or Technical Evaluation Teams, Program or Deputy Program Managers, and Administrative Contracting Officers.
Terminal Leave
Q: Are you in the military and on terminal leave?
A: You may be hired while on terminal leave as long as the following conditions are met: 1) You have obtained approval from the DAEO (ethics letter) and 2) if you are a commissioned military officer, you may not represent, communicate or appear on behalf of Sabel Systems or otherwise act as an agent for Sabel Systems, before any government agency or official with respect to any matter, regardless of prior involvement therein, until after your final separation date, and 1 you may not interact, appear or perform work in a federal workplace or government facility during their terminal leave period. Condition (2) above does not apply to enlisted military personnel or non-commissioned military officers