2022 Code of Ethics | Page 39

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HIRING OF GOVERNMENT & FORMER GOVERNMENT EMPLOYEES
Special restrictions apply to hiring or retaining a government or former government employee as an employee or consultant . In addition , various laws create post-employment restrictions that may limit the type of work that the government employee can perform for certain periods of time , particularly for matters in which they were personally and substantially involved or that involved agencies where they had held senior positions .
BBNC will not discuss potential employment or business opportunities wit any procurement official connected to a contract for which a bid has been submitted or a contract awarded . In order to be sure that you do not run afoul of restrictions in this area , before discussing potential BBNC employment with any government employee , contact the BBNC Compliance Department .
Written authorization from the BBNC Compliance Department must be obtained before even mentioning proposed employment to current or recently separated government employees , and only after they have publicly announced that they are leaving government service .
In addition , any plans to employ retired military officers of general or flag rank , or civilian officials having the rank of Deputy Assistant Secretary or above , must be approved by the BBNC President and CEO or the respective subsidiary company group President and CEO prior to an offer of employment .
BBNC Code of Ethics | Ethics Hotline : 1.866.513.7078 | August 5 , 2022 | info . bbnc . net
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Hiring Government Employees
Q : I would like to hire a current or former government employee . What precautions should I take before discussing potential employment with a current or former government employee ?
A : The first step is to contact the BBNC Compliance Department to discuss what you can and cannot do depending on the specific facts and circumstances . There are restrictions on even discussing possible employment with certain current government employees .
Current and former government employees are also banned from disclosing certain information that they learned during their government employment , and further safeguards / firewalls may need to be put in place so as to avoid BBNC or its subsidiaries from potentially being disqualified from competing for future contracting opportunities .
Some government employees have post-employment or revolving door restrictions on the type of work the can do for specified periods of time after leaving the government .