POST-GOVERNMENT EMPLOYMENT REPORTING POLICY

INFORMATION AND OVERVIEW

Current and former federal government employees (i.e., military officers, enlisted personnel, and civilians) seeking employment with Sabel Systems Technology Solutions, LLC ("Sabel Systems" or the "Company") who have participated personally and substantially (e.g., gave advice, made decisions and/or recommendations) in matters (i.e., procurement, contracts, task-orders, source selection and/or asset sales) that have had a direct and predictable effect on Sabel Systems' financial interests fall into one of two (2) categories listed below:

  1. You fall outside one of the five (5) "Bans and Restrictions" listed below and can provide Sabel Systems with an ethics letter indicating approval from the Designated Agency Ethics Officer (DAEO) or,

  2. You fall within one of the five (5) "Bans and Restrictions" listed below and are unable to obtain DAEO approval. If this second category applies to you, kindly reject further discussions surrounding possible employment with Sabel Systems until approval is obtained from the DAEO.

Enlisted personnel on terminal leave, regardless of personal and substantial participation in any matter (see first paragraph 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, your ethics letter along with where you fall in one of the five (5) "Bans and Restrictions" listed below, must be submitted to Recruiting@SabelSystems.com. The Talent Acquisition Team will confer with the Human Resources Department and legal counsel for approval and further consideration.

BANS AND RESTRICTIONS

  1. Lifetime Representation Ban 18 U.S.C 207 (a)(1)
    Q: Are you a current/former federal government employee who has participated personally and substantially in matters on a contract affiliated with Sabel Systems?
    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 federal government civilians but not enlisted personnel. "Lifetime" refers to the life of the contract.

  2. Two-Year Representation Ban 18 U.S.C 207 (a)(2)
    Q: Are you a current/former federal government employee who has/had a contract awarded or administered under your official responsibility during your last year as a federal government employee?
    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 federal government civilians but not enlisted personnel.

  3. 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.

  4. One-Year Compensation Ban 41 USC 423 (d)
    Q: Are you a current/federal government employee who made decisions in any particular matter on contracts affiliated with Sabel Systems 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 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.

  5. Terminal Leave
    Q: Are you in the military and on terminal leave?
    A: You may be employed by Sabel Systems while on terminal leave as long as the following conditions are met: 1) You have obtained approval from the DAEO 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 3) you may not interact, appear or perform work in a federal workplace or government facility during your terminal leave period. Note: Condition (2) above does not apply to enlisted military personnel or non-commissioned military officers.