Sine Cera maintains a FAR-compliant organizational and personal conflict of interest prevention program to avoid even an appearance of personal or organizational conflict. Sine Cera screens employees for actual and potential personal conflicts, obtaining and maintaining for each employee a disclosure of interests that might be affected by the work the employee performs. We update disclosures of interests and Non-Disclosure Agreements annually and when assigned to new efforts. Unless effectively mitigated as determined by the contracting officer, Sine Cera will not assign an employee any task under a contract for which a personal conflict of interest has been identified. Sine Cera maintains a log of supported organizations, services provided, and the staff supporting each task, including the applicable non-disclosure agreements, and reviews this log as a routine element of our bid/no bid decisions and teaming agreement decisions.


Avoiding Conflicts of Interest

The Sine Cera Code of Ethics

Procurement integrity is more than personal integrity. It is a process that is sound, complete, built with a sincere interest in quality work, statutory and regulatory compliance, and expert judgment. It’s a commitment to meeting the requirement using proven processes and best practices that can withstand scrutiny – with no wax or cracks.  To this end, Sine Cera’s members pledge and recertify annually to the following ethical code:

  • I will demand excellence from myself, my colleagues, and from our work products. If it’s worth doing, it’s worth doing my best the first time, on time.
  • I will conduct myself in a professional manner that builds and maintains confidence in my expertise, Sine Cera, and the integrity of the procurement process.
  • I will avoid every entanglement that may create or appear to create a personal or organizational conflict of interest, or otherwise impair or impede my ability to provide impartial judgment.
  • I will comply with all laws and regulations that govern the acquisition process to the best of my knowledge and ability.
  • I will never disclose procurement sensitive information or attempt to profit from the sensitive information I access in the performance of my duties.
  • I will remain informed and current on changes in acquisition policy, statute, and regulation that inform the performance of my duties and my profession.
  • I will give sound acquisition advice and support to my clients. I will not cut corners or mince words. My input will be professional, but always direct.

Sine Cera Consulting has an established pool of Federal and Defense financial management, acquisition, contracting, strategic communications, and information security experts available to support your needs. Examples include:

DoD Acquisition Support:  Sine Cera currently assists an office within the Under Secretary of Defense, Acquisition Technology and Logistics, with its Planning, Programming, Budgeting, and Execution functions, Acquisition Strategies, and Acquisition Plans for a $20 million (annually) program comprising multiple contracts. Sine Cera also helps prepare Performance Work Statements, Quality Control and Quality Assurance Surveillance Plans, and Work Breakdown Structures.

Market Research:  Sine Cera performed market research for a Defense Health Agency acquisition supporting a multi-billion dollar managed care procurement, researching commercial best practices and performance standards, identifying significant differences between commercial healthcare and military managed care support.

Procurement Policy:  Sine Cera supported the drafting of a Federal Agency's Acquisition Manual, documenting its policies and procedures compliant with the Federal Acquisition Regulation.

Consulting Services:  When a US firm's commercial items status was challenged by the Defense Contract Management Agency, Sine Cera drafted the firm's appeal to its US Senator for assistance and to the Under Secretary of Defense for Acquisition, Logistics, and Technology for relief; the commercial items determination was decided in favor of the firm.

Congressional Testimony Preparation: Sine Cera staff have prepared several DoD officials for more than a dozen appearances before Congressional Committees and Commissions on some of the DoD’s most complex contracting issues including the accidental, wartime exposure of Servicemembers and Civilian Contractors to hazardous industrial chemicals in Iraq.