At I-2-I Solutions, we are dedicated to protecting sensitive information and upholding the highest cybersecurity standards. Our certification under the Cybersecurity Maturity Model Certification (CMMC) Level 1 reflects our proactive approach to safeguarding Federal Contract Information (FCI). Additionally, by adhering to the NIST SP 800-171 framework, we ensure that our security practices meet the stringent requirements set by federal guidelines. With these certifications, we demonstrate our unwavering commitment to data protection and reliability as a trusted partner for government and defense agencies.
Certifications
Cyber Security compliance
Code of Ethics
SCOPE
This Business Ethics & Code of Conduct (“Code”) applies to employees, subcontractors, subcontractor employees and agents of I-2-I Solutions, Inc, (hereinafter referenced as "I-2-I Solutions") and the I-2-I Solutions company office performing work under a federal contract subject to Federal Acquisition Regulation (hereafter “FAR”) 52.203-13 – Contractor Code of Business Ethics and Conduct.
POLICY
This Code sets forth I-2-I Solutions expectations and standards of its employees, subcontractors, subcontractor employees, and agents as well as its compliance plan in compliance with FAR 52.203-13. This policy and plan are consistent with the I-2-I Solutions core values of practicing respect for all people and conducting ourselves in an ethical, lawful manner.
Local and Foreign Laws
I-2-I Solutions, nor anyone acting on behalf of I-2-I Solutions, may, directly or indirectly, break or seek to evade the laws or regulations of any country in, though, or with which I-2-I Solutions seeks to do business. That an illegal act is a “customary business practice” in any country is not sufficient justification for violation of this provision.Bribery and Facilitating Payments
Bribery includes any offer, promise, or gift of any pecuniary or other advantage, whether directly or through intermediaries, to a public official, political party, political candidate or party official or any private sector employee, in order that the official or employee act or refrain from acting in relation to the performance of their duties, in order to obtain or retain business or other business advantage.I-2-I Solutions recognizes that extortion is widespread and that participation by the business community increases demand for facilitating payments.
I-2-I Solutions, nor anyone acting on behalf of I-2-I Solutions, shall offer or make facilitating payments to government officials in order to encourage them to expedite a routine governmental task that they are otherwise required to undertake. I-2-I Solutions, or anyone acting on behalf of I-2-I Solutions, shall have discretion to deviate from this prohibition if he/she believes that there is an immediate threat to his/her or another’s health or safety. The circumstances of such payment must be reported as soon as possible after the event and the payment properly recorded.
I-2-I Solutions, nor anyone acting on behalf of I-2-I Solutions, may, directly or indirectly, offer or provide a bribe, and all demands for bribes must be expressly rejected.
- Kick-Backs
A “kickback” is a particular form of bribe which takes place when a person entrusted by an employer or public function has some responsibility for the granting of a benefit and does so in a way that secures a return (kickback) of some of the value of that transaction or benefit for that person without the knowledge or authorization of the employer or public body to which the person is accountable.I-2-I Solutions, nor anyone acting on behalf of I-2-I Solutions, may offer or accept a “kick-back” of any portion of a contract payment to employees of other parties to a contract or use other vehicles such as subcontracts, purchase orders or consulting agreements to channel payments to government officials, political candidates, employees of other parties to a contract, their relatives or business associates.
Conflicts of Interest
I-2-I Solutions, and anyone acting on behalf of I-2-I Solutions, shall avoid any relationship or activity that might impair, or appear to impair, the ability to render objective and appropriate business decisions in the performance of our jobs.Political Contributions
I-2-I Solutions, nor anyone acting on behalf of I-2-I Solutions, may make a political contribution in order to obtain an unlawful business advantage. I-2-I Solutions shall comply with all public disclosure requirements.Philanthropic Contributions
I-2-I Solutions, and anyone acting on behalf of I-2-I Solutions, may make contributions only for bona fide charitable purposes and only where permitted by the laws of the country in which the contribution is made. Contributions made in order to obtain an unlawful business advantage are prohibited.Extortion
I-2-I Solutions, and anyone acting on behalf of I-2-I Solutions, shall reject any direct or indirect request by a public official, political party, party official, or private sector employee for undue pecuniary or other advantage, to act or refrain from acting in relation to his or her duties.Gifts, Hospitality, and Entertainment
I-2-I Solutions, and anyone acting on behalf of I-2-I Solutions, shall avoid the offer or receipt of gifts, meals, entertainment, hospitality or payment of expenses whenever these could materially affect the outcome of business transactions, are not reasonable and bona fide expenditures, or are in violation of the laws of the country of the recipient.
DISCIPLINARY ACTION
I-2-I Solutions will take appropriate action against employees, subcontractors, subcontractor employees and agents that violate this Code, which action may include, but is not limited to, the following, as applicable:
- Removal of employees from the contract, or requiring the subcontractor to remove a subcontractor employee or employees from the contract;
- Reduction in employee benefits;
- Termination of employment;
- Declining to exercise available options under the contract;
- Termination of the contract for default or cause, in accordance with the termination clause of the contract, or requiring the subcontractor to terminate a contract; or
- Termination of the business relationship with the subcontractor.
COMPLIANCE PLAN
I-2-I Solutions has established the following compliance plan in compliance:
A) Awareness Program
I-2-I Solutions distributes this Code to employees performing work under a federal contract subject to FAR 52.203-13. This Code is available publicly to all I-2-I Solutions employees, subcontractors, subcontractor employees and agents. Copies of this Code can be requested by emailing
B. Grievance Mechanism
I-2-I Solutions personnel, subcontractors, subcontractor employees and agents are required to report any violations of or activity inconsistent with this Code and may do so without fear of retaliation and subject to employee protection, if applicable. Reports should be made to Human Resources by email
E-Verify
This Organization Participates in E-Verify
This employer participates in E-Verify and will provide the federal government with your Form I-9 information to confirm that you are authorized to work in the U.S.
If E-Verify cannot confirm that you are authorized to work, this employer is required to give you written instructions and an opportunity to contact Department of Homeland Security (DHS) or Social Security Administration (SSA) so you can begin to resolve the issue before the employer can take any action against you, including terminating your employment.
Employers can only use E-Verify once you have accepted a job offer and completed the Form I-9.
E-Verify Works for Everyone
For more information on E-Verify, or if you believe that your employer has violated its E-Verify responsibilities, please contact DHS.
CTIPs (Combatting Trafficking In Persons plan)
SCOPE
This Combating Trafficking in Persons Policy and Compliance Plan (“Policy and Plan”) applies to employees, subcontractors, subcontractor employees and agents of I-2-I Solutions, Inc, (hereinafter referenced as "I-2-I Solutions") and the I-2-I Solutions company office performing work under a federal contract subject to Federal Acquisition Regulation (hereafter “FAR”) 52.222-50 -- Combating Trafficking in Persons and/or Defense Federal Acquisition Regulation Supplement (hereafter “DFARS”) 252.203-7004 -- Display of Hotline Posters, and/or 252.225-7040 -- Contractor Personnel Supporting U.S. Armed Forces Deployed Outside the United States, in each case as applicable.
POLICY
This Policy and Plan sets forth I-2-I Solutions' policy against trafficking in persons and in trafficking in persons compliance plan in compliance with FAR 52.222-50. This policy and plan are consistent with the I-2-I Solutions Code of Ethics & Business Conduct and I-2-I Solutions' core values of practicing respect for all people and conducting ourselves in an ethical, lawful manner.
I-2-I Solutions is opposed to all forms of human trafficking, slavery, servitude, forced or compulsory labor and all other trafficking-related activities. I-2-I Solutions is committed to (a) fully complying with all applicable labor and employment laws, rules and regulations and (b) working to mitigate the risk of human trafficking in our business and supply chains.
The United States has long had a policy prohibiting government employees and contractor personnel from engaging in trafficking in persons activities, including severe forms of trafficking in persons. The FAR prohibits federal contractors and subcontractors from engaging in prohibited practices such as destroying, concealing, confiscating, or otherwise denying access by an employee to his or her identity or immigration documents; using misleading or fraudulent recruitment practices; charging employees recruitment fees; and providing or arranging housing that fails to meet the host country housing and safety standards. I-2-I Solutions complies with, and requires that its employees, subcontractors, subcontractor employees and agents to comply with, FAR 52.222-50, which can be accessed at http://www.acquisition.gov. I-2-I Solutions employees, subcontractors, subcontractor employees and agents (a) shall fully comply with all applicable labor and employment laws, rules and regulations, and (b) shall not:
- Engage in severe forms of trafficking in persons;
- Procure commercial sex acts;
- Use forced labor;
- Destroy, conceal, confiscate, or otherwise deny access by an employee to the employee’s identity or immigration documents, such as passports or drivers’ licenses, regardless of issuing authority;
- Use misleading or fraudulent practices during the recruitment of employees or offering of employment, such as failing to disclose, in a format and language accessible to the worker, basic information or making material misrepresentations during the recruitment of employees regarding the key terms and conditions of employment, including wages and fringe benefits,
- information or making material misrepresentations during the recruitment of employees regarding the key terms and conditions of employment, including wages and fringe benefits, the location of work, the living conditions, housing and associated costs (if employer or agent provided or arranged), any significant cost to be charged to the employee, and, if applicable, the hazardous nature of the work or use recruiters that do not comply with local labor laws of the country in which the recruiting takes place;
- Charge employees recruitment fees;
- Fail to provide return transportation or pay for the cost of return transportation upon the end of employment: (i) for an employee who is not a national of the country in which the work is taking place and who was brought into that country for the purpose of working on a U.S. Government contract or subcontract (for portions of contracts performed outside the United States); (ii) or for an employee who is not a United States national and who was brought into the United States for the purpose of working on a U.S. Government contract or subcontract, if the payment of such costs is required under existing temporary worker programs or pursuant to a written agreement with the employee (for portions of contracts performed inside the United States); except that:
- The requirements of this paragraph (7) shall not apply to an employee who is legally permitted to remain in the country of employment and who chooses to do so or exempted by an authorized official of the contracting agency from the requirement to provide return transportation or pay for the cost of return transportation; or
- The requirements of this paragraph (7) are modified for a victim of trafficking in persons who is seeking victim services or legal redress in the country of employment, or for a witness in an enforcement action related to trafficking in persons. The contractor shall provide the return transportation or pay the cost of return transportation in a way that does not obstruct the victim services, legal redress, or witness activity. For example, the contractor shall not only offer return transportation to a witness at a time when the witness is still needed to testify. This paragraph does not apply when the exemptions in this paragraph
- (7) apply.
- Provide or arrange housing that fails to meet the host country housing and safety standards or if required by law or contract, fail to provide an employment contract, recruitment agreement, or other required work document in writing. Such written work document shall be in a language the employee understands. If the employee must relocate to perform the work, the work document shall be provided to the employee at least five (5) days prior to the employee relocating. The employee’s work document shall include, but is not limited to, details about work description, wages, prohibition on charging recruitment fees, work location(s), living accommodations and associated costs, time off, roundtrip transportation arrangements, grievance process, and the content of applicable laws and regulations that prohibit trafficking in persons.
DISCIPLINARY ACTION
I-2-I Solutions will take appropriate action against employees, subcontractors, subcontractor employees and agents that violate this Policy and Plan, which action may include, but is not limited to, the following, as applicable:
- Removal of employees from the contract, or requiring the subcontractor to remove a subcontractor employee or employees from the contract;
- Reduction in employee benefits;
- Termination of employment;
- Declining to exercise available options under the contract;
- Termination of the contract for default or cause, in accordance with the termination clause of the contract, or requiring the subcontractor to terminate a contract; or
- Termination of the business relationship with the subcontractor.
COMPLIANCE PLAN
I-2-I Solutions has established the following compliance plan in compliance with FAR 52.222-50(h):
Awareness Program
I-2-I Solutions distributes this Policy and Plan to employees performing work under a federal contract subject to FAR 52.222-50(h). I-2-I Solutions prominently displays the Department of Defense’s Combating Trafficking in Persons Hotline Poster, Fraud Hotline Poster and Whistleblower Protection Hotline Poster, the Department of Homeland Security’s Fraud Hotline Poster, and/or an employee bill of rights, in each case as applicable, in the common work areas within its operating subsidiaries performing work under a federal contract.Grievance Mechanism
I-2-I Solutions personnel, subcontractors, subcontractor employees and agents are required to report any violations of or activity inconsistent with the U.S. Government’s policy prohibiting trafficking in persons set forth in FAR 52.222-50(b), and may do so without fear of retaliation and subject to employee protection, if applicable, under U.S.C. 2409 as implemented in the DFARS subpart 203.9.Recruitment and Wages
I-2-I Solutions prohibits employees, subcontractors, subcontractor employees and agents from:- Using misleading or fraudulent practices during the recruitment of employees or offering of employment, such as failing to disclose, in a format and language accessible to the worker, basic information or making material misrepresentations during the recruitment of employees regarding the key terms and conditions of employment, including wages and fringe benefits, the location of work, the living conditions, housing and associated costs (if employer or agent provided or arranged), any significant cost to be charged to the employee, and, if applicable, the hazardous nature of the work;
- Using recruiters that do not comply with local labor laws of the country in which the recruiting takes place; and
- Charging employees recruitment fees.
I-2-I Solutions only permits the use of recruitment companies that provide proper training to employees, do not charge recruitment fees to employees, and that have established procedures to ensure that wages meet applicable host country legal requirements.I-2-I Solutions' Human Resources Department, in appropriate consultation with Legal Counsel, is tasked with completing periodic, but no less than two annual, audits of all Employees HR and payroll files to check for compliance with local labor laws and Federal regulations. All discrepancies shall be immediately rectified and reported to Senior Management.
I-2-I Solutions requires its subcontractors to develop and make available to I-2-I Solutions staff for review and comment, procedures to ensure compliance with all local labor laws and Federal regulations. I-2-I Solutions requires all subcontractors to agree to periodic audits of payroll records by Human Resources and Legal Counsel to ensure proper wages are being paid. Additionally, subcontractors are required to certify compliance with local labor laws and wages with the submission of each invoice for payment. These requirements shall be incorporated to subcontracts awarded to Subcontractors.
Upon hiring, all I-2-I Solutions employees, subcontractor employees, and employees employed by third- party Agencies must have their HR files reviewed and approved by I-2-I Solutions Human Resource prior to working. During this file review, I-2-I Solutions Human Resources, in consultant with Legal, as appropriate, will ensure that all wages paid are compliant with local labor laws and Federal regulations.
Housing
Typically, I-2-I Solutions does not provide housing as such housing is on a military base in-country, arranged by the US Government. In the event that I-2-I Solutions is required to provide or arrange housing under a US Government contract, such housing will be provided that meets host-country housing and safety standards.Compliance Procedures
In order to prevent agents and subcontractors at any tier and at any dollar value from engaging in trafficking in persons (including the activities identified in the U.S. Government’s policy prohibiting trafficking in persons set forth in FAR 52.222-50(b)) and to monitor, detect, and terminate any agents, subcontracts, or subcontractor employees that have engaged in such activities, I-2-I Solutions requires that its agents and subcontractors performing work under a federal contract subject to FAR 52.222-50(h) complete annually the I-2-I Solutions Combating Trafficking in Persons Due Diligence Representation and Certification. This representation and certification is designed to provide I-2-I Solutions with sufficient information to adequately assess the practices of its agents and subcontractors with respect to combating trafficking in persons compliance. If I-2-I Solutions determines that there is a reasonable risk that an agent or subcontractor has engaged in trafficking in persons (including the activities identified in the U.S. Government’s policy prohibiting trafficking in persons set forth in FAR 52.222-50(b)), or has otherwise violated FAR 52.222-50, I-2-I Solutions will determine and administer disciplinary action in accordance with the terms of this Policy and Plan.Monitoring Procedures
Each I-2-I Solutions project site will have an appointed CTIP Compliance Supervisor. This senior level manager will be responsible for conducting random on site interviews and spot checks to ensure ongoing compliance with local labor laws and regulations. This appointed supervisor along with all mid- and senior- level management are required to complete training by Human Resources on the company’s CTIP Policies, how to identify violations, and the appropriate reporting procedures.Additionally, I-2-I Solutions monitors multiple sources of third party information including international news sources. If adverse information concerning a I-2-I Solutions supplier is discovered, the matter will be investigated and appropriate action taken.I-2-I Solutions relies on the reporting of other project staff (either from within I-2-I Solutions or from other project partners) of any alleged or actual violations of CTIP or other policies. I-2-I Solutions CTIP policy clearly establishes the consequences for violations of its CTIP policy either by employees or sub- awardees.
From time to time I-2-I Solutions Executive Directors, Project Managers, and other personnel may travel to project sites. During such visits they will seek to be vigilant of any indications of possible violations of CTIP or other policies. During site visits, personnel are instructed to interview randomly selected Employees to ensure appropriate compliance. Interviews shall be on-the-spot with randomly selected Employees and shall follow a short questionnaire provided to the traveling personnel by Human Resources and Legal Counsel. All results will be reported to Human Resources and Legal Counsel for review and record keeping. Site visits shall be conducted no less than twice annually.
Process for Reporting Violations
If Legal Counsel anticipates that the event may require reporting under FAR 52.222-50, he or she immediately shall notify: (1) the corporate Vice President & Associate General Counsel – Litigation & Compliance or designee, and (2) the Contracts, Human Resources, and, if the matter involves subcontractors, Global Supply Chain Operations. Legal Counsel, in consultation with Contracts and Global Supply Chain Operations, as applicable, will inform the cognizant Contracting Officer of the allegation, and the corporate Vice President & Associate General Counsel – Litigation & Compliance will inform the cognizant Inspector General of the allegation.Employees may also report, without fear of retaliation, activity inconsistent with the policy prohibiting trafficking in persons to Ethics, Legal Counsel, and the Global Human Trafficking Hotline (1 (888) 373-7888 ) FREE;
This email address is being protected from spambots. You need JavaScript enabled to view it. .Any credible information received from any source (including host country law enforcement) that an employee, subcontractor, subcontractor employee, or agent has violated FAR 52.222-50 must be reported immediately to Legal Counsel. Employees can submit their report via
This email address is being protected from spambots. You need JavaScript enabled to view it. or by calling 804.575.4474 (and ask to speak to Legal).Informing Employees of the Global Human Trafficking Hotline
Upon hiring, all employees of I-2-I Solutions and its subcontractors shall be informed of I-2-I Solutions's CTIP policy. Human Resources should ensure all new team members fully understand their responsibilities under the CTIP policy. Onboarding paperwork will also include a one-pager handout with the contact information of the Global Human Trafficking Hotline (1 (888) 373-7888) FREE;This email address is being protected from spambots. You need JavaScript enabled to view it. .Additionally, a poster containing information about the CTIP policy and the Global Human Trafficking Hotline will be posted in all I-2-I Solutions and subcontractor managed housing. The poster shall be posted in a public space. Additional smaller posters shall be posted inside all restrooms.