Purchasing - Compliance

Compliance

The ES3 Purchasing Department complies with the Defense Contract Management Agency (DCMA) Contractor Purchasing System Review (CPSR) requirements.

Combatting Trafficking in Persons

The US Department of Homeland Security has identified that every year millions of people, including children, are trafficked worldwide, including in the US. ES3 takes very seriously our requirement to look for and report any indicators that may suggest forced labor or exploitation. ES3 adheres to Federal Acquisition Regulation (FAR) clause 52.222-50 Combating Trafficking in Persons and flows down this requirement to our suppliers whenever applicable.

Counterfeit Parts

ES3 maintains a counterfeit, counterfeit electronic, fraudulent, and/or suspect part(s) detection and avoidance system. Our system employs a risk-based approach to detection and avoidance that includes: Supplier Screening, Supplier Qualification and Approval, Part Traceability, Inspection and Quarantine, Reporting, and Training. ES3 issued Purchase Orders will contain, as appropriate, such Government clauses as 52.246-26 Reporting Nonconforming items, 252.246-7007 Contractor Counterfeit Electronic Parts Detection and Avoidance System, and 252.246-7008 Sources of Electronic Parts, or others.

Cybersecurity

Improving the cybersecurity resilience of the aerospace and defense industry is a high priority for the US Government and ES3. The National Institute of Standards and Technology (NIST) developed the NIST 800-171 protocol to dictate how contractors and subcontractors doing business with the government should handle Controlled Unclassified Information (CUI). The NIST 800-171 protocols specify security to reduce the risk of insider threats, data breaches, and other cyber related threats. In order to be eligible for award, government contractors were required to demonstrate NIST compliance by November 30, 2020 via submission of a NIST self-assessment completed and uploaded to the Supplier Risk Performance system (SPRS) within the last three years. When the NIST 800-171 DFARs clause 252.204-7020 appears in an ES3 prime contract, we are frequently required to have our subcontractors demonstrate compliance via submission to us of their SPRS screenshot or a copy of their self- assessment. For more information, please visit Privacy Matters.

Executive Compensation

The Federal Funding Accountability and Transparency Act (FFATA) of 2006 ensures that the public can access information on companies and their first-tier suppliers who receive Federal funds. This information includes executive compensation. Section 2(d)(2) of FFATA (Pub. L. 109-282), as amended by section 6202 of the Government Funding Transparency Act of 2008 (Pub. L. 110-252) requires ES3 to collect and report information from those companies to whom ES3 awards subcontracts. The public reporting requirement is accomplished via the prime contractor collecting requisite information in accordance with FAR 52.204-10 from the first- tier supplier and reporting that information via the FFATA Subaward Reporting System (FSRS). On this page, you can download a typical ES3 FFATA form we may require you to complete. As explained on the form, any company that is publicly traded or whose government revenue is either under a particular threshold is exempt from having to disclose any data. However, even if you are exempt from disclosing data, you must still check the appropriate exemption box, sign, and return the form to ES3 so that we will be in compliance with the Government’s reporting requirements.

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