“Procurement Ethics” 

Presented by;Thomas Blaine, CPPO, FCPA

Division DirectorDepartment of Procurement Management

Miami-Dade County

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Values and EthicsValues and Ethics

Values are at the heart of the Values are at the heart of the ethical choices that we make.ethical choices that we make.

When values are in conflict and When values are in conflict and competition, ethical dilemmas competition, ethical dilemmas occur.occur.

Our ethical framework is usually Our ethical framework is usually influenced by the values of our influenced by the values of our family members, our peers, our family members, our peers, our customers, our clients, the public, customers, our clients, the public, vendors, and our organization.vendors, and our organization.

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What happens when there What happens when there is conflict between and is conflict between and among these various among these various

values?values?

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Values Values

Security Fairness Productivity

Advancement Compassion Leadership

Honesty Integrity Efficiency

Advancement Entrepreneurship Reward

Transparency Competition Leadership

Truthfulness Loyalty Respect

Fidelity Community Justice

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Values and PrinciplesValues and Principles

There is a need to distinguish between There is a need to distinguish between values and principles, too often values values and principles, too often values are dressed up as principles.are dressed up as principles.

Principle = a guide to actionPrinciple = a guide to action Value = a preference expressedValue = a preference expressed For public service (and public For public service (and public

procurement) are there universal procurement) are there universal values?values?

Universal principles? Universal principles?

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What is ethics?What is ethics?

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2 a : a set of moral principles or values b : a theory or system of moral values <the present-day materialistic ethic> c plural but

singular or plural in construction : the principles of conduct governing

an individual or a group <professional ethics> d : a guiding

philosophy

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Ethical Principles of Public Ethical Principles of Public ServiceService

five ethical principles of public service:five ethical principles of public service:

– Public trust, objective judgment, Public trust, objective judgment, accountability, democratic leadership, and accountability, democratic leadership, and respectability.respectability.

It is important to understand how It is important to understand how procurement in the public sector imposes procurement in the public sector imposes responsibilities related to the public trust.responsibilities related to the public trust.

Taking these principles from the ‘ideal’ to Taking these principles from the ‘ideal’ to the ‘real’ suggests an awareness that these the ‘real’ suggests an awareness that these principles transcend obligations imposed principles transcend obligations imposed by law and formal codes of conduct.by law and formal codes of conduct.

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The Ethical Dimension: The Ethical Dimension: Values and PrinciplesValues and Principles

Values Principles

Individual HonestyIntegritySecurity

Give first consideration to the objectives and policies of my organization

Professional CompetenceFairness

Conduct business with potential and current suppliers in an atmosphere of good faith

Organizational ProductivityEfficiencyImpartiality

Foster fair, ethical, and legal procurement practices

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An Integrity-based An Integrity-based Approach to Ethics Approach to Ethics

One approach to ethics that is One approach to ethics that is advocated is an integrity-based advocated is an integrity-based approachapproach

How is the word How is the word integrityintegrity defined? defined?

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““possession of firm principles, the possession of firm principles, the quality of possessing and quality of possessing and steadfastly adhering to high moral steadfastly adhering to high moral principles or professional principles or professional standards” (Microsoft Incarta, standards” (Microsoft Incarta, 2001). 2001).

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Integrity ethics attempts to create Integrity ethics attempts to create an awareness of a public service an awareness of a public service ethosethos

Integrity ethics also attempts to Integrity ethics also attempts to create an awareness of ethical create an awareness of ethical standards and valuesstandards and values

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The Public Service The Public Service EthosEthos

An integrity based approach An integrity based approach suggest that there is a “public suggest that there is a “public service ethos.”service ethos.”

EthosEthos– the distinguishing character,

sentiment, moral nature, or guiding beliefs of a person, group, or institution

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What are the values and principles What are the values and principles that make up this ethos?that make up this ethos?

““Public service ethos” is traditionally Public service ethos” is traditionally characterized as comprising honesty, characterized as comprising honesty, integrity, impartiality, recruitment integrity, impartiality, recruitment and promotion on merit, probity*, and promotion on merit, probity*, and accountability. and accountability.

**adherence to the highest principles and ideals

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Have you embraced a “public Have you embraced a “public service ethos” and does it provide service ethos” and does it provide a foundation for the procurement a foundation for the procurement decisions that you make?decisions that you make?

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From ‘Ideal’ to ‘Real’From ‘Ideal’ to ‘Real’ How do you make the transition from How do you make the transition from

the ‘ideal’ to the ‘real’ ? the ‘ideal’ to the ‘real’ ? Moral imagination and reflection are Moral imagination and reflection are

importantimportant From ‘outside in’ to ‘inside out’ is From ‘outside in’ to ‘inside out’ is

importantimportant Developing principle based decision-Developing principle based decision-

making strategies is importantmaking strategies is important

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Consulting resources is importantConsulting resources is important Knowing how to recognize value Knowing how to recognize value

conflicts is importantconflicts is important Knowing how to resolve value Knowing how to resolve value

conflicts is importantconflicts is important

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The ‘Ideal’ has to become The ‘Ideal’ has to become the ‘Real’the ‘Real’

GUIDING PRINCIPLES IN GUIDING PRINCIPLES IN PUBLIC PROCUREMENTPUBLIC PROCUREMENT

1.1. CONFIDENTIALITYCONFIDENTIALITY : Sensitive information : Sensitive information must be kept secure so there is no danger must be kept secure so there is no danger of using such information for personal gain of using such information for personal gain and to eliminate prejudice against fair and to eliminate prejudice against fair competition whether it is deliberate or competition whether it is deliberate or inadvertent.inadvertent.

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• WRITTEN RECORDSWRITTEN RECORDS: In order to : In order to ensure and demonstrate that ensure and demonstrate that ethical standards are practiced and ethical standards are practiced and observed, it is essential that observed, it is essential that records are kept in writing, which records are kept in writing, which serve as evidence of a reason for serve as evidence of a reason for making a particular decision and as making a particular decision and as an audit trial.an audit trial.

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• FAIR DEALINGFAIR DEALING: Obligation to : Obligation to suppliers, contractors, vendors that suppliers, contractors, vendors that you must be honest, fair and even-you must be honest, fair and even-handed.handed.

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• DECLARATION OF INTERESTDECLARATION OF INTEREST: Must : Must ensure that there are no conflicts ensure that there are no conflicts of interest and immediate of interest and immediate disclosures are necessary where disclosures are necessary where impartiality may be affected.impartiality may be affected.

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• HOSPITALITYHOSPITALITY: Modest hospitality is : Modest hospitality is an accepted courtesy of a business an accepted courtesy of a business relationship, but public relationship, but public procurement officials are held to procurement officials are held to the highest of standards, which the highest of standards, which may require rejecting trivial or may require rejecting trivial or inexpensive gifts.inexpensive gifts.

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NIGP CODE OF ETHICSNIGP CODE OF ETHICS

The Institute believes, and it is a condition of The Institute believes, and it is a condition of membership, that the following ethical principles membership, that the following ethical principles should govern the conduct of every person should govern the conduct of every person employed by a public sector procurement or employed by a public sector procurement or materials management organization.materials management organization.

Seeks or accepts a position as head (or Seeks or accepts a position as head (or employee) only when fully in accord with the employee) only when fully in accord with the professional principles applicable thereto and professional principles applicable thereto and when confident of possessing the qualifications when confident of possessing the qualifications to serve under those principles to the advantage to serve under those principles to the advantage of the employing organization.of the employing organization.

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Believes in the dignity and worth of the service Believes in the dignity and worth of the service rendered by the organization, and the societal rendered by the organization, and the societal responsibilities assumed as a trusted public servant.responsibilities assumed as a trusted public servant.

Is governed by the highest ideals of honor and Is governed by the highest ideals of honor and integrity in all public and personal relationships in integrity in all public and personal relationships in order to merit the respect and inspire the order to merit the respect and inspire the confidence of the organization and the public being confidence of the organization and the public being served.served.

Believes that personal aggrandizement or personal Believes that personal aggrandizement or personal profit obtained through misuse of public or personal profit obtained through misuse of public or personal relationships is dishonest and not tolerable.relationships is dishonest and not tolerable.

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Identifies and eliminates participation of any Identifies and eliminates participation of any individual in operational situations where a conflict of individual in operational situations where a conflict of interest may be involved.interest may be involved.

Believes that members of the Institute and its staff Believes that members of the Institute and its staff should at no time, or under any circumstances, should at no time, or under any circumstances, accept directly or indirectly, gifts, gratuities, or other accept directly or indirectly, gifts, gratuities, or other things of value from suppliers, which might influence things of value from suppliers, which might influence or appear to influence purchasing decisions.or appear to influence purchasing decisions.

Keeps the governmental organization informed, Keeps the governmental organization informed, through appropriate channels, on problems and through appropriate channels, on problems and progress of applicable operations by emphasizing the progress of applicable operations by emphasizing the importance of the facts.importance of the facts.

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Resists encroachment on control of personnel in Resists encroachment on control of personnel in order to preserve integrity as a professional order to preserve integrity as a professional manager.manager.

Handles all personnel matters on a merit basis, and Handles all personnel matters on a merit basis, and in compliance with applicable laws prohibiting in compliance with applicable laws prohibiting discrimination in employment on the basis of discrimination in employment on the basis of politics, religion, color, national origin, disability, politics, religion, color, national origin, disability, gender, age, pregnancy and other protected gender, age, pregnancy and other protected characteristics.characteristics.

Seeks or dispenses no personal favors. Handles Seeks or dispenses no personal favors. Handles each administrative problem objectively and each administrative problem objectively and empathetically, without discrimination.empathetically, without discrimination.

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Subscribes to and supports the professional Subscribes to and supports the professional aims and objectives of the National Institute of aims and objectives of the National Institute of Governmental Purchasing, Inc.Governmental Purchasing, Inc.

CASE STUDY 1: LOVE IN THE TIME OF CASE STUDY 1: LOVE IN THE TIME OF CONTRACTINGCONTRACTING

  

 

Hutch has been working with WeRGreat, Inc. for nearly ten years, where he is a contract specialist/manager in the government relations department. During this time, he’s worked on various issues, specifically dealing with bid proposals and government contract management and compliance. Although these last ten years have bestowed upon him many professional accolades, his love life has seriously suffered.

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He’s been so busy drafting bid He’s been so busy drafting bid proposals, studying procurement proposals, studying procurement legislation and attending legislation and attending government and corporate government and corporate meetings; that sadly, he hasn’t meetings; that sadly, he hasn’t dated at all. However, as fate would dated at all. However, as fate would have it, he met someone a month-have it, he met someone a month-and-a-half ago, Daisy, and she is and-a-half ago, Daisy, and she is great. great.

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They both love to go out to nice dinners, They both love to go out to nice dinners, see shows and drink expensive wine. More see shows and drink expensive wine. More importantly, they both have so many importantly, they both have so many hobbies in common, that they never really hobbies in common, that they never really discuss work. Hutch only knows that Daisy discuss work. Hutch only knows that Daisy is presently leaving her private sector job is presently leaving her private sector job to start working with a local government to start working with a local government agency.agency.

  

  

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One afternoon, as Hutch is One afternoon, as Hutch is preparing for a meeting and preparing for a meeting and reviewing several new bids just reviewing several new bids just advertised by various local advertised by various local government agencies, he sees government agencies, he sees her name as a contact reference her name as a contact reference for one of the bids, a potentially for one of the bids, a potentially lucrative contract no less. With all lucrative contract no less. With all the excitement “new love” offers the excitement “new love” offers [in addition to the splendid vino][in addition to the splendid vino]

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Daisy failed to mention that Daisy failed to mention that she was the new procurement she was the new procurement manager and acting deputy manager and acting deputy director of the government director of the government agency, which advertised the agency, which advertised the lucrative bid. lucrative bid.

  

  

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If WeRGreat, Inc. is awarded the If WeRGreat, Inc. is awarded the bid; it could mean a huge bid; it could mean a huge commission for Hutch, not to commission for Hutch, not to mention the company prestige. mention the company prestige. The advertisement is fairly The advertisement is fairly standard; however, Hutch standard; however, Hutch expects there to be much expects there to be much competition. competition.

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He is also well aware that the ethics rules He is also well aware that the ethics rules prohibit any oral communication about prohibit any oral communication about the advertised bid, but for questions of the advertised bid, but for questions of process and procedure. He thinks about process and procedure. He thinks about calling Daisy but decides to wait until calling Daisy but decides to wait until later, when he will see her for a romantic later, when he will see her for a romantic dinner. In fact, a few days ago he bought dinner. In fact, a few days ago he bought her an engagement ring and is thinking her an engagement ring and is thinking about asking Daisy to marry him. about asking Daisy to marry him.

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If he decides to ask Daisy for If he decides to ask Daisy for her hand in marriage and she her hand in marriage and she says yes, might she be more says yes, might she be more willing to talk about the willing to talk about the contract?contract?

    

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QUESTION: Do you attempt to QUESTION: Do you attempt to ask her questions about the ask her questions about the potential contract, knowing potential contract, knowing with certainty, for example, with certainty, for example, that no one will find out? that no one will find out?

  

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What are the other ethical What are the other ethical considerations and rules to considerations and rules to consider?consider?

  

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You decided not to talk to her You decided not to talk to her about the contract in light of the about the contract in light of the ethics rules. The two of you are ethics rules. The two of you are sharing a romantic dinner sharing a romantic dinner celebrating your engagement. celebrating your engagement. You only have eyes for each You only have eyes for each other but it turns out your other but it turns out your embraces and celebration are embraces and celebration are being observedbeing observed

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by several of Daisy’s staff who also know by several of Daisy’s staff who also know you from your years of “hanging” out at you from your years of “hanging” out at government hall. During dinner you and government hall. During dinner you and Daisy decide to live together. Ultimately, Daisy decide to live together. Ultimately, WeRGreat, Inc. is awarded the contract. WeRGreat, Inc. is awarded the contract. Many in Daisy’s office are now suspicious. Many in Daisy’s office are now suspicious. How do you address this issue? How do you address this issue?

  

  

PUBLIC CORRUPTIONPUBLIC CORRUPTION

““Quis custodes ipsos custodiet”Quis custodes ipsos custodiet”

““Who guards the guardians?”Who guards the guardians?”

Juvenal (Roman Poet, A.D.c. 60-140)Juvenal (Roman Poet, A.D.c. 60-140)

THE PAUL MENDELSON THE PAUL MENDELSON CITIZEN’S RIGHT TO CITIZEN’S RIGHT TO

HONEST GOVERNMENT HONEST GOVERNMENT ACTACT

BRIBERY, F.S. 838.015 BRIBERY, F.S. 838.015 UNLAWFUL COMPENSATION, F.S. UNLAWFUL COMPENSATION, F.S.

838.016838.016

1) Increased from 31) Increased from 3rdrd degree felony to degree felony to 22ndnd degree felony degree felony

2) Increased from Level 1 to Level 72) Increased from Level 1 to Level 7

GUIDELINES CHANGE FOR GUIDELINES CHANGE FOR BRIBERY/UNLAWFUL COMPENSATIONBRIBERY/UNLAWFUL COMPENSATION

COUNTS OLD NEW

1 count 4 pts – NSPS 56 pts 21 mos. State Prison

5 counts 6.8 pts – NSPS 105 pts 8 ¾ yrs State Prison

DEFINITION OF “CORRUPT INTENT”DEFINITION OF “CORRUPT INTENT”

F.S. 838.014 (4) F.S. 838.014 (4) Bribery/Unlawful Compensation (Current):Bribery/Unlawful Compensation (Current):

““Corruptly means done with a wrongful intent and Corruptly means done with a wrongful intent and for the purpose of obtaining or compensating or receiving for the purpose of obtaining or compensating or receiving compensation for any benefit resulting from some act or compensation for any benefit resulting from some act or omission of a public servant which is inconsistent with the omission of a public servant which is inconsistent with the proper performance of his or her public duties.”proper performance of his or her public duties.”

Official Misconduct (Current):Official Misconduct (Current):“ ‘“ ‘Corrupt’ means done with knowledge that act is Corrupt’ means done with knowledge that act is

wrongful and with improper motives.” wrongful and with improper motives.”

Bribery/Unlawful Compensation/Official Misconduct (New):Bribery/Unlawful Compensation/Official Misconduct (New): “ “Corruptly” or “with corrupt intent” means acting Corruptly” or “with corrupt intent” means acting

knowingly and dishonestly for a wrongful purpose.knowingly and dishonestly for a wrongful purpose.

OFFICIAL MISCONDUCT, F.S. 838.022 OFFICIAL MISCONDUCT, F.S. 838.022 (FORMERLY F.S. 839.25)(FORMERLY F.S. 839.25)

(1) It is unlawful for a public servant, with corrupt intent to (1) It is unlawful for a public servant, with corrupt intent to obtain a benefit for any person or to cause harm to another, obtain a benefit for any person or to cause harm to another, to:to:

(a) Falsify or cause another person to falsify, any (a) Falsify or cause another person to falsify, any official record or official document;official record or official document;

(b) Conceal, cover up, destroy, mutilate, or alter any (b) Conceal, cover up, destroy, mutilate, or alter any official record or official document or cause another person official record or official document or cause another person to perform such an act; orto perform such an act; or

(c) Obstruct, delay, or prevent the communication of (c) Obstruct, delay, or prevent the communication of information relating to the commission of a felony that information relating to the commission of a felony that directly involves or affects the public agency or public entity directly involves or affects the public agency or public entity served by the public servant. served by the public servant.

OFFICIAL MISCONDUCT, F.S. 838.022OFFICIAL MISCONDUCT, F.S. 838.022

(2) For the purpose of this section:(2) For the purpose of this section:

(a) The term “public servant” does not include a (a) The term “public servant” does not include a candidate who does not otherwise qualify as a public candidate who does not otherwise qualify as a public servant.servant.

(b) An official record or official document (b) An official record or official document includes only public records.includes only public records.

OFFICIAL MISCONDUCT, F.S. 838.022OFFICIAL MISCONDUCT, F.S. 838.022

(3) Any person who violates this section commits a (3) Any person who violates this section commits a felony of the third degree, punishable as provided in felony of the third degree, punishable as provided in s.775.082, s. 775.083, or s. 775.084.s.775.082, s. 775.083, or s. 775.084.

Remains as a 3Remains as a 3rdrd degree felony degree felony

Increased from Level 1 to Level 4Increased from Level 1 to Level 4

DISCLOSURE OR USE OF DISCLOSURE OR USE OF CONFIDENTIAL CRIMINAL JUSTICE CONFIDENTIAL CRIMINAL JUSTICE

INFORMATION,INFORMATION, F.S. 838.21 F.S. 838.21

(New Statute)(New Statute)

ItIt is unlawful for a public servant, with intent to obstruct, is unlawful for a public servant, with intent to obstruct, impede, or prevent a criminal investigation or a criminal impede, or prevent a criminal investigation or a criminal prosecution, to disclose active criminal investigative or prosecution, to disclose active criminal investigative or intelligence information as defined in chapter 119 or to intelligence information as defined in chapter 119 or to disclose or use information regarding either the efforts to disclose or use information regarding either the efforts to secure or the issuance of a warrant, subpoena, or other secure or the issuance of a warrant, subpoena, or other court process or court order relating to a criminal court process or court order relating to a criminal investigation or criminal prosecution when such investigation or criminal prosecution when such information is not available to the general public and is information is not available to the general public and is gained by reason of the public servant’s official position. gained by reason of the public servant’s official position. Any person who violates this section commits a felony of Any person who violates this section commits a felony of the third degree, punishable as provided in s. 775.082, s. the third degree, punishable as provided in s. 775.082, s. 775.083 or s. 775.084.775.083 or s. 775.084.

BID TAMPERING, F.S. 838.22BID TAMPERING, F.S. 838.22(New Statute)(New Statute)

(1) It is unlawful for a public servant, with corrupt intent to influence (1) It is unlawful for a public servant, with corrupt intent to influence or attempt to influence the competitive bidding process undertaken by or attempt to influence the competitive bidding process undertaken by any state, county, municipal, or special district agency, or any other any state, county, municipal, or special district agency, or any other public entity, for the procurement of commodities or services, to:public entity, for the procurement of commodities or services, to:

(a) Disclose material information concerning a bid or (a) Disclose material information concerning a bid or other aspects of the competitive bidding process when other aspects of the competitive bidding process when such information is not publicly disclosed.such information is not publicly disclosed.

(b) Alter or amend a submitted bid, documents or other (b) Alter or amend a submitted bid, documents or other materials supporting a submitted bid, or bid results for materials supporting a submitted bid, or bid results for the purpose of intentionally providing a competitive the purpose of intentionally providing a competitive advantage to any person who submits a bid.advantage to any person who submits a bid.

BID TAMPERING, F.S. 838.22BID TAMPERING, F.S. 838.22

(2) It is unlawful for a public servant, with corrupt (2) It is unlawful for a public servant, with corrupt intent to obtain a benefit for any person or to cause intent to obtain a benefit for any person or to cause unlawful harm to another, to circumvent a competitive unlawful harm to another, to circumvent a competitive bidding process required by law or rule by using a bidding process required by law or rule by using a sole-source contract for commodities or services.sole-source contract for commodities or services.

BID TAMPERING, F.S. 838.22BID TAMPERING, F.S. 838.22

(3) It is unlawful for any person to knowingly agree, (3) It is unlawful for any person to knowingly agree, conspire, combine, or confederate, directly or conspire, combine, or confederate, directly or indirectly, with a public servant to violate indirectly, with a public servant to violate subsection (1) or subsection (2).subsection (1) or subsection (2).

(4) It is unlawful for any person to knowingly enter (4) It is unlawful for any person to knowingly enter into a contract for commodities or services which into a contract for commodities or services which was secured by a public servant acting in violation was secured by a public servant acting in violation of subsection (1) or subsection (2).of subsection (1) or subsection (2).

BID TAMPERING, F.S. 838.22BID TAMPERING, F.S. 838.22

(5) Any person who violates this section commits a (5) Any person who violates this section commits a felony of the second degree, punishable as provided felony of the second degree, punishable as provided in s. 775.082, s. 775.083, or s. 775.084.in s. 775.082, s. 775.083, or s. 775.084.

PUBLIC CORRUPTION STUDY PUBLIC CORRUPTION STUDY COMMISSION PROPOSALS NOT COMMISSION PROPOSALS NOT

INCLUDED IN NEW LEGISLATIONINCLUDED IN NEW LEGISLATION

1) Criminal Misuse of Official Position – 21) Criminal Misuse of Official Position – 2ndnd degree degree FelonyFelony

2) Public Servant Perjury – 22) Public Servant Perjury – 2ndnd degree Felony degree Felony

3) Official Misconduct – 23) Official Misconduct – 2ndnd degree Felony degree Felony

4) Mandatory Training For Elected Officials in Ethics, 4) Mandatory Training For Elected Officials in Ethics, Sunshine Law and Public Record LawsSunshine Law and Public Record Laws

5) Whistleblowing Public Employees Given 5) Whistleblowing Public Employees Given “Confidential Informants” status“Confidential Informants” status

CASE STUDY 2: WEARING MANY (HARD) HATSCASE STUDY 2: WEARING MANY (HARD) HATS

Twelve years ago, Isabel was one of only five engineers in her graduating class at a college in the Midwest. She married shortly after graduation, moved to Miami, and began working for BIG, Inc., a large engineering consulting company. At BIG, Isabel served as a construction inspector for county engineers on several capital improvement projects, including the construction of Terminal Z, at Miami International Airport.

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Last year, Isabel left BIG to form her Last year, Isabel left BIG to form her own engineering consulting firm. She own engineering consulting firm. She got one job right away, working with got one job right away, working with her brother-in-law, who is a private her brother-in-law, who is a private real estate developer in Broward real estate developer in Broward County. Since then, however, Isabel County. Since then, however, Isabel has been concerned about getting has been concerned about getting more contracts.more contracts.

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From a friend she keeps in touch From a friend she keeps in touch with at her old job, Isabel learned with at her old job, Isabel learned that GIANT, Inc., another large that GIANT, Inc., another large engineering company in South engineering company in South Florida, will be bidding on managing Florida, will be bidding on managing the Terminal Z project, which is still the Terminal Z project, which is still under construction. Isabel believes under construction. Isabel believes she can offer a lot of expertise to she can offer a lot of expertise to GIANT, based on her past experience GIANT, based on her past experience as a construction inspector at as a construction inspector at Terminal Z.Terminal Z.

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“ “Why don’t you approach GIANT with Why don’t you approach GIANT with a joint-venture offer?” her friend a joint-venture offer?” her friend suggested. “You know the ins and suggested. “You know the ins and outs of working with the county. You outs of working with the county. You can certainly help GIANT pass the can certainly help GIANT pass the inspection process.”inspection process.”

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QUESTION: May Isabel serve as QUESTION: May Isabel serve as an engineering consultant with an engineering consultant with GIANT and bid as part of a joint GIANT and bid as part of a joint venture for the construction venture for the construction manager project despite her manager project despite her prior work as an inspector on the prior work as an inspector on the same project, through her same project, through her previous employer, BIG?previous employer, BIG?