Business Integrity, Property & Information
Impartiality, property accountability, records, and data rights — the four controls a federal customer relies on when it hands a contractor something it cannot afford to lose.
Policy Statement
Monarch Space Systems, Inc. treats integrity as an operating system rather than a statement of values. Federal work is performed under a standard of conduct in which impartiality is protected structurally, customer property is accounted for as if it were audited tomorrow, records are retained as if they will be read by someone with no institutional memory, and intellectual property rights are asserted and respected with the same rigor. The institution publishes how these controls are built because a customer, a prime, and an acquirer each need to know that integrity here is procedural, not personal.
- Conflicts of interest, organizational and personal, are screened before a pursuit decision and disclosed to the contracting officer when they are material.
- No employee holds a financial interest in, or accepts anything of value from, a supplier, teammate, or competitor whose interests they can influence.
- Property furnished or funded by a customer is recorded, marked, segregated, and never used for another program without written authorization.
- Every record class has an owner, a retention period, a protection level, and a defined retrieval path.
- Data rights assertions are made only where the underlying development was independent, and are documented at the time of development rather than at the time of delivery.
- Third-party intellectual property, including software licenses and customer-furnished data, is used strictly within the terms that convey it.
Program Architecture
Four domains, one program. Each has a written scope, an accountable owner, and a review cadence.
Conflict of Interest and Impartiality
Conflicts are identified before a pursuit begins, not after an award is protested. Organizational conflicts are screened at the capture decision, personal conflicts are disclosed annually and on change, and mitigation is written down and enforceable.
Read the detailGovernment and Customer Property
Property furnished by a customer is accounted for from the moment it arrives to the moment it is returned or disposed. Records are current, custody is assigned, and loss is reported rather than absorbed quietly.
Read the detailRecords, Retention and Data Management
A contract is defensible only if its record survives the people who worked it. Record classes, retention periods, protection, and retrieval are defined in advance so that an audit years later is a retrieval task, not an investigation.
Read the detailIntellectual Property and Data Rights
Rights are asserted where they are genuinely earned, respected where they belong to others, and marked correctly either way. The government gets what it paid for, and the institution keeps what it developed independently.
Read the detailIntegrity Authority and Accountability
Chief Executive
Issues the integrity policy, resolves escalated conflict of interest determinations, and holds accountability for the honesty of the institution's representations to the government.
Legal & Contracts Function
Maintains the conflict of interest register, drafts and enforces mitigation plans, controls data rights assertions and markings, and manages records and disclosure obligations to the contracting officer.
Property Administrator
Owns the property record system, custody assignments, physical inventory, loss and damage reporting, and disposition instructions for property in the institution's possession.
Records Custodians
Maintain designated record classes to the published retention schedule, control access, and support retrieval for audit, litigation hold, or customer request.
Program Leads
Identify emerging conflicts on their programs, verify that property in program use is on the record, and ensure deliverables carry correct rights markings before submission.
Every Employee
Discloses personal interests and outside activity, protects information entrusted by customers and teammates, and reports suspected misconduct without fear of retaliation.
Standards We Align To
The program is written against the regulations and consensus practice a NASA contracting officer, a property administrator, or a prime's compliance organization expects to see. Alignment is stated as alignment; no system approval or determination is claimed.
FAR Subpart 9.5 — Organizational and Consultant Conflicts of Interest
Identification, avoidance, neutralization, and mitigation of organizational conflicts
FAR Part 3 — Improper Business Practices and Personal Conflicts of Interest
Standards of conduct, gratuities, kickbacks, and contractor code of business ethics
FAR 52.203-13 — Contractor Code of Business Ethics and Conduct
Written code, awareness program, internal control system, and mandatory disclosure
FAR Part 45 / FAR 52.245-1 — Government Property
Property management system criteria, records, use, inventory, loss reporting, and disposition
NASA FAR Supplement Part 1845
NASA-specific government property administration and reporting expectations
FAR Part 4.7 — Contractor Records Retention
Retention periods for financial, acquisition, payroll, and program records
FAR Part 27 / DFARS 227 — Patents, Data, and Copyrights
Rights in technical data and computer software, assertions, and marking requirements
NASA FAR Supplement Part 1827
NASA policy on patent rights, technical data, and software rights in agency contracts
ASTM E2135 / E3227 — Property Management Practice
Consensus property management terminology and voluntary practice used by federal property administrators
31 U.S.C. 3729 — False Claims Act
The legal floor beneath every representation, invoice, and certification submitted
Alignment Disclosure
Monarch Space Systems describes its business integrity, property accountability, records, and data rights practices as aligned with the cited federal regulations, agency supplements, and consensus standards. Alignment is not a determination. The institution does not claim an approved property management system, an audited records program, a government determination on any conflict of interest matter, or any specific contract, customer relationship, or property holding. Case-specific facts, disclosures, and filings are handled with the responsible contracting officer rather than published.
Policy documentation, procedures, and control descriptions are available to customers and prospective teammates through the confidential engagement pathway or by request through institutional contact.
Questions We Are Asked
How does Monarch Space Systems screen for organizational conflicts of interest?
At the pursuit decision, before capture resources are committed. The screen asks three questions the FAR asks: would this work let the institution set the ground rules for a later competition, would it give access to another party's non-public competitive information, or would it require the institution to evaluate its own work or a close teammate's work? Where any answer is yes, the pursuit either does not proceed or proceeds under a written mitigation plan disclosed to the contracting officer.
Does the institution claim an approved government property management system?
No. The property practices described here are structured against the outcomes required by FAR 52.245-1 and the NASA FAR Supplement. No property system approval, property administrator determination, or audit result is claimed. Where an award triggers a property system analysis, the institution supports that analysis rather than asserting a result in advance.
What happens when an employee discloses a personal conflict?
The disclosure is recorded and evaluated by the legal and contracts function within a defined interval. The outcome is one of four: no conflict exists, the interest is divested, the employee is recused from the affected work with a documented screen, or the institution declines the work. The employee is not penalized for disclosing, and the record of the determination is retained.
How are records handled when a program ends?
Closeout is a controlled event, not an exhaustion of interest. Deliverable records, property records, purchase files, cost records, and technical data are inventoried, verified against the retention schedule, transferred or returned as the contract directs, and placed under retention for the required period. Records under litigation hold are exempt from destruction until the hold is released in writing.
Will the institution assert rights in everything it develops?
No, and asserting too much is as damaging as asserting too little. Where the government funds development, the government receives the rights it paid for. Where development is genuinely at private expense, the basis is documented at the time it occurs so the assertion is verifiable later. Assertions unsupported by a contemporaneous record are not made.
Why publish integrity procedures instead of keeping them internal?
Because a reviewer cannot evaluate what is invisible. Most contractors hold these procedures on internal portals, which means a contracting officer, a prime's compliance organization, or an acquiring engineering firm learns the structure only after a document request. Publishing the structure — while keeping every case, name, filing, and holding confidential — lets that assessment begin earlier and on better terms.
Public References
Related Institutional Documentation
Integrity controls sit alongside the procurement and supply chain program, accounting system and internal controls, ethics and responsibility, the legal division, export compliance, and enterprise risk management.