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FOCI

Foreign Ownership, Control, or Influence

PreviousRecruiter Policy

Last updated 3 months ago

Dispel serves clients globally, protecting critical infrastructure and manufacturing around the world. Part of our supply-chain security includes considerations for where our suppliers and service providers are based, and the extent to which foreign ownership, control, or influence ("FOCI") may impact our supply chain.

FOCI does not disqualify a company from serving or supplying Dispel. After completing the questionnaire, a review will be conducted considering the following factors:

  • Record of economic and government espionage against U.S. targets

  • Record of enforcement and/or engagement in unauthorized technology transfer

  • The type and sensitivity of the information that shall be accessed

  • The source, nature, and extent of FOCI

  • Record of compliance with pertinent U.S. laws, regulations and contracts

  • The nature of any applicable bilateral and multilateral security and information exchange agreements

  • Ownership or control, in whole or in part, by a foreign government

  • Any other indications of a foreign interests’ capability to control or influence the company’s operations or management

In addition to these specific factors, Dispel also assesses companies for any other factors that may indicate or demonstrate a capability on the part of foreign interests to control or influence the company’s operations or management in a manner that would be detremental to our end customers.

Questionnaire

Dispel's FOCI form is modeled after Standard Form (SF) 328, the Certificate Pertaining to Foreign Interest, which is a 10-question document designed to help identify the presence of FOCI in an organization. Each of the 10 questions requires a yes or no answer, and any yes answer requires that additional information or documentation be included with the form.

https://eform.pandadoc.com/?eform=4e1940f9-28c6-43b6-8506-e7ad5f9c05ffeform.pandadoc.com