Corrective Action Plan:
The Corporation has reviewed the current procurement standards and has identified gaps in
compliance with the federal requirements. To address this, the Corporation will adopt a
Procurement Policy Addendum, based on the attached draft, which includes compliance
measures for:
● Small and minority business engagement
● Domestic preferences for procurements
● Recovered materials procurement
● Cost analysis for contracts over the Simplified Acquisition Threshold
● Bonding requirements for construction contracts
● Contract provisions regarding Equal Employment Opportunity, Davis-Bacon Act, and other
federal mandates
The attached model policy will be presented to the Board for formal adoption and will be
incorporated into the Corporation's procurement procedures to ensure full compliance with 2 CFR
§ 200.318-326.
Responsible Individual: Joseph Ninomiya - Chief Executive Officer
Planned Date of Implementation:
October 23, 2024