Organizational Conflict of Interest Policy

The California High-Speed Rail Authority adopted an Organizational Conflict of Interest Policy in September 2011 which prescribes ethical standards of conduct applicable to persons or entities entering into contracts with the California High-Speed Rail Authority as authorized under section 185000 et seq. of the California Public Utilities Code, and applies to subcontractors as well as prime contractors. This Policy is supplemental to the Authority’s general Conflict of Interest Code and does not modify or supersede any requirements in that Code.

This Policy is intended to accomplish the following: promote integrity, competitiveness transparency and fairness in the Authority’s procurements and contracts; prevent bidders and proposers from obtaining or appearing to obtain an unfair competitive advantage with respect to the Authority’s procurements and contracts; provide guidance to enable contractors to make informed decisions while conducting business with the Authority; and protect the Authority’s interests and confidential and sensitive information concerning the high-speed rail project.

Originally adopted in 2011, this policy was subsequently updated in 2023.

Organizational Conflict of Interest Policy

If you have any questions, or require a conflict-of-interest determination, after reviewing the policy, please send a written request to the Legal Office Legal@hsr.ca.gov and provide the following information regarding the procurement/contract/subject of your inquiry:

1. A summary of each of your company’s current and former contracts with the Authority, either as a consultant or subconsultant, including the status (open/closed/expiration date); include the project section(s), if applicable.
2. A brief description of the scopes of work for the above-identified current and former contracts, including tasks, deliverables, and key roles of personnel, if applicable.
3. A brief description of the work, tasks, deliverables, and any key roles that your company expects to perform relative to the anticipated contract or procurement; if your scope of work is not yet final, please provide as much information as possible about the expected/likely scope of work.
4. A statement about whether your company or principals/employees of your company had any role in the development of the anticipate contract, procurement or scope of work.
5. A statement about whether your company or principals/employees of your company have learned, received, or were privy to any non-public information regarding the scope of work, content or development of the anticipated contract or procurement.
6. Information regarding the type of entity and/or corporate make-up of your company (for example, an LLC, sole proprietorship, corporation, etc.). If applicable, include whether it is a subsidiary of another company and/or if it is owned, in whole or in part, by another consultant working on the Project.
7. If your company is planning to seek work related to other existing or future Authority procurements, provide information regarding the procurement(s) and the scope of work your company would likely perform.
8. Any other information and/or documents that you believe are relevant to this analysis, including information regarding other public projects your company is a part of that may impact the Authority or the Project (LA Union Station, ACE expansion, TJPA, etc.).

Determinations are typically issued within 1-2 weeks; however, a determination may take longer depending on the complexity of the request.