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Defense Security ServiceFCL Orientation HandbookBusiness StructureBusiness Records RequiredPCLs for KMPsPrivately Held Corporation Business LicenseFictitious Name CertificateArticles of IncorporationBy-LawsStock LedgerLegal Organization ChartBoard/Company MeetingMeetings* Recent changes to companystructure Publicly Held Corporation Business LicenseFictitious Name CertificateArticles of IncorporationBy-LawsMost recent SEC filingsLegal Organization ChartBoard/Company MeetingMeetings* Recent changes to companystructure Limited Liability Company Business License Fictitious Name Certificate Certificate of Formation or Articlesof Organization Legal Organization Chart Operating Agreement LLC Meeting Meetings* Recent changes to companystructure SMO FSO LLC Members are cleared if their dutiesrequire access to classified information ManagersSMOFSOChairman of the BoardVice Chair of Board, if provisions forrotating or Pro Tem duties Corporate Officials are cleared if theirduties require access to classifiedinformationSMOFSOChairman of the BoardVice Chair of Board, if provisions forrotating or Pro Tem duties Corporate Officials are cleared if theirduties require access to classifiedinformation Charter SMO Board/University Meeting FSOMeetings* President Legal Organization Chart Regents/Trustees/Directors are cleared if Recent changes to universitytheir duties require access to classifiedstructureinformation*Include the most recent Meeting Minutes and any Meeting Minutes to reflect changes to a company’s address, name,KMPs, etc.** If Business Structure is not identified, discuss with ISR during Telephonic SurveyCollege/UniversityExcluded KMPs: DSS will determine which Officers and Directors of the company not accessing classifiedinformation are considered excluded, and do not need a PCL. The company must submit exclusion resolutions forthese Officers and Directors (see Appendix C).If Key Management Personnel are cleared for contractual performance reasons and not in connection with theFCL then this difference needs to be identified.Page 9

Defense Security ServiceFCL Orientation Handbook3.2 Required FormsThe following outlines the Forms required for upload into the e-FCL.FormsTo Include on FormsSF-328; Certificate Pertainingto Foreign Interests Certificate pertaining to a company’s foreign interests Execute two original SF328 forms for DSS and contractor retention SF328 must be signed by an employee or representative of the company whohas actual authority to execute agreements with the U.S. Government onbehalf of the company Upload signed SF328 into e-FCL Provide all supplemental responses to affirmative SF328 questions (Seesupplemental data sheets in e-FCL)Summary Data Sheet List company website Include stock information List all previous business names List all Tiered Parents Match number of Directors in Articles of Organization to Company Bylaws List all addresses dating back 10 years Current Chairman of the BoardKey Management Personnel(KMP) Form Spell out entire KMP names Social Security Number not required for excluded KMPs Citizenship of all personnel listed as required to be cleared KMPs must match the Articles of Organization, by-laws or amendmentsTiered Parent ListIf applicable List of all Parent Companies (see 3.3)DD Form 441 Agreement between your organization and the United States Government thatdetails the security responsibilities of both the cleared organization and theUnited States Government Execute two original DD441 forms for DSS and contractor retention. DD441 must be signed by an employee or representative of the company whohas actual authority to execute agreements with the U.S. Government onbehalf of the company. Upload signed DD441 into e-FCL upon receipt of countersignatures from DSS. DD Form 441DD Form 441-1If applicable Attachment to the DD Form 441 listing cleared divisions or branch offices thatare included in and covered by the provisions of the organization's SecurityAgreement and Certificate Pertaining to Foreign Interest. DD Form 441-13.2.1 Required e-FCL Forms Signatures per Business StructureThe following guidelines provide information to sign the DD441, DD441-1 and SF328 forms according to yourcompany’s Business Structure.Business StructureBusiness StructureSole Proprietorship Sole proprietor will execute the DD 441/ SF328. “Certification” section of DD 441/ SF328 will not be executed, butone witness must sign these formsGeneral Partnership All general partners will execute DD 441/ SF328 One witness signature is requiredLimited Partnership One witness signature is requiredPage 10

Defense Security ServiceBusiness StructureFCL Orientation HandbookBusiness StructureJoint Venture DD 441/ SF328 forms must be executed by an authorizedrepresentative of one the contractor participants performing onthe classified contractPrivately Held Corporation Authorized management personnel may execute the DD441/ SF328forms Witness is not required Corporate seal must be applied, if applicablePublicly Held Corporation Authorized management personnel may execute the DD441/ SF328forms Witness is not required Corporate seal must be applied, if applicableLimited Liability Company (LLC) LLC member or authorized manager may execute the DD 441/SF328 forms Two witnesses must sign the DD 441 and SF328 Certification, at bottom, does not need to be completedIf only one officer exists within your organization then work with your assigned Industrial SecurityRepresentative to determine how the forms must be certified or whether an alternate process with witnessesshould be utilized.Page 11

Defense Security ServiceFCL Orientation Handbook3.3 Excluded Tier Entity ProcessThe objective of this process is to clear the Sponsored Facility and identify Tiered Companies to exclude fromaccess to classified information. A Tiered Company, also known as a Parent Company, is defined as a companyowning at least a majority of another company’s voting securities. DSS determines if Tiered Companies arerequired to obtain an FCL or can be excluded from access to classified information.3.3.1 Excluded Tier Entity RequirementsThe process flow below outlines the required documents the Sponsored Facility must provide to DSS on behalf ofany Intermediate Excluded Entities and the Ultimate Excluded Entity. In this process neither the Ultimate ExcludedEntity nor any of the Intermediate Tiered Entities hold a FCL.3.2.1.1 Process FlowExcluded Entity: In-Process FacilitySponsored Facility:Company AFirst Tier Excluded Entity:Company BSecond Tier ExcludedEntity: Company CThird Tier ExcludedEntity: Company D1) Provides company orgchart, KMP lists andbusiness records to UltimateExcluded Parent2) Provides company orgchart, KMP lists andbusiness records to UltimateExcluded Parent3) Provides company orgchart, KMP lists andbusiness records to UltimateExcluded ParentUltimate Excluded Entity:Company E4) Compiles excluded entitycompanies org charts, KMPlists and business records5) Consolidates a SF-328 forthe excluded entitiesAcknowledges exclusion ofthe Excluded Entities fromaccess to classifiedinformationResolution for intermediateexcluded entities8) Submits excluded entitiesdocumentation into e-FCL;submits Subsidiary ExclusionResolution into e-FCL7) Provides documents toSponsored Facility9) Submits all e-FCLdocuments and formsrequired per itsBusiness Structure3.3.1.2 Entity Roles and ResponsibilitiesEntityIntermediateParent/Owner EntityResponsibility Submits Company’s Organization Chart, KMP List, and Business Recordsto Ultimate Cleared EntityPage 12

Defense Security ServiceFCL Orientation HandbookEntityResponsibility Ultimate Parent/OwnerEntity Sponsored Facility(Highest Cleared Facility) Provides all Entities Organization Charts, KMP Lists, and Business Recordsto Sponsored FacilityProvides Sponsored Facility the requested Exclusion Resolution on behalfof its company and Intermediate parents to be ExcludedSubmits Parent entities to be Excluded Organization Charts, KMP Lists,Business Records, and Exclusion Resolution for entitiesSubmits Subsidiary Exclusion Resolution acknowledgementSubmits all required e-FCL Forms and Documents per its BusinessStructure3.3.2 Highest Cleared Tier EntityThe process flow below documents the required documents the Sponsored Facility and Highest Cleared Entity mustprovide to DSS on behalf of any Intermediate Excluded Entities and the Ultimate Excluded Entity. In this processthe Highest Cleared Entity holds a FCL and provides DSS updates on behalf of the Ultimate Excluded Entity andIntermediate Tier Entities. Highest Cleared Entity previously submitted all required Documents and Forms forExcluded Entities during its FCL process.3.2.2.1 Process FlowExcluded Entity: Highest Cleared FacilitySponsored Facility:Company AAcknowledges exclusion ofthe parent company fromaccess to classifiedinformation5) Submits SubsidiaryExclusion Resolution into eFCLHighest Cleared Entity:Company BInformation for ExcludedEntities previously submittedby Highest Cleared Entityduring its FCL processFirst Tier Excluded Entity:Company CSecond Tier ExcludedEntity: Company D1) Submits company updatesto Ultimate Excluded Entity2) Submits company updatesto Ultimate Excluded Entity4) Submits Excluded EntitiesUltimate Excluded Entity:Company E3) Submits all ExcludedEntity company updates toHighest Cleared Facilityinformation forSponsored Facility6) Submits all e-FCLdocuments and formsrequired per itsBusiness Structure3.3.2.2 Entity Roles and ResponsibilitiesEntityResponsibilityIntermediate Entity Submit changes to Ultimate Entity, if applicableUltimate Entity Provides Intermediate Entity changes to Highest Cleared Entity, ifapplicableHighest Cleared Entity Provides Entity changes to DSS, if applicableSponsored Facility Submits all required e-FCL Forms and Documents per its BusinessStructure Submits Subsidiary Acknowledgement of Exclusion ResolutionPage 13

Defense Security ServiceFCL Orientation Handbook4.0 e-FCL ProcessThe e-FCL web based system to submit company data in an electronic format for facility clearance and FOCImitigation e-FCL Submission Site URL: https://submission.dssfcl.anl.gov. Your account will have been registered bythe Facility Clearance Branch (FCB) upon receipt of your Sponsorship Package from the cleared contractor or GCA.The Company designates a representative, usually the FSO, as the e-FCL Administrator. Below outlines the e-FCLprocess steps:Facility Clearance BranchReceivesSponsorship PackageCreates Company’se-FCL accountCompany e-FCL AdministratorReceives “WelcomePackage”Logs into e-FCLaccountObtains and uploadse-FCL documentsand forms4.1 Logging into e-FCLPrior to Logging-In: It is recommended that you download the e-FCL “ Su b mis sion Sit e Us er Gu id e” , to gaina better understanding of the system, how to Log-In the first time, and the required documents and forms to uploadinto the system.First Time Log-In: The Log-In requires a User ID and Password. The initial User ID is the e-mail address enteredwhen the User was registered by DSS or by the company’s e-FCL Administrator. The temporary password was sentto the e-mail address entered when the User was registered by the DSS or by the company’s e-FCL Administrator.First time Log-In also requires the e-FCL Administrator to enter the Company’s Organization Type andOrganization’s Employer Identification (EIN) Tax ID or SSN. The e-FCL automatically generates the forms requiredby Organization Type as well as a list of required document uploads.4.2 e-FCL in 5 StepsThe e-FCL Submission Site provides Users with an easy fivestep process for completing andsubmitting e-FCL submission packages. The packageconsists of all of the forms and attachmentsrequired for a facility clearance submission. The user cannavigate between steps as needed and enter or exit thepackage as many times as needed before sending the finalsubmission.Below provides a list of the five steps and the requiredforms and documents to submit into the e-FCL. Allpotential forms and documents are listed under A.1 this document.Step #1e-FCL Submission StepComplete Formse-FCL Submission DescriptionElectronic copies of all required forms are provided for completionbased on the type of contractor organization2Upload DocumentsUploads are requested of key business documents.Also review required documents per your company’s businessstructure3Requested FormsForms requested by DSS for FOCI Mitigation are stored here, this stepwill be empty the first time an Initial Package is submitted4Review FormsAfter reviewing all documents and uploads, the system checks toensure that all forms and uploads have been completed and displaysthose that still need to be completed5Send Final SubmissionFinal submission, once the package is submitted the contractor cannotedit the package unless DSS “unlocks” itPage 14

Defense Security ServiceFCL Orientation Handbook5.0 Accounts and SystemsThe table below outlines the Accounts and Systems the FSO must activate or leverage to submit additionaldocuments for its Facility to receive its FCL and to maintain a compliant security program after obtaining the FCL.Discontinuation Point: Failure to submit all KMP e-QIPs within 45 days after receipt of the FCL OrientationHandbook results in the discontinuation of your Facility’s FCL. Failure to submit KMP fingerprints within 14 daysafter submitting KMP e-QIPS results in the discontinuation of your Facility’s FCL.AccountsReason for AccountDescriptionLinksDD FormCommercial andGovernment Entity(CAGE) CodeProvides a standardizedmethod to identify yourspecific facilityThe CAGE Code is a five-character ID numberused extensively within the federalgovernment, assigned by the Department ofDefense’s Defense Logistics Agency (DLA). Ittracks basic facility information. If yourcompany does not already have a CAGE Codefor the facility requiring clearance, one may beobtained by submitting a DD Form 2051 toCommander, Defense Logistics ServicesCenter, ATTN: DLSC-SBB, Federal Center, 74North Washington, Battle Creek, MI 490173084. Alternatively, you may visit System forAward Management (SAM) to obtain yourCAGE CodeJoint PersonnelAdjudicationSystem (JPAS)*System to supportadjudication process.(Account created afterFacility is issued its FCL.)JPAS standardizes the adjudication processwithin DoD, and provides a database andprocesses within the security manager realmof functions. It allows communication betweenthe central adjudication facility (CAF) and thesecurity personnel in the field who actuallygive cleared individuals access to classifiedinformation.For JPAS access, submit DMDC’s newPersonnel Security System Access Request(PSSAR) form to the DMDC Contact Center forprocessingA Public Key Infrastructure (PKI) is required forJPAS. Please see linkJPASElectronicQuestionnaires forInvestigationsProcessing (eQIP)*Submit KMP informationthrough this system as partof the PCL processe-QIP allows the user to electronically enter,update and transmit their personalinvestigative data over a secure internetconnection to a requesting agencye-QIPISFDProvides FCL andsafeguarding statusfor prime and subcontractorsWeb enabled database that maintains FCLrelated informationSAMPKIPage 15

Defense Security ServiceAccountsSecure WebFingerprintTransmission(SWFT)*FCL Orienta

forms, such as the Department of Defense Security Agreement, DD Form 441 (or DD Form 441-1 for division/branch facilities); process Key Management Personnel (KMP) for personnel security clearances; and appoint a U.S. citizen employee as the Facility Security Officer (FSO). FCL Roadmap FCL Orientation Handbook Day 1 - Day 5 DSS to provide FSOs an