Student Intern Program Guide to Contractual and Legal Relationships rev. April 2011

1. Student Intern ProgramGuide to Contractual and Legal Relationshipsrev. April 2011

2. Program Introduction Vista Sciences has a contract with the Government to administer and manage semester-long student intern programs. The components of this program include the following: • Recruit and screen student intern candidates • Select students for participation • Relocate students to work performance location • Provide ongoing support and supervision of students • Handle all logistics concerning housing and transportation • Evaluate student performance throughout term • Provide final evaluation and feedback of student performance • Ensure that students comply with all Government regulations

3. Important Contract Information Vista Sciences Corporation’s contract with the Government is defined as a Non-Personal Services Contract. Why is this important?

4. Non-Personal Services A Non-Personal Services contract is defined as follows: “Non-personal services” means the furnishing of labor, time, or effort by a contractor, not involving delivery of a specific end product other than reports which are related to the required performance. In regards to the student intern program, Vista Sciences Corporation is the CONTRACTOR. Student interns are EMPLOYEES OF VSC- NOT of the Government……

5. Non-Personal Services What does this mean for YOU- the student intern? Under Non-Personal Services Contracts, student interns cannot: • Be placed in a position where they are under the relatively continuous supervision and control of a government employee. • Be placed in a position of command, supervision, administration, or control over government personnel, or over personnel of other contractors; or become part of the government organization.

6. Non-Personal Services Under Non-Personal Services Contracts, student interns cannot: • Go to a Government employee to discuss problems or issues related to job requirements, housing, transportation or other aspects of logistical support provided to the intern by VSC. • Go to a Government employee to discuss personal issues or problems. • Go to a Government employee to make requests for time off, schedule changes or other related requests/questions.

7. Non-Personal Services So, what IS acceptable under a Non-Personal Services contract? • Government employees (assigned mentors) can request of an intern that a specific task be performed or specify the result/outcome to be achieved, with the right to accept or reject such work outcomes. • Government employees (assigned mentors) can voluntarily submit to VSC, feedback regarding a student intern’s performance or training needs.

8. Chain of Command • The “chain of command” is the line of authority and responsibility along which orders, policies and reporting procedures are established. • This line of authority is established by the type of contract with the Government- in this case, VSC has a Non-Personal Services Contract.

9. Broken Links Don’t be the BROKEN LINK in the Chain of Command! • Failure to follow the Chain of Command can result in very undesirable outcomes, including some outcomes with legal implications for both Vista Sciences and the student intern. • The nature of this contractual relationship is prescribed and governed by law and Government regulations.

10. The Legal Stuff Federal Acquisition Regulation (FAR) The FAR was established to create and codify uniform policies for acquisition of supplies and services by Government agencies. It is issued and maintained jointly, under the statutory authorities granted to the Secretary of Defense, Administrator of General Services and the Administrator, National Aeronautics and Space Administration.

11. The Legal Stuff • FAR 37.000  prescribes and regulates policy and procedures that are specific to the acquisition and management of services by contract. • The student intern program must comply at all times with the FAR regulations and clauses!

12. The Legal Stuff What does it take for Vista Sciences Corporation to be in violation of the FAR regulations that apply to the student intern program?

13. The Answer: It takes only YOU!

14. What if ??? • Violations of the contractual relationship can vary in both the level of severity and the resulting impact on Vista Sciences Corporation’s contract with the Government for student intern services. • Students are held accountable as employees of Vista Sciences Corporation for actions that constitute a violation of regulations and laws.

15. What’s Possible…… Failure to follow the “chain of command” can: • Result in this contract being revoked immediately from VSC, eliminating the possibility for ALL current interns to complete their program. • Result in the immediate termination of the student intern who violated the policy and regulations set by the Government. • Result in an investigation by the Government, with the possibility of penalties and/or fines.

16. What does this all mean for YOU? 1. If you are asked to perform a task or comply with an order by a Government employee that differs from the Statement of Work provided to you, and you are unsure of whether or not there is a potential violation of our Non-Personal Services contract, you must contact your assigned Program Manager by phone or email to discuss the situation and obtain clarification. Under NO CIRCUMSTANCES should you have this conversation with the Government Employee……

17. What does this all mean for YOU? 2. While at the workplace, keep your personal business PRIVATE. Discussing your personal issues or problems at work is seen as unprofessional in any business environment, and discussing such matters with a Government employee violates our contractual relationship with the Government agency.

18. What does this all mean for YOU? 3. Direct any questions or concerns you have about your job assignment, problems with your housing arrangements, issues about your transportation arrangements or any personal matters with your assigned Program Manager.

19. What does this all mean for YOU? 4. If your assigned Program Manager cannot be reached and the question, concern or problem requires immediate attention, VSC policy mandates that you must contact the corporate office. All phone calls related to these issues should be followed up in writing and transmitted electronically to the assigned Program Manager.

20. What does this all mean for YOU? 5. In some cases, such as an accident on the job site or an incident where you have damaged Government property or equipment, you should notify your internship sponsor and also notify immediately your assigned Program Manager. Completion of VSC reporting forms is required for either type of occurrence. These forms are reviewed during student intern orientation.

21. DON’T BREAK THE CHAIN Vista Sciences Corporation wants all students to have the opportunity to complete this very special program with the Government. REMEMBER: The actions of any individual student can impact all other student participants!

22. Module Completion After reviewing the information in this training module, you will be asked to read and sign a document indicating that you have completed this required training, and that you are aware of the consequences for failing to comply with the specific FAR regulations that govern this contract with the U.S. Government. The signed document will become part of your official employee records, and will be a factor in any situation in which a student violates these regulations.