Touch Not the Anointed: Procurement Integrity, Servant Leadership, and Ethics in GovCon

Sep 7, 2025

7 min read

Servant Leader: I have been inspired by fellow bloggers to write more in-depth content for my readers. This blog is the beginning in that series that is designed to offer more than milk for breakfast.

In the high-stakes world of government contracting (GovCon), competition is fierce, margins are thin, and the pressure to win can tempt even seasoned leaders to cut corners. But what if the real measure of success isn’t just securing the award—but preserving integrity in the process?

Scripture gives us a striking parallel in the life of King David. Twice, men tried to “help” David by eliminating rivals—first Saul, then Ish-bosheth. Both times, David’s response was unwavering:

“Were you not afraid to lift your hand against the LORD’s anointed?” (2 Samuel 1:14)

David understood something we often forget: some things are sacred. The crown was his by promise, but he would not grasp it by violating God’s order. [2][3]

In today’s marketplace, the “anointed” is not a king—it’s the public trust and the procurement process that safeguards it. FAR regulations, ethics statutes, and compliance frameworks aren’t bureaucratic red tape; they are the guardrails that keep competition fair and stewardship honorable. And for leaders who follow the principles of Servant Leadership, these rules aren’t obstacles—they’re opportunities to lead with humility, courage, and care. [4][5]

This blog explores what it means to compete with integrity in GovCon—drawing lessons from David’s restraint, grounding them in Servant Leadership, and applying them to the ethical challenges of today’s business culture.

David understood that some things are set apart—anointed—and the faithful do not “win” by violating what God has made holy. In GovCon, the public trust—and the process that guards it—is sacred.

GovCon’s “Anointed”: The Public Trust and the Procurement Process

In GovCon, the “anointed” is not a person but a trust—the legally protected processes, information, and roles that steward taxpayer funds. The Federal Acquisition Regulation (FAR) treats these as sacrosanct through explicit standards of conduct (FAR Part 3), restrictions on obtaining and disclosing source-selection information (the Procurement Integrity provisions), and conflict-of-interest guardrails (FAR Subpart 9.5). These aren’t suggestions; they are the ethical rails of the field. [6][7][8]

Standards of Conduct (FAR 3.101): Procurement must be conducted “with complete impartiality and with preferential treatment for none.” [6]
Procurement Integrity (41 U.S.C. ch. 21; FAR 3.104): It is illegal to disclose—or obtain—nonpublic bid, proposal, or source-selection information prior to award; there are also post‑employment restrictions for certain officials. Examples of how this restriction applies include: [9][10][7]
- Cost or Pricing Data – Detailed breakdowns of estimated costs, profit margins, or pricing strategies submitted in a proposal.
- Indirect Costs and Direct Labor Rates – Proprietary financial structures that reveal how a contractor allocates overhead or labor expenses.
- Proprietary Technical Information – Manufacturing processes, operations, or techniques marked as confidential by the contractor.
Organizational Conflicts of Interest (FAR Subpart 9.5): Agencies must identify, avoid, or mitigate “unequal access,” “biased ground rules,” and “impaired objectivity” conflicts; note the special rules around marketing consultants and access to proprietary information. This can be: [8][11]
- Proprietary Information – Using a competitor’s non-public document, like a Capture Brief or Proposal, to develop ghosting or pricing strategies.
- Inside Information – Leveraging a position on a support contract (Sub for a Prime; Advisory work for a Client) to gain early access to acquisition information, strategies, and timelines.
- Noncompetitive Bias – Drafting the technical requirements for a service or system, then bidding on the contract to deliver that service or system.
Anti‑Kickback Act: Prohibits payments or “things of value” intended to improperly obtain or reward favorable treatment in prime/subcontracting. These can include: [12][13]
- Gift Card – A subcontractor giving a $500 gift card to a Prime’s PM to facilitate receipt of a subcontract extension
- Tickets – Giving a potential source selection official tickets to the 50-yard-line for their favorite football team
Gift Rules (OGE standards): Strict limitations govern gifts and entertainment for federal employees; missteps here create real risk to integrity. Violations can include: [14][15]
- Food – Picking up the tab for an expensive dinner or regular lunch meeting.
- Gift – Not just cars and trips, but even simple things like a protective phone case, a company shirt, or even a coffee mug.

The rules protect something sacred—impartiality, fairness, and public confidence. Touch those safeguards the wrong way, and you haven’t “competed”; you’ve corrupted.

Servant Leadership in a Zero‑Sum Market

Robert K. Greenleaf teaches that real authority flows from service, not from seizing advantage. Its disciplines—listening, humility, foresight, stewardship—translate directly into how we compete. [16]

Listen to the mission, not just the market. Your bid should serve the end user and the taxpayer, not just your quarterly target. (FAR’s emphasis on best value embodies that stewardship.) [6]
Win without wounding. Honor competitors as fellow image‑bearers; learn from them but refuse tactics that exploit nonpublic information or create unfair access. (That’s the heart of procurement integrity.) [7][10]
Hold power open‑handedly. If your incumbent knowledge risks “unequal access,” insist on mitigation plans and firewalls that protect the process—even when it complicates your near‑term win. (FAR 9.505–9.508 gives the playbook.) [11]

David would not grasp the throne by violating an anointed boundary, even when shortcuts beckoned. In GovCon, Servant Leaders refuse to “advance the crown” by trespassing procurement holiness.

Today’s Business Culture: Pressure, Speed, and the Temptation to Cut Corners

Our marketplace rewards speed and certainty—two conditions that often collide with ethical patience. False Claims Act enforcement trends underscore the real consequences when companies treat requirements as paperwork rather than promises. In FY 2024, DOJ reported more than $2.9B in FCA settlements and judgments, with 979 qui tam suits filed—the highest number ever, signaling sustained scrutiny across sectors, including government procurement. [17][18]

A fear‑driven, win‑at‑all‑costs culture is spiritually corrosive and financially reckless. Servant‑led compliance is strategic risk management.

A Servant‑Leader’s Ethics Code for Competitive GovCon

1) Procurement Integrity First (Always).

Train every capture, BD, solution, and proposal teammate on what qualifies as contractor bid or proposal information and source selection information; formalize “Do/Don’t” examples and escalation paths. [10][7]
Build walls around incumbency advantages; document how you avoid unfair access to competitors’ proprietary information. [11]

2) Conflict‑of‑Interest Hygiene.

Run OCI screens at pipeline entry, pre‑RFP, and post‑draft RFP; keep living OCI matrices by role, task, and teammate. [8]
If you employ marketing consultants or former government officials, codify limitations, recusal memos, and reviews (FAR 9.5; FAR 3.104‑6). [8][7]

3) No Pay‑to‑Play (Ever).

Teach the Anti‑Kickback Act basics to sales, subcontracting, and supply chain; align referral fees and finders with lawful contingent‑fee provisions and disclosures. [12][13]

4) Gifts & Hospitality with Holy Caution.

Default to “no gifts” to federal personnel; when exceptions exist, require ethics pre‑clearance and documented value thresholds. [14]

5) Truth in Pricing, Truth in Performance.

Treat certifications (pricing, cybersecurity, small‑business reps, Buy American, etc.) as covenantal statements—because FCA liability turns on what you knew and certified. [17]

6) Whistleblowers Are a Safety Valve, Not a Threat.

Encourage internal speak‑up channels. FAR 3.9 protects contractor employees for reporting suspected wrongdoing—your culture should too. [6]

Fieldcraft You Can Use This Quarter

Ethics Pre‑Brief for Red/Gold Teams (20 minutes):

Reconfirm the sources allowed in the room; verify that no participant has unmitigated access to nonpublic info from prior work.
Read aloud the PIA basics; designate an integrity officer for the session. [7][10]

Bid/No‑Bid Self-Audit (Examen) (5 questions):1) Are we tempted to rely on information we shouldn’t have? (If yes, stop.) [10]2) Have we pressure‑tested OCIs with primes/subs and documented mitigation? [8]3) If we win this way, can we look our customer—and the taxpayer—in the eye?4) Would giving a competitor the same playbook still yield a fair fight?5) Is our story true from compliance to delivery, or are we “promising future heroics” we can’t responsibly deliver? (FCA risk) [17]

On‑Ramp Protocol for Former Government Officials:

Obtain an ethics opinion (FAR 3.104‑6), define “no‑touch” matters, and implement screens for 1–2 years as needed. [7]

The Heart Behind the Rules

David’s refrain was simple: Do not lay a hand on the LORD’s anointed. Even as a hunted man, he refused shortcuts to the throne (see also 1 Sam. 26:9). That same reverence should shape our posture toward the anointed elements of public procurement—its processes, its laws, its guardians. The Servant‑Leader does not rationalize shortcuts; we out‑serve, out‑listen, and out‑love. [3]

Because in the end, the best competitors don’t just outperform— they honor the sacred and, by doing so, outlast.

A Prayer for the Capture Room (and the Boardroom)

Lord, make us leaders who refuse ill‑gotten advantage; who steward information with clean hands; who honor competitors as neighbors; who seek the welfare of the agencies we serve; and who win, if we win, by serving well. Amen.

Sources & Further Reading

Scripture & Commentary: 2 Samuel 1 (David and the Amalekite); 2 Samuel 4 (Ish‑bosheth’s assassination and judgment). [2][4][5]
Procurement Integrity: FAR 3.104; 41 U.S.C. ch. 21 (Procurement Integrity Act). [7][9][10]
Standards of Conduct & Improper Practices: FAR Part 3; eCFR Title 48 Part 3. [6][19]
Organizational Conflicts of Interest: FAR Subpart 9.5; eCFR Subpart 9.5. [8][11]
Anti‑Kickback Act: 41 U.S.C. ch. 87; FAR 3.502‑2. [12][13]
Gifts & Ethics (OGE): 5 C.F.R. Part 2635 (gift rules). [14]
Servant Leadership: Robert K. Greenleaf, The Servant as Leader (essay). [16]
Culture & Enforcement: DOJ FY2024 False Claims Act statistics and analysis. [17][18]