1. Purpose and Relationship to Governing Documents
This Compensation Disclosure Policy ("Policy") is published by VA WORKS, LLC ("Consultant") and forms part of the Governing Policies referenced in the Master Service Agreement (MSA), the MSA Terms and Conditions (https://vaworks.com/MasterServiceAgreement), and any applicable Scope of Work Terms and Conditions (https://vaworks.com/SOWSelection). In the event of conflict, priority shall be determined in accordance with the MSA.
The purpose of this Policy is to ensure the integrity of compensation practices, preserve trust with personnel, and prevent disruptions caused by inappropriate disclosure of invoices or payment structures to Consultant's employees or independent contractors.
2. Confidentiality of Compensation
Compensation arrangements, including salaries, stipends, and payments to Consultant's personnel, are strictly confidential. All invoices issued by Consultant to Company include costs beyond individual wages or salaries, including but not limited to statutory benefits, employer taxes, administrative fees, global payment charges, technology costs, training, and compliance expenses. The gross invoice amount paid by Company does not represent the salary of any individual personnel.
3. Restrictions on Disclosure to Personnel
Company shall not disclose, communicate, or imply to any Consultant personnel the gross invoice amounts or other client-facing billing data as if such amounts constituted the individual's compensation. Personnel are not authorized to discuss human resources, payroll, or compensation matters with Company. Any attempt by Company to bypass Consultant's role in compensation administration creates confusion, disrupts trust, and undermines Consultant's compliance with labor and employment obligations.
4. Fiduciary Responsibility of Personnel
All Consultant personnel, whether employees or independent contractors, owe their fiduciary and contractual obligations solely to Consultant, not to Company. Personnel must not engage in compensation discussions with Company, and any such discussions may result in corrective action, including formal discipline, in accordance with Consultant's internal policies and applicable foreign labor laws.
5. Recognition of Foreign Labor Law
Compensation, payroll, benefits, severance, and related employment matters are administered exclusively by Consultant in accordance with foreign labor laws governing Employer of Record arrangements and independent contractor engagements. Nothing in this Policy shall be interpreted to restrict or override any rights or obligations that are mandatory under applicable foreign labor laws.
6. Consequences of Violation
Any violation of this Policy by Company may be deemed a material breach of the MSA and subject to remedial action, including termination of services. Consultant reserves the right to protect the confidentiality and stability of its compensation practices through enforcement of this Policy.
7. Economic Consequences of Improper Disclosure
Company acknowledges that disclosing or misrepresenting invoice amounts as personnel compensation can create serious operational harm, including loss of trust, reduced morale, higher attrition, and service disruption. Such actions may also require Consultant to increase compensation levels to maintain retention, leading to higher costs passed on to Company. By respecting this Policy, Company helps preserve a stable, competitive, and cost-efficient service relationship.