CIVIL RIGHTS AND EQUAL OPPORTUNITY

DEPARTMENT

PROJECT VELVET1:
MINORITY & WOMAN BUSINESS ENTERPRISE
UTILIZATION REPORT

April 06, 2023

Revised April 26, 2023
Tanya Lewis
Civil Rights Specialist

Andrea C. Dorch, JD, MPA, CPM

Director

1
The project tenant is Meta Platforms, Inc. and is the entity formerly known as Facebook, Inc.
INTRODUCTION

Summary

Due to the highly classified and proprietary information associated with the project, this project
has been marketed, processed and approved under its code name Project Velvet. The first phases
of the project are developed for Meta Platforms, Inc. (formerly known as Facebook, Inc.)
through a created entity known as Velvet Tech Services, LLC.

The Golden Plains Technology Park/ Project Velvet was approved as an industrial development
project by City Plan Commission and ultimately granted Chapter 100 tax incentives. The project
developers received rezoning approval from agriculture zoning to accommodate 13 data center
buildings. The project plans included approximately 6.75 million square feet of construction that
crosses both Clay County and Platte County, Missouri. 2

The City of Kansas City, Missouri is the owner of the facility and will enter into a lease
agreement with Meta Platforms, Inc. once the construction is completed.

Accordingly, Project Velvet is referred herein as “Meta”.

Project and Incentive Approval Background

In August 2020, City Council approved Resolution No. 200571 to grant a modified economic
development approval process due to the “high impact” analysis the project received on the
AdvanceKC scorecard. The modification of the approval process included exemption from
Ordinance No. 160383 and a directive from City Council to expedite review of the applications
for the project and a requirement to include an ombudsman to assist EDCKC and City processes.

Meta is being financed, in part, with tax incentives pursuant to RSMo. Chapter 100. The
financing structure includes Chapter 100 bond revenue to finance the project, exemption from
sales and use tax on purchases of tangible personal property and other materials for constructing
the buildings, and other permitted uses. All Chapter 100 projects and other tax incentivized

2
City Plan Commission Docket #: 7.1, 7.2, 7.3, 7.4, 7.5; Controlling Case # CD-CPC-2020-00059 (accessed via
https://clerk.kcmo.gov/view.ashx?M=F&ID=9817142&GUID=ACF572C4-9169-420E-9DB6-5487CC4CE727 )
(last accessed 4.5.2023).

2
projects are amenable to City of Kansas City, Missouri, Code of Ordinances, Chapter 3, Article
IV. As such, under the City of Kansas City, Missouri Code of Ordinances contract and lease
requirements and EDCKC processes, minority and woman business enterprise program, local
prevailing wage, nondiscrimination employment standards, and construction employment
program should have been applied to Meta. However, the provisions under Chapter 3, Article IV,
were excluded at the City Plan Commission and waived by City Council upon contract
execution.

MWBE Program

The City of Kansas City, Missouri conducted its first contracting MWBE disparity study in
accord with City of Richmond v. J.A. Croson Co.3 in 1994 and implemented its minority and
woman owned business enterprise program (MWBE) pursuant to that study.

The City of Kansas City, Missouri codified the 2016 MWBE Disparity Study at Ordinance No.
180535. The MWBE program is designed to ensure that minority and woman owned business
enterprises are notified of contract opportunities and have the opportunity to fairly bid or make
proposals on contracts that are City funded or assisted and through the application of MWBE
contract goals.

As part of the MWBE program, CREO certifies business firms4 that are legitimately owned,
operated and managed by bona fide disadvantaged individuals, minorities and/or women. The
MWBE firms certified by the City are located in the Kansas City Metropolitan Area which
includes: Jackson, Cass, Clay and Platte County in Missouri; and Wyandotte, Johnson, and
Leavenworth County in Kansas 5. Only those firms that have been certified as an MBE or WBE
by the City are counted towards participation goals to ensure that the program is narrowly
tailored to eliminate marketplace discrimination.

3
488 U.S. 469 (1989)
4 The City also certifies federally defined disadvantaged business enterprises (DBE) and small business enterprises (SBE). The

DBE/SBE program is normally applied to federally funded and/or assisted contracts. These programs are not discussed in this
report and are mentioned here to distinguished the City’s MWBE program from the Federal DBE/SBE program.

5
These seven counties are included as part of Kansas City, Missouri’s contracting requirements because they are
regarded as having a close commercial nexus to the City of Kansas City, Missouri and to ensure compliance with
constitutional equal protection requirements.

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MWBE goals

The MWBE program applies to all professional contracts that exceed $160,000 and all
construction contracts that exceed $300,000. The following types of contracts are excluded:
personal services contracts, emergency contracts, and imprest accounts in the nature of petty
cash funds.

The city-wide goals for MWBE participation are established at: 6

o MBE: 14.7%

o WBE: 14.4%

These goals establish the baseline for the city in its overall endeavors to ensure that good faith
efforts to include minority and woman owned firms on city funded or assisted contracts are
accomplished.

Pursuant to Ordinance No. 180535, all tax incentivized projects that meet the threshold for
professional and construction services are required to include MWBE goals. For Chapter 100
projects, the goals are established based on the scopes of work anticipated for the project. An
analysis of the marketplace at the time of the Meta project was used to determine the availability,
willingness and ability of MWBEs to participate.

Due to the waiver of goals by City Council, CREO did not receive the normal developer’s scope
segmentation for professional or construction services. Subsequently, CREO found that the
professional services budget had been fully contracted and that limited or no opportunities
remained for contracting MWBE firms for participation.

Accordingly, CREO was unable to analyze the project under normal procedures. Instead, CREO
analyzed the project using historical data for typical industrial facilities. The comparative
projects used to determine appropriate goals for Meta are: the Kansas City International terminal
modernization project and Cerner South Kansas City campus data and office facilities. These
projects were used to determine availability of MWBE construction contractors for Meta. Both

6
See footnote 2 (herein); also reference City Resolution No. 200571; City Ordinance Nos. 210313, 210837, 210841,
211119, and Project # TAP3324(412) Route 152 Trail Segment 12.

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historical projects were considered design/build and had an estimated value exceed $1 billion.
The historical utilization had average goals of 15% MBE and 15% WBE. These projects
combined to determine MWBE availability.

There were more than 300 MWBE firms with a total combined contract value of $355.87 million.

Accordingly, the construction services goals for Meta project should have been set at 15% MBE
and 15% WBE, with an estimated value of $300,000,000 in MWBE construction services
contract availability and more than 300 available firms to participate.

NOTE: This project included other peripheral projects funded directly by the City, including:
water main extensions, landscaping, stream buffers, bike and walking trails, and tree/vegetation
plans. Goals for these peripheral projects were set individually either at Missouri Department of
Transportation or by CREO.

Additional City Requirements

The Construction Workforce Program, Local Prevailing Wage, and Equal Employment
Standards are required on all city funded or assisted projects, including Chapter 100, unless
waived by the CREO director or City Council. Although required, none of these mandates were
included on Meta.

Each requirement is described below.

Construction Workforce Program: The City codified the Construction Workforce Program
(also known as Construction Employment Program) for inclusion of minorities and females on
construction projects at Ordinance 130041, as amended. The Construction Workforce Program
requires that city funded or tax incentive construction projects exceeding $300,000 and estimated
to exceed 800 workforce hours include minority and female participation goals of 10% minority
workforce hours and 2% female workforce hours.

7
Totals are across KCI-TMP construction services, Cerner Phase 10 construction services, Cerner Phase 1
construction services and Cerner Phase 4 construction services. NOTE: Cerner has other phases that were not
included in this total because for reference, the other projects had smaller scopes of work segmentation.

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Prevailing Wage: The City’s Prevailing Wage Ordinance requires that construction projects
exceeding $75,000 include requirements for construction contractors to pay prevailing wage
under Missouri Annual Wage Order for trades under the Code of State Regulations (CSR).

Equal Employment Standards: City Code Sec. 3-517 requires that all
city construction contracts contain language requiring as a condition thereof that
all construction contractors will adhere to the equal opportunity clause set forth in the Code of
Ordinances, chapter 38, article III, section 38-103. The equal opportunity clause shall include, at
a minimum, the following provisions:

(1) The construction contractor will not discriminate against any employee or applicant
for employment because of race, color, religion, sex, national origin or ancestry, disability,
sexual orientation, gender identity or age.

(2) The construction contractor will take affirmative action to ensure that employees are treated
fairly during employment without regard to their race, color, religion, sex, national origin or
ancestry, disability, sexual orientation, gender identity or age. Such action shall include, but not
be limited to the following: employment, promotion, demotion, or transfer; recruitment or
recruitment advertising; layoff or termination; rates of pay or other forms of compensation; and
selection for training, including apprenticeship.

(3) The construction contractor agrees to post in conspicuous places, available to employees and
applicants for employment, notices to be provided setting forth the provisions of the
nondiscrimination clause:

• the construction contractor will, in all solicitations or advertisements for

employees placed by or on behalf of the construction contractor, state that all
qualified applicants will receive consideration for employment without regard to
race, color, religion, sex, national origin or ancestry, disability, sexual orientation,
gender identity or age;
• in the event of the construction contractor's noncompliance with the
nondiscrimination clauses of this contract or with any of the said rules,
regulations, or orders, the director shall bring a complaint before the human rights
commission and the contract may be canceled, terminated, or suspended in whole
or in part and the construction contractor may be declared ineligible for further
contracts with the city for a period of one year should the construction contractor
fail to agree to comply with the terms of any order arising from that proceeding.

Applicability and Reporting Requirements

All developers are treated as Prime contractors on City or tax incentivized contracts. Developer’s
general contractors and project management subcontracts are required to comply with all
reporting requirements through flow down provisions. All tax incentivized contracts are required

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to include MWBE provisions and the applicable goals for the particular contract unless waived
by the City Council. MWBE Contractor Utilization Plans (CUP) to meet the goals are required to
be submitted to CREO. Developer’s CUPs are required to include names, addresses, scopes of
work, contract values of each subcontractor, and the amount paid to each respective MWBE
subcontractor. CUPs are entered into CREOs diversity management system, B2Gnow, for
monitoring contractor and subcontractor payments for compliance with City Ordinance 180535,
progress towards meeting goals, and to ensure that payments are made pursuant to the Missouri
Prompt Pay statute.

Additionally, construction contractors and subcontractors are required to submit certified

payrolls for compliance with local resident tracking, local prevailing wage requirements and
labor standards enforcement.

Meta refused to comply with any of these provisions.

Compliance and Enforcement Background

CREO received several complaints from construction labor, minority and woman owned
contractors, and organizations that represent businesses and labor.

Minority contractors reported that they were discriminated against in contracting on the project.
Additionally, CREO received reports of racially motivated intimidation on the project, including
effigies being hung in facilities on the project. CREO also received inquiries from the Black
Chamber of Commerce of Greater Kansas City because many of its members were inquiring as
to whether any further professional and construction opportunities existed for Meta.

On behalf of labor, Manny Abarca contacted CREO, City Council, the Mayor and the City
Manager’s office multiple times. Additionally, the Fair Contracting Alliance8 inquired multiple
times whether prevailing wage was applicable to Meta because they were being denied access to
publicly available information, such as contracts and payrolls.

After many complaints directed to Councilmember Lee Barnes, CREO was contacted regarding
the status of the Meta project. Upon receiving a copy of the contract, and several

8
The Fair Contracting Alliance is an entity created to monitor city funded and assisted projects for tracking
compliance with Missouri and Kansas City prevailing wage requirements.

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communications between CREO and the City’s Law Department, it was revealed that the
MWBE program requirements, prevailing wage, construction workforce program, and
employment standards were not included in the Meta project.

In late 2022, in consultation with Assistant City Attorney Emalea Black and Economic
Development Manager, Mario Vasquez, Director Andrea Dorch requested that an amendment be
made to include MWBE contract goals, prevailing wage and nondisrimination employment
standards be included. ACA Black concurred and developed an amendment for Director Dorch
to approve. Director Dorch approved the amendment with few modifications.

Voluntary Compliance

After CREO acquired the documentation associated with Meta, CREO reached out to James
“Jim” Bowers, local attorney for Meta. Bowers assembled the Meta team and Turner
Construction to meet with CREO and City officials.

City Councilmembers Dan Fowler, Kevin O’Neill, and Lee Barnes attended the meeting along
with CREO staff, Director Andrea Dorch and Civil Rights Investigators Tanya Lewis and
MauRece Green.

The discussion resulted in a consensus that Meta and Turner Construction would voluntarily
comply with the requirements of the MWBE program, $15.00 minimum wage9, and the
Construction Workforce Program. Specifically, Meta agreed to allow the CREO compliance
investigators to attend safety training and to interview workers and subcontractors onsite.
Further, to avoid any further delays, Director Dorch and Turner Construction (on behalf of Meta
Platforms, Inc.) agreed to use the Meta project as a “but for”10 project to assess whether the
MWBE program is having a remedial effect in public and private contracting as it relates to
utilization of MWBE firms.

9
The City’s Prevailing Wage requirements were contested by Turner Construction due to the project’s collective
bargaining agreement with several labor organizations. Therefore, the City’s Quality of Services Assurances Act
was decided to be the minimum requirement for worker’s wages on the project at $15.00/hour.
10 A “but for” analysis answers the question of whether bona fide local, small, minority and woman owned firms

would be utilized in the marketplace if there was no requirement to use such firms.

8
In anticipation of the voluntary compliance, Mario Vasquez submitted the contract amendment
with MWBE inclusion to Meta for signature. Despite Turner and Meta’s agreement to
voluntarily comply with the MWBE program and the Construction Workforce Program, the
Meta attorney, James “Jim” Bowers, Councilman Dan Fowler and Councilman Kevin O’Neill
immediately contacted City Manager Brian Platt to insist that CREO cease compliance and
auditing activities of the project. Additionally, Attorney Bowers advised that his client would
not sign the MWBE amendment approved by Director Dorch and instead requested to have no
goals attached to the project. Director Dorch was advised by City Manager to accept a “no goals”
second amendment drafted by ACA Black.

Turner Construction then advised its subcontractors that they were not required to comply with
CREO’s request to audit contract payments or worker hours, despite the agreement from Meta
and Turner Construction to “voluntarily comply” with the MWBE program and the Construction
Workforce Program, which includes reporting and auditing.

The following email was sent to Turner Construction contractors and subcontractos on or about
February 9, 2023:

KCM Trade Partners,

Some of you have been receiving Workforce Utilization and Compliance reporting notifications
from KCMO CREO Department. We want to reassure you this project is not subject to these
reporting requirements. Turner and Meta have voluntarily agreed to submit an MWBE matrix and
Workforce reporting from our security badging system on a monthly basis. NO action is required
by you.

Below is a statement you can copy and paste if you receive these notifications. The City Manager
and Andrea Dorch have also said the notifications can be turned off from your end if you
wish. We will leave that up to each company to make the decision.

Forward notification back to Tanya Lewis & Maurece Green

(emails Tanya.lewis@kcmo.org, Maurece.Green@kcmo.org). You are welcome to copy Andrea
Dorch as well if you would like. Add the statement below to your message.

Please forward this information to your team members as needed. Please feel free to reach out
with any questions. Thanks.

KCMO CREO Team,

This project is not subject to CREO reporting requirements. Turner and the Client have
agreed to submit voluntary compliance documentation on behalf of the entire project by
the 5th of every month. No further action is required on our behalf.

Thank you,
{your name/signature block}

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 Rebecca Kalinowsky | Project Executive
Turner Construction Company |
Mobile 303.725.9889 | rkalinowsky@tcco.com

After this email was sent, Councilmembers and Mr. Bowers again contacted Brian Platt to insist
that Director Dorch eliminate the normal requirements for reporting and to just accept the
summary data submitted by Turner Construction. Director Dorch explained that without analysis
or compliance with reporting requirements, CREO would be unable to validate, verify or
reconcile the information for compliance with the programs. CREO had spent more than 80
hours to enter the information in the database. After pressure from the City Manager’s office
and City Councilmembers, CREO office turned off the compliance audits that were sent to:
Meta, Turner Construction, contractors and subcontractors. Additionally, CREO investigators
were denied any access to the workers or contractors onsite after their initial safety training.
These actions conveyed to CREO that Meta and Turner Construction did not intend to
voluntarily comply with the program requirements as detailed in City of Kansas City, Missouri
Code of Ordinances, Chapter 3, Article IV.

Rather than voluntarily comply in a transparent manner, Turner Construction Company

determined that it would control the narrative as it relates to utilization of businesses without any
independent verification. Additionally, based on numerous complaints from subcontractors,
including complaints of racial discrimination in the form of a “noose” hanging onsite, many
subcontractors reported feeling “stuck” in an exclusionary public contracting process.

Investigator Narrative & Data Analysis

This narrative conveys information shared with CREO collected from Turner Construction
Company representatives working directly with the Meta project. Analysis of provided data
directly relates to Turner Construction’s synthesized summary reports to Civil Rights and Equal
Opportunity department.

Based on interviews with minority and woman owned businesses (MWBE), some minority
businesses and contractors were chosen by Turner to discuss bid opportunities. These businesses
were invited to a secretive bid meeting to sign non-disclosure agreements (NDA) where it was

10
stated repeatedly that the agreements would be enforced whether the MWBE were awarded
contracts or not. Many minority businesses reported that they felt intimidated.

According to contractor reports, contracts were either pending or done on a work order basis, not
contract values as in traditional development projects.

By late 2022, construction started without a clear plan for utilization of certified MWBEs.
Turner Construction refused to submit any City approved documents or provide a listing of the
actual contracts awarded on the project. Therefore, there is no voluntary compliance with the
requirements of Chapter 3, Art. IV of the City of Kansas City, Missouri Code of Ordinances.

Project Labor Agreements

Additional requirements were added to subcontractors on the project that were not signatory to
collective bargaining organizations. Non-signatory construction contractors were required to
sign project labor agreements on the project, pay Union fringe benefits, and minimum trade-
specific wages. Under Missouri Law, RSMo. 34.209.1(1) (transferred in 2022 a RSMo. 9.968),
prohibits the public entity from requiring or prohibiting “contractors or subcontractors” to enter
into or adhere to agreements with one or more labor organizations on the same or related
projects. This prohibition applies to entities receiving tax incentives from a municipality for the
construction, repair, remodeling or demolition of a public works facility. Additionally, under the
National Labor Relations Act, “construction contractors and employees have the right to choose
to unionize or not to unionize.” On Meta, no contractor has been allowed to opt out of signing a
project labor agreement despite the vast majority of contractors and their workers – more than 80
percent – have said they do not wish to unionize permanently or temporarily but felt compelled
to do so.

Project labor agreements usually require contractors to grant union officials monopoly
bargaining privileges over all workers, use exclusive union hiring halls, force workers to pay
dues to keep their jobs and pay above-market prices. Qualified non-union contractors who wish
to make lower-cost bids, and their employees who wish to work non-union, are then locked out
of the project; losing access to millions of dollars in revenue for their businesses and
communities. Politicians and government officials continue to utilize project labor agreements in

11
contradiction to the Missouri prohibition against mandatory signatory on public projects to the
detriment of small business owners.

Contract Data Analysis

Turner Construction submitted monthly reports beginning December 2022 through April 2023.
This analysis is based on data submitted between December 2022 through March 30, 2023.
Without accurate scope segmentation, CREO could not independently verify any contract data
submitted by Turner Construction.

The historical projects used for comparative analysis are the Kansas City International terminal
modernization project (KCI) and Cerner South Campus (Cerner) project. Both projects had
estimated budgets that exceed $1 billion and more than 4 million worker hours. The projects’
final utilization data were combined for comparison to the Meta project.

The KCI and Cerner combined projects include approximately 300 MWBE firms and more than
$355 million in total MWBE intended contracts for construction services.

Meta construction estimate is approximately $800 million. Based on the summary reports
submitted by Turner Construction, MWBE intended utilization includes 28 verified, certified
MWBE firms. The values associated with the 28 MWBE firms account for $44 million (or
approximately 5%) intended MBE firms’ participation and $88 million (or approximately 11%)
intended for WBE firms’ participation.

CREO found that the Turner Construction reports are either (1) overinflated contract values
distributed over 28 MWBE firms; or (2) utilization of MWBE contractors are to be used as extra
participants in the intended contracts which would result in a non-commercially useful function
being performed by the MWBE firms in violation of the City Code requirements.

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Below is a list of the firms listed on the Turner Construction summary reports that have verified
Kansas City MWBE certification (listed in alphabetical order):
• 4 Gen Construction, Inc.
• A Clean Slate, LLC
• AGP, INC.
• Alexander Mechanical INC.
• Axiom Construction Group LLC
• Blue Cedar Landscaping
• CJ Industries, LLC
• CJR Construction Group Inc
• Clean It All LLC
• Cornelll Roofing & Sheet Metal Co.
• DAX Safety
• DB Flooring dba Regents Flooring
• DMMC, LLC, dba Davis Minority Mechanical Contracting
• Encompass
• JA Lillig Excavating, Inc.
• Katie’s Catering
• LM2 Construction
• Lumber dba Albert Tamm Lumber Company
• Miller Sign Shop
• Odimo LLC
• Parrish & Sons Construction, LLC
• Pro Metals, LLC
• Sorella Group Inc
• T-Shirt King
• Three Feathers Construction & Sales, LLC
• TREKK Design Group, LLC
• We Got It Covered Food Service
• Wilkerson Crane Rental, Inc.

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Turner Construction has refused to submit formal CUPs, complete monthly audits for
verification of contract payments and construction workforce audits, and has refused periodic
onsite audits the project. Turner Construction asserts its refusal is based on their own analysis
and its established internal “UBE11” plan. Based on meetings with Turner Construction
representatives, Turner Construction stated that the UBE plan ensures inclusion but does not
analyze certification to ensure legitimate MWBE ownership. To this point, CREO is unsure of
the accuracy of the data as provided.

Final analysis of the provided data indicates that Turner Construction Company’s participation
efforts have been less than effective. Actual utilization for : 14% combined MWBE utilization.
Certified MBE utilization is at 5% and the certified WBE utilization is 9%. Based on Turner
Construction’s future intended contracts, MBE utilization will be approximately 5.5% MBE and
11% WBE.

The contract distribution by ethinicity and dollar value is as follows:

White--$88,406,996
Black--$33,559,289

11
CREO could not verify what a UBE program is or how it works.

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Hispanic--$10,659,634
Other--$5,938,333
Construction Workforce Analysis
Turner Construction submitted worker badge data that measured the number of workers entering
the site daily but did not capture the number of hours the workers were onsite. Due to
noncompliance with workforce audit reporting, CREO could not verify the data as submitted.
However, because Turner Construction submitted unredacted, machine generated data, CREO
has reason to rely on the veracity of the worker data submitted, even in limited form.

CREO analyzed the data submitted to create the following breakouts.

The monthly average for the number of individual construction workers on the project site is
about 1,135 persons. The following ethnicities were recorded as being self-identified on the
construction site. This data is based on the number of people, not the number of hours worked.

• White: 67%
• African American: 5%
• Hispanic: 5%
• Asian: 1%
• Native American: 1%
• Other: 2%
• Unspecified: 19%

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 Turner/Partners

MWBE Subprime Data

Out of the contract data submitted, CREO reviewed the intended contracts for MWBE as being
either subprime or subcontractor. An MWBE firm is considered a “subprime” if it is the
responsible project manager for the entirety of a particular scope of work which includes
retaining qualified subcontractors to assist in the completion of a portion of the entire scope of
work. An MWBE firm is considered a “subcontractor” if it is responsible for only a portion of
particular scope of work.

CREO found that there were 8/28 firms that had intended subprime contracts. At least one of the
subprime contracts is a Joint Venture between MWBE firms. The value of the subprime MWBE
contracts could not be determined because of the lack of segementation in the Turner
Construction synthesized summary report.

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Conclusion

Data supplied by Turner Construction demonstrates the necessity for Kansas City ordinance
application to ensure civil rights and equal opportunities for businesses and workers. It has
provided no transparency in hiring practices, shows limited MWBE inclusion despite clear
marketplace availability, and Turner Construction has also been deceptive in its contracting
practices.

The Meta data center is a perfect storm noncompliance and violations of local, state and federal
laws for equal opportunity and protection under the law. The project has utilized union aligned
contracting firms and weaponized NDAs to prevent transparency in the marketplace in order to
inspire fear and control over local businesses, small businesses, and MWBE businesses.

Recommendation

CREO recommends that an amendment to the Meta contract dba Project Velvet under Velvet
Tech Services, LLC be required by ordinance prior to any future bond revenue payments. The
amendment should include the following: (1) MWBE program goals for construction at 15%
MBE and 15% WBE; (2) MWBE program goals for professional services on future phases at
14% MBE and 14% WBE; (3) employment nondiscrimination clauses as required by Chapter 3,
Art. IV; (4) Construction Workforce Program with construction worker hours at 10% minority
participation and 2% female participation; (5) local prevailing wage requirements; (6) Missouri
prohibitions against project labor agreements in compliance with Missouri revised statutes; (7)
Nondiscrimination Against Israel as required by Missouri revised statutes; and (8) compliance
with reporting and onsite auditing requirements.

[END OF REPORT]

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