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Frequently Asked Questions (FAQs) – OESC Group’s Oneida Environmental subsidiary’s contract w/Federal Government Re: Facilities Associated with ICE

General

Did the OBC make the decision to enter the contract with Immigration Customs and Enforcement (ICE)?

A: No, the OBC did not make the decision to enter into a contract with ICE; the OBC was not aware this decision was made and did not have details on dollar amount, scope, or intent. This was a corporate contract between a subsidiary of OESC Group, Oneida Environmental and Stantec Joint Venture in the amount of $3.8m.

What is OESC?

A: Oneida ESC Group, LLC (OESC) is a corporation wholly owned by the Nation. OESC is a holding company comprised of several subsidiaries, many of which are SBA 8(a) companies that are eligible for direct awards from the federal government. Additional information about OESC can be found on their website at: https://oescgroup.com/

Who manages OESC, is it the Oneida Business Committee?

A: No, the OBC does not manage the day-to-day operations of OESC. There is a board of managers who are responsible for the oversight of OESC; their responsibilities and required qualifications are outlined in the corporate charter. All of the Nation’s tribally charter entities governing documents are available for viewing on the Nation’s tribally chartered entities webpage at: https://oneida-nsn.gov/government/triballycharteredentities/

When did the OBC know about this contract?

A: The OBC became aware the contract existed late Monday, December 29, 2025, and did not have the full facts about the contract. The OBC took immediate steps to begin completing necessary due diligence to identify as many facts as possible. The OBC met on Tuesday, December 30, 2025, to review the information collected, ask additional questions and seek additional information.

The OBC does not manage and is not involved in day-to-day operations of tribally chartered corporations. The OBC would not have been made aware of or been privy to any specific actions or contracts awarded to any corporation.

What steps has the OBC taken to address this contract?

A: The OBC issued a press release to provide information to Nation citizens as quickly as possible that entering into a contract with ICE, regardless of intent, is a condemnable action. Further, the OBC identified that the Nation’s corporations, representatives, and employees must align with the Nation’s Core Values and the OBC passed a resolution to ensure no future ambiguities arise.

Has this contract been terminated?

A: In an open letter, on December 31, 2025, the CEO of OESC provided an apology for this decision, provided an explanation for decision, and informed all Stakeholders that steps are being taken to sever the contract. This letter can be found on the Nation’s website on the corporation’s page at: https://oneida-nsn.gov/government/triballycharteredentities/#Oneida-ESC-Group-LLC

Are there other contracts with ICE or other questionable contracts that should be reconsidered?

A: OESC has several subsidiaries that do work with the federal government. It is the OBC’s expectation that OESC will review current and pending contracts to ensure current and future alignment with the Nation’s Core Values.

How could the Nation allow this to happen?

A: The Nation provides for separate chartered corporations to ensure the Nation is protected from certain liabilities relating to a corporation’s business decisions. The Nation requires regular reporting from each of its corporations; however, in order to maintain a corporate veil, the Nation does not engage in day-to-day decision-making of its corporations, there are boards in place which are responsible for oversight.

The OBC appoints members of the Oneida Nation to corporate boards who are aware of the Nation’s Core Values and are expected to provide guidance to corporate employees on how those should be considered in decision-making.

What is a “corporate veil”?

A: A Corporate Veil is a legal concept that recognizes a company as a separate legal entity distinct from its shareholders and it protects shareholders from personal liability for the company’s debts and obligations (meaning the company itself is responsible for its own liabilities). Piercing the corporate veil refers to a situation in which courts put aside limited liability and hold corporation’s shareholders or directors personally liable for the corporation’s actions or debts.

How does the Nation benefit from businesses like OESC?

A: Owning a holding company such as OESC, Oneida Golf Enterprise or BayBank corporation has several advantages, including timely decision-making, limiting liability of the Nation, asset protection, tax advantages, investment diversification and return on investment.

Over the years, OESC and others have returned millions of dollars back the Nation that support community infrastructure and other projects.

Where are the OESC corporation’s governing documents, can I get a copy?

A: The Nation places all its corporation’s information on the website for public viewing. The information is located here: https://oneida-nsn.gov/government/triballycharteredentities/

Why would an entity of the Oneida Nation even consider doing business with an entity anywhere near the mention of ICE?

A: In an open letter, on December 31, 2025, the CEO of OESC provided an apology for this decision, provided an explanation for decision, and informed all Stakeholders that steps are being taken to sever the contract. This letter is available for review on the Nation’s website at: https://oneida-nsn.gov/government/triballycharteredentities/#Oneida-ESC-Group-LLC

How do we assure this does not happen again?

A: The OBC takes its oversight role of the Nation’s corporations seriously and sincerely apologizes to Oneida’s citizens for the OESC’s subsidiary, Oneida Environmental, egregious decision in this matter.

The OBC is reviewing all processes and communications requirements between the Nation and its corporations to identify gaps and then take both a legal and due diligence approach to correcting them. These steps may take some time to ensure thoroughness and legal requirements are met; however, direction to begin this process has already started and should be completed within the current quarter.

The OBC has taken steps to replace the OESC Board of Managers with an interim board manager until a new board can be appointed. Also, the OBC has passed a resolution which will require all tribal corporations to adopt Corporate Social Responsibility Policies based on the Nation’s Core Values.

Are Oneida’s corporate entities required to follow the Nation’s values?

A: The OBC has passed a resolution which makes clear this specific contract does not align with the Nation’s Core Values. The OBC has also identified several next steps that may need to be taken, one of which includes requiring all of the Nation’s corporations to adopt Corporate Social Responsibility policies that align with the Nation’s Core Values.

The OBC has adopted a resolution which requires the Nation’s corporations to incorporate the Core Values into a CSR policy.

Is OESC just Seven Generations with a new name?

A: No, OESC is not 7 Generations with a new name. OESC is a holding company that evolved from Oneida Total Integrated Enterprise (OTIE) which is an engineering company that was acquired by the Nation. OESC has several subsidiaries all with varying specialties. When the Nation took full ownership of OTIE, and OTIE graduated from their 8a program, OTIE then became a subsidiary of the OESC Group.

It is also notable that 7 Generations Corporation was dissolved per GTC action. That business had assets (commercial properties with leasing mostly) that needed to be managed, so those assets were purchased by OESC for no profit and placed in 1822 development company. For example, there was an agreement in place for the property leased by the company Kitchen Fresh which needed to be managed moving forward.

Who is responsible for interpreting which political issue aligns with our Nation’s Core Values (regarding accepting contracts)?

A: All of the Nation’s employees, representatives and tribally owned corporations are responsible to understand and actively practice the Nation’s Core Values. There is no single person or entity responsible to ensure political alignment; however, the Nation’s OBC and Intergovernmental Affair’s team is usually the most knowledgeable about current or trending issues relating to political issues at the local, state, tribal and federal levels.