Global Files Formal Ethics Complaint Concerning Procurement Oversight in MassDOT RFP Process

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Concerns Include Apparent Conflicts of Interest and Failure to Disclose Outside Engagements by MBTA Official acting as Head of Selection Committee

Waltham, Mass. (July 24, 2025) – Global Partners, a leading independent liquid energy supplier and retail operator, has filed a formal complaint with the State Ethics Commission identifying serious concerns about the conduct of Scott Bosworth, a Massachusetts Bay Transportation Authority (MBTA) official, who played a central role in overseeing the Massachusetts Department of Transportation (MassDOT) Request for Proposal (RFP) process for the state’s Service Plaza lease.

The complaint raises concerns about Mr. Bosworth’s impartiality and possible undisclosed external engagements, and whether the integrity of the public procurement process was compromised by the actions of Mr. Bosworth as the head of the selection committee, ultimately resulting in MassDOT foregoing a guaranteed $1.5 billion in rent in favor of a foreign, private equity-backed proposal offering significantly less public value, and no apparent current financing.

 

Key Concerns Raised in the Complaint 

  • Potential Conflict of Interest: Mr. Bosworth engaged in discussions regarding employment opportunities with Blackstone Infrastructure Partners, the majority owner of Applegreen, the selected bidder, during a period in which Applegreen was working on the anticipated RFP.
  • Failure to Disclose: Mr. Bosworth’s conduct may have violated Massachusetts General Laws Chapter 268A, Section 23(b)(3), which prohibits state employees from acting in a manner that would cause a reasonable person to conclude that they could be unduly influenced in the performance of their official duties due to personal interests, unless that employee makes a written disclosure to their appointing authority. No such disclosure appears on the State Ethics Commission’s public database for the period 2022 to present and the question should be asked if Mr. Bosworth appropriately reported any potential conflict to MBTA General Manager Phil Eng.
  • Improper Influence: Multiple individuals with knowledge of the process have expressed concerns that the actions of Mr. Bosworth, and possibly other members of MassDOT, throughout the RFP process may have improperly influenced the outcome, including possible inappropriate communications with bidders, their RFP partners, and questionable internal committee decisions.
  • Why was an MBTA Official Overseeing a Highway Lease Process? While Mr. Bosworth currently serves as Chief of Transit Oriented Development and Innovative Delivery at the MBTA, he chaired a MassDOT RFP for highway service plaza redevelopment and operations. This overlap raises fundamental questions about jurisdiction, transparency, and appropriate oversight within state transportation agencies.

 

Background on Scott Bosworth 

In 2015, Mr. Bosworth was appointed to MassDOT by then-Governor Baker to drive real estate and public-private development strategy. In 2023, under General Manager Phillip Eng’s reorganization of the MBTA (an organization responsible for subway, bus, Commuter Rail, ferry, and paratransit service to eastern Massachusetts and parts of Rhode Island), Mr. Bosworth was named to lead Transit Oriented Development. That role now appears to include oversight over highway infrastructure contracts, despite limited public clarity on the scope of that authority.

This is not the first time Mr. Bosworth’s professional relationships have raised ethical questions. In 2017, the Boston Herald reported that Fort Hill Companies, where Bosworth held a 49% ownership stake, had received more than $300,000 in taxpayer-funded contracts, plus a $750,000 MBTA energy consulting contract, plus additional multi-year MBTA contracts, just months after his appointment to his prior role as MassDOT’s Chief Strategy Officer position, despite his stated recusal from matters involving his former firm.

The current suggestions of impropriety may reflect a troubling pattern of behavior that undermines public confidence in the integrity of Massachusetts transportation procurement processes.

 

Request for Review and Full Disclosure 

Global is calling for a formal inquiry into the following areas:

  • Undisclosed Communications: Whether Mr. Bosworth or other members of the MassDOT Selection Committee engaged in any discussions, formal or informal, with representatives of Blackstone, Applegreen or any other major participant involved in their bid.
  • Failure to Disclose Conflicts: Whether Mr. Bosworth properly disclosed any real or potential conflicts of interest, including relationships or employment discussions with parties affiliated with the selected bidder, to MBTA General Manager Phil Eng, MassDOT leadership, or the State Ethics Commission, as required under state law.
  • Manipulation of RFP Criteria: Whether any member of the MassDOT Selection Committee altered the structure or evaluation criteria of the RFP in a manner intended to unfairly advantage Applegreen or otherwise skew the process to favor a specific bidder. Global specifically notes highly consequential to the Commonwealth alterations made to the RFP in addendums issued weeks prior to the proposal submission date.
  • Misrepresentation to the Board: Whether Mr. Bosworth failed to appropriately provide the MassDOT Board with material information related to their decision-making process, when he failed to provide a side-by-side financial comparison of the bids and then misleadingly stated that the bids were “very close” in value.
  • Suppression of Independent Review: Why employees of consultants hired by MassDOT to provide independent input during and after the procurement process were removed after raising concerns about Mr. Bosworth’s and/or the Selection Committee’s conduct.

 

Public Records Stonewalled 

Global, as others involved in the RFP process, has filed multiple Public Records Requests related to the RFP process, designed to further delve into the potentially improper actions. Despite legal obligations under M.G.L. c. 66, § 10, MassDOT has failed to timely produce critical documents, prompting Global to file a formal petition with the Secretary of State’s Office for violation of the Public Records Act.

 

Global Partners Position

“This isn’t about one contract, it’s about the integrity of public procurement in Massachusetts and protecting the interests of Massachusetts taxpayers,” said Sean T. Geary, Global Partners Chief Legal Officer. “The public deserves to know that billion-dollar plus decisions are made based on facts, not favoritism. When potential conflicts arise, they must be disclosed and investigated. We hope the State Ethics Commission’s inquiry will restore faith in a process that, by every indication, has failed to appropriately serve the public interest.”

 

Media Contact:

Reid Lamberty, Senior Communications Advisor

[email protected]

516-305-1210