Ethics And Government Contracting

Synopsis: The Federal Acquisition Regulations (“FAR”) were revised during the Fall of 2007 to add a new rule which mandated, among other things, mandatory federal contractor compliance plans and business ethics training. The rule was designed to increase awareness of contractor compliance obligations and thereby decrease violations of federal law during contract performance. The final rule, with certain exceptions, requires contractors to maintain a written code of business ethics and conduct (“Code”), make the Code accessible to all employees working on a federal contract, establish a business ethics and conduct awareness program including an internal control system, display fraud hotline posters, and flow-down these requirements to certain subcontractors. In November 2008, the rule was revised yet again to require ALL contractors to timely report suspected violations of Federal criminal and civil laws involving fraud, and conflict of interest, bribery, or gratuity violations. Failure to timely report suspected violations can result in the withholding of payment, debarment or suspension.

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