Ethics Burdens on Contractors

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Presentation transcript:

Ethics Burdens on Contractors UNCLASSIFIED Ethics Burdens on Contractors Damien Walsh Office of the Chairman Joint Chiefs of Staff, LC-HR June/July 2018 UNCLASSIFIED

Summary of FAR 52.203-15 & Related Requirements Contractors Shall: (unless an SB, or contract is for commercial items under FAR 2.101) Within 30 days of award; Have a written code of business ethics and conduct; Make a copy available to the KO; Obligation to report violations of Federal criminal law, COI or gratuity violations and violations of the False Claims Act to the Office of the Inspector General (OIG) and the KO; Show proof of: compliance and an ongoing program – not ENRON – and internal controls. Display Hotline Poster 52.203-14; Flow down through subcontracts $5.5M or more in value, and a performance period exceeding 120 days (see exclusions above); Whistleblower Protections 52.203-15; Preventing COIs, 52.203-16. Include in subcontractor flow down for contracts in excess of $150K in which employees perform acquisition functions closely associated with inherently governmental functions.

Questions Discussion Contact: Damien Walsh (757) 203-5457