1. 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

2. 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 ;
Flow down through subcontracts $5.5M or more in value, and a performance period exceeding 120 days (see exclusions above);
Whistleblower Protections ;
Preventing COIs, Include in subcontractor flow down for contracts in excess of $150K in which employees perform acquisition functions closely associated with inherently governmental functions.

3. Questions Discussion
Contact:
Damien Walsh (757)