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Breakout Session # 907 Bill Hemphill, Manager, Government Compliance,

Starting a Government Compliance (GC) Program. Breakout Session # 907 Bill Hemphill, Manager, Government Compliance, Siemens Building Technologies, Inc. Time 4:30 to 5:30 pm. The Nature of the Firm. Grown by acquisition and revenue Complementary to construction industry

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Breakout Session # 907 Bill Hemphill, Manager, Government Compliance,

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  1. Starting a Government Compliance (GC) Program Breakout Session #907 Bill Hemphill, Manager, Government Compliance, Siemens Building Technologies, Inc. Time 4:30 to 5:30 pm

  2. The Nature of the Firm • Grown by acquisition and revenue • Complementary to construction industry • Three product lines (matrixed divisions): • Fire Safety—active and passive systems • Building Automation—environmental control • Security Systems—active and passive syst. • Heavily commercial (about 95%) • Sales: 100+ field offices reporting to 19 districts reporting to three regions

  3. GC--My Definition • GC: A process compliance paradigm that insures that a firm meets its commitments to its government customers at all levels: • US Federal Government • State governments • County governments • Municipal governments • My efforts focused on the Federal Government • More detailed and regularly applied regulations • Recurring huge dollar opportunities

  4. Six Components of GC • Codification • Training • Communication • Auditing and measuring • Reporting • Revision

  5. Codification • Set up rules and procedures interpreting the FAR and supplements into a culturally understandable form. • We initially set up the procedures in a contract-maturity chronology • Stress the “living document” characteristic • Current version maintained electronically • SBT’s procedures are on my intranet website

  6. Procedures Family Tree

  7. Training • Two mandatory annual phases involved: • Education phase to enlighten workforce on contemporary issues and concerns • Testing phase to document participants, training received, and test scores • Training is starting out offering this electronically • Because of the size, availability, and geographic dispersion of the personnel

  8. Communication • Intranet Government Compliance website • FAQs • Procedures • Other pertinent data (SBSP, links, etc.) • Periodic electronic newsletter • Topic-specific memos • FAC summaries and impact analysis • Letters from corporate Executives

  9. Communication (con’t.) • Periodic news items, compliance memos • Shared visit findings • Audit awareness and lessons learned • Engage executive management • Non-training presentations at the district or regional sales meetings • Engaging peripheral disciplines: QA, Procurement, Finance, Operations

  10. Audit/Measurement • Field site visits to insure compliance with • Training • Internal procedures • FAR and supplements • Audit contract files • Interview key personnel • Do one-on-one training • Possibly a mini test in the future

  11. Reporting • Write timely reports upon completion of site visits • Direct to highest level required by findings • If warranted write a compliance violation report • Document findings and keep notes for two years • Follow-up with business unit if corrective action is recommended

  12. Corrective action categories (severity) Where and when Detail what was discovered and corrective action Response by offending group

  13. Corrective Action Categories • Deviation—minor impact divergence from SBT or Government procedures • Minor Discrepancy—more serious, and requires corrective action response • Major Discrepancy—very serious, with immediate imposed corrective action, and longer term corrective action in coordination with a corporate Executive

  14. Revision • Revise procedures based upon: • Site visits • Unsolicited field recommendations • Reorganization • FAR changes • Audits • Communicate the fact that there have been changes, for credibility

  15. COMPLIANCE AUDIT CONTRACT PERFORMANCE UNDERSTAND CURRENT SYSTEM PROCEDURES (CHANGE) TRAINING (CHANGE) CULTURE CONTRACT EXECUTION Nature of Compliance

  16. Contact Information Bill Hemphill William.Hemphill@siemensgovt.com Office: 703-638-5018 The antithesis to change is extinction” C. Darwin Those who fail to learn the lessons of History are doomed to forever repeat them” G. de Santayana

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