Supplier Ethics: Program Checklist

Supplier Ethics:Program Checklist

Guidelines for Program Requirements • Federal Sentencing Guidelines (FSG) • Last amended 2010 • Effective Compliance and Ethics Program (Chapter 8, Part B, Section 2) • Due diligence to prevent and detect criminal conduct • Promote organizational culture encouraging ethical conduct and compliance with law • Defense Industry Initiative on Business Ethics and Conduct (DII) • Creating and Maintaining an Effective Ethics and Business Conduct Program • Suggestions for each element of an effective program • Good resource for possible additions / enhancements

Guidelines for Program Requirements (cont’d) • FAR Clause 52.203-13 “Contractor Code of Business Ethics and Conduct” • Requires government contractors to: • Exercise due diligence to prevent and detect criminal conduct • Promote an organizational culture that encourages ethics and compliance • Submit mandatory disclosures to the government • Mandates: • Code of Business Ethics and Conduct • Business Ethics Awareness and Compliance Program • Internal Control System • Subcontract Flowdown

Checklist • Checklist maps requirements of FSG and FAR, as well as DII recommendations, against program elements • Reviewers should refer to the source documents for more detail • Links to Source Documents • Federal Sentencing Guidelines §8B2 • FAR Clause 52.203-13 “Contractor Code of Business Ethics and Conduct” • DII Creating and Maintaining an Effective Ethics and Business Conduct Program • Note both potential gaps and highlights/best practices

Ethics & Business Conduct Program *for contracts of more than $5M and period of performance > 120 days Note: Bold text indicates minimum program requirement

Ethics & Business Conduct Program

Supplier Ethics: Program Checklist