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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

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Supplier Ethics: Program Checklist

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  1. Supplier Ethics:Program Checklist

  2. 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

  3. 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

  4. 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

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

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