A meaningful Ethics and Compliance Program can help prevent potential issues of non-compliance. In addition, agency Inspector Generals and Justice Department attorneys will examine a contractor's Ethics and Compliance Program to determine if the company implemented it in substance or just in form. If the record demonstrates that the contractor sought to reinforce its program on a continuous basis, that record may help mitigate the penalty for a failure to comply with the multitude of laws and regulations. In contrast, the lack of an Ethics and Compliance Program or one that merely offers lip service to the expected standard of business ethics and conduct will substantially increase the risk of a violation, as well as civil and criminal penalties or debarment.
Combining checklists, forms, tables, and business ethics training materials, this publication will help contractors appreciate the grounds for an alleged violation of the expected standards of business conduct and ethics and to develop, implement, and document an effective Ethics and Compliance Program in order to mitigate, if not avoid, issues of non-compliance.