1. Home
  2. |Insights
  3. |Déjà Vu: Another FAR Rule On Contractor Codes Of Business Ethics And Conduct

Déjà Vu: Another FAR Rule On Contractor Codes Of Business Ethics And Conduct

Client Alert | 1 min read | 11.26.07

The Federal Register of November 23 published a final rule (http://www.crowell.com/PDF/FAR-Rule-On-Contractor-Codes_Federal-Register_11-23-07.pdf), effective December 24, which adds new features to the FAR mandating specified contractor standards of conduct (except for commercial item contracts and contracts to be performed entirely outside the United States), for new contracts expected to exceed $5 million (base plus option year value) and performance of 120 days or more (including flow down to subcontractors of the same value and performance duration). The mandated standards of conduct include (i) having a written code of business ethics and conduct; (ii) providing a copy of the code to all employees performing the contract; (iii) promoting compliance with the code; and (iv) except for small businesses, establishing an ongoing business ethics and conduct awareness program and an internal control system which facilitates timely discovery of improper conduct in connection with Government contracts and ensures prompt corrective actions (such program to include periodic reviews of company business practices, a "hotline," internal and/or external audits, and discipline for improper conduct).

Insights

Client Alert | 3 min read | 04.25.24

JUST RELEASED: EPA’s Bold New Strategic Civil-Criminal Enforcement Collaboration Policy

The Environmental Protection Agency’s (EPA’s) Office of Enforcement and Compliance Assurance (OECA) just issued its new Strategic Civil-Criminal Enforcement Policy, setting the stage for the new manner in which the agency manages its pollution investigations. David M. Uhlmann, the head of OECA, signed the Policy memorandum on April 17, 2024, in order to ensure that EPA’s civil and criminal enforcement offices collaborate efficiently and consistently in cases across the nation. The Policy states, “EPA must exercise enforcement discretion reasonably when deciding whether a particular matter warrants criminal, civil, or administrative enforcement. Criminal enforcement should be reserved for the most egregious violations.” ...