Many government contractors are required by their contracts to have a code of business ethics and implement a compliance program and internal control system. The Federal Acquisition Regulation, at FAR 52.203-13, identifies the expected elements to be included in the code, compliance program, and internal control system. If a contractor is subject to this FAR clause, it is not sufficient to use compliance materials developed for commercial business. Instead, contractors must be aware of and comply with the specific requirements set forth in this clause. Failing to do so could result in a breach of contract allegation or possible suspension or debarment. In addition to a code of business ethics, compliance program and internal control system, the clause also requires contractors to make disclosures to the government when they have credible evidence of certain civil and criminal violations. Determining when to make a mandatory disclosure can be tricky but failure to comply with the rule can put the contractor in an unfavorable position with the government. Moreover, it is critical to be aware that while not every contract contains FAR 52.203-13, similar disclosure obligations are found in the suspension and debarment regulations, which apply to all government contractors and subcontractors, regardless of contract value.

This 90-minute webinar will provide an overview of the requirements outlined in FAR 52.203-13 for a code of business ethics, business ethics awareness and compliance program and internal control system. It will also review the key requirements associated with the mandatory disclosure rule and will address the relationship between the disclosure requirement in FAR 52.203-13 and the disclosure expectations in the suspension and debarment regulations in FAR Part 9. The webinar will also address the consequences of failing to comply with all aspects of the compliance and disclosure obligations placed on contractors. Then the speakers will provide an in-depth review of best practices, as learned through experience by government contractors and as specified by the government, for complying with FAR 52.203-13 and the mandatory disclosure obligations.

Learning Objectives

• Become familiar with the specific requirements for a code of business ethics, compliance program, and internal control system as required by FAR 52.203-13.
• Become familiar with the specific requirements for mandatory disclosures to the government as required by FAR 52.230-13 and by FAR Part 9, and understand the differences between the requirements and to which contractors they apply.
• Understand the risks and possible repercussions of noncompliance with both the compliance requirements and the disclosure obligations.
• Learn what the government expects from contractors’ compliance programs and disclosures.
• Gain insight from other contractors’ experiences and learn best practices for both the compliance and disclosure obligations to ensure successful compliance with each.
• Increase your knowledge of contractors’ compliance and disclosure obligations so you can successfully prepare your company to meet both obligations.

Who Will Benefit

This webinar is a must if you’re a contractor, subcontractor, supplier, attorney, government procurement official or other party, including non-profits, that work on federal government projects. This will be a critical issue with the expanded federal funds being spent under proposed jobs and stimulus plans. Get ahead of the curve — register your team today!