A Model Ethics Program For A Department Of Defense Contracting Office PDF Download

Until recently, ethics programs and practices of defense contractors were self-policed. Given the significant sums spent to acquire goods and services, the Federal Acquisition Regulation (FAR) was amended twice starting in December 2007 to first mandate and later amplify contractor ethics program rules. Before FAR changes were finalized in December 2008, Congress required GAO to report in 2009 on the ethics programs of major defense contractors. This report (1) describes the extent that contractors had ethics programs before the finalization of the FAR rules that included practices consistent with standards now required by the FAR and (2) assesses the impact the new FAR rules have on Department of Defense (DOD) oversight of contractor ethics programs. To do this work, in September 2008 GAO surveyed all 57 contractors -- those receiving more than $500 million in 2006 DOD contract awards -- and interviewed DOD contractor oversight agency officials on the impact of the new FAR rules on oversight. GAO recommends four actions aimed at improving oversight of ethics programs during contract administration and DOD hotline poster requirements for contractors to ensure that whistleblower protections are communicated. DOD concurs with GAO's recommendations.