Recommendation 2011-3, “Compliance Standards for Government Contractor Employees—Personal Conflicts of Interest and Use of Certain Non-Public Information” responds to agencies' need to protect integrity and the public interest when they rely on contractors. The Conference recommends that the Federal Acquisition Regulatory Council provide model language for agency contracting officers to use when negotiating or...
Government Contractor Ethics
Project Stages:1. Gather ideas - Completed
2. Select ideas - Completed
3. Council approval - Completed
4. Picking a researcher - Completed
5. Committee consideration - Completed
6. Back to the council - Completed
7. Consideration by the full conference - Completed
8. Implementation - Current
Federal employees and contractor employees are subject to widely disparate ethics regimes. Whereas government employees must comply with extensive rules covering things like personal conflicts of interest, receiving gifts, and post-employment restrictions, contractor employees are generally not subject to such specific regulations (though contractors performing contracts exceeding $5 million must have an internal ethics code). Government contracting has vastly expanded in recent years, and some have suggested that the ethics regime currently applicable to contractors is insufficient. At the same time, new regulations can create additional costs for contractors and agencies. The Recommendation proposes compliance standards related to personal conflicts of interest and use of certain non-public information, with the aim of ensuring ethical conduct on the part of contractors without imposing excessive compliance costs.