In this special podcast series, sponsored by Affiliated Monitors, Inc. (AMI); I am joined by AMI Managing Director Rod Grandon. We will be considering the responsibility of federal contractors to maintain their status as “Responsible Contractors” and explore the benefits of having an effective compliance and business ethics program not only to increase business efficiencies and profitability but prepare you in good stead if the regulators come knocking. In this episode, we introduce the concept of Responsible Contractors.
In this series, we examine the impact of two key Federal Acquisition Regulations (FARs), FAR3.1002 and FAR 52.203-13, Contractor Code of Business Ethics and Conduct, in the context of other authorities relating to corporate integrity programs, along with proactive steps contractors can take to better position their companies should federal enforcers come calling. It has certainly been Grandon’s experience that companies that proactively embrace robust ethics and compliance programs tend to become better companies for their employees and customers. Grandon emphasized that the government is focused on what it terms “responsible contractors”. While there is no FAR laying out the definition of this term, Grandon noted it has come to have a very broad meaning.
First, it addresses performance characteristics that a responsible contractor “should have the ability to perform as it said that it would perform pursuant to its contract.” This includes a contract with goods or services. It is beyond ethics and compliance “as it encompasses the concept that a contractor should have the financial wherewithal to complete the contracted task, the facilities or physical plant to perform the work, accounting systems and purchasing systems that are up to the task, property management systems, and all other such systems should be in place. It also means having a workforce that is capable of performing. Finally, it also includes a workforce that is committed to compliance and promoting all they do with integrity.”