Ethics & Compliance

The Steptoe team provides cutting-edge advice and assistance in the area of ethics and compliance. We help our clients develop, enhance and implement their internal business ethics and compliance programs, encompassing the full range of statutory and regulatory requirements including the Truth In Negotiations Act, FAR Cost Principles and the Cost Accounting Standards, the Procurement Integrity Act, organizational conflicts of interest, OGE’s Standards of Conduct (including rules regarding gifts and gratuities), kickback prohibitions, the Davis Bacon and Service Contracting Acts, country of origin requirements, FAR disclosure commitments, and the National Industrial Security Program.  We have conducted internal reviews of compliance issues identified by “hotline” calls, whistleblowers and other sources.  We are very sensitive to the importance of fully understanding the business context in which these issues arise, and draw upon our broad experience advising clients in the aerospace, defense, high technology, healthcare and construction industries.   We have also assisted clients in enhancing their business ethics and compliance policies and procedures for purposes of demonstrating their present responsibility to agency suspension and debarment officials.

Representative Matters

  • Assisted nationally recognized manufacturing company update its code of ethical conduct and expense accounting procedures, and conducted training sessions for company leaders and sales personnel.
  • Advised clients on issues related to the application of the Anti-Kickback Act and its implementing FAR clause, including requirements for disclosure to agency inspectors general. 
  • Advised a major European industrial company concerning ethical and compliance rules that apply to the US government marketplace.
  • Counseled software, high technology and manufacturing clients on various business ethics issues in government contracting, including gratuities, kickbacks and procurement integrity, and assisted them in enhancing compliance policies and procedures and in providing training to company employees on those subjects.   
  • Advised a professional services company regarding the risks associated with contingent fee agreements between a government contractor and agents or employees developing government contracts’ business.  We also proposed potential policies and due diligence measures that could be implemented to manage the risks presented by such agreements.
  • Advised clients in various industries on compliance with country of origin requirements under the Buy American Act, Trade Agreements Act and American Reinvestment and Recovery Act.

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