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National Contract Management Association The Cape Canaveral Chapter. A Balancing Act Winter Education Conference Contracting February 23, 2007. Contract Compliance for Government Contractors. Dr. Ralph “Mike” Criss. Is This The View from Your Window?. What is Compliance?.
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The Cape Canaveral Chapter
A Balancing Act
Winter Education Conference Contracting
February 23, 2007
Dr. Ralph “Mike” Criss
People make choices, or choose behaviors, based on their understandings of what is proper and expected under the circumstances.
Paula Desio, Deputy General Counsel, United States Sentencing Commission, has written a very nice one page summary of the organizational guidelines.
She includes eight key criteria for an effective compliance program.
Desio, Paula. An Overview of the Organizational Guidelines, United States Sentencing Commission, Organizational Guidelines,
Taken from the United States Sentencing Commission Guidelines Manual and reflect the sentencing guidelines as of November 1, 2005.
Is As Important As The Product
I attribute this phrase to Mr. Jim Dyer, colleague and friend. I do not know if he was this first to say it, but it was from him I heard it first. Jim, as of this writing is a contract manager for Parsons Engineering
Taking responsibility for compliance always comes down to personal choice no matter what level you are in the organization.
This Is Difficult
Training is How an Employee Learns the Rules
Bribery and Illegal Gratuities Statute
Standards of Ethical Conduct for Employees of the Executive Branch
Trade Agreements Act
Foreign Ownership Control and Influence (FOCI)
Foreign Corrupt Practices Act
False Claims ActSome Formal Training
Tie Quality Control, Audit, Corporate Governance, and Common Sense Together
What Do the Following People Have in Common?
Since 2004, there have been at least 20 indictments or convictions of government officials and contractors for corruption related to procurement. These have included the conviction of a senior Republican congressman, the indictment of the top White House procurement officials, and the conviction of one of the most senior procurement officials at the Air Force. Corruption has tainted a wide array of contract initiatives, including the reconstruction in Iraq, the response to Hurricane Katrina, and major Defense Department procurements.
Dollars Not Sense
Government Contracting Under the
Rep, Henry A. Waxman
United States House of Representatives
Committee on Government Reform – Minority Staff
Special Investigations Division