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Here are some initial thoughts on some of the important changes proposed in this rule, as well as a recap of the original statute and my earlier predictions. It will also change the title of the part from Improper Business Practices and Personal Conflicts of Interest to Business Ethics and Conflicts of Interest.
At the Public Contracting Institute , we recognize the importance of this knowledge and its impact on your business operations. This standard ensures that taxpayers’ money is spent responsibly and that contractors maintain ethical financial practices.
“Within three months of first discovering the possibility of misconduct and hours after an internal investigation confirmed that misconduct had occurred” Lifecore voluntarily self-disclosed to the DOJ. [6] While pre-acquisition due diligence is important, it does not always uncover misconduct. g)(1)) (accessible here ). [3]
Government contractors need to consider the broad scope of such liability, the importance of early detection of underlying misconduct, potential mandatory or voluntary disclosures, the effectiveness of their compliance programs in detecting and effectively addressing serious misconduct, and the risk of potential suspension and debarment.
And that’s called the internalcontrols and books and records provisions, or what we call the accounting provisions. And if they have controls that allow that sort of thing, then they have a weakness in their internalcontrols, and that’s a violation of the internalcontrols provisions.
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