Did you know that within 30-days of the award of a contract containing FAR 52.203-13, Contractor Code of Business Ethics and Conduct, you are required to have a written code of business ethics? Not only do you have to have a written Code, but you also must make a copy of the Code available to each employee engaged in the performance of the contract. As a government contractor, it is vitally important to have an ongoing business ethics awareness and compliance program that includes training for all your employees.

Our highly qualified team of legal, HR, and Government consultants understand ethics, business conduct, and the government expectations for your company to be compliant. We partner with contractors to create a corporate ethics program compliant with FAR 52.203.13, tailored to your workforce, governance needs, and business objectives. Our focus is on educating and training your workforce to promote a company-wide culture of ethical behavior. We also support you in investigations of any ethics complaints or concerns and possible mandatory disclosures, if applicable.


  • Code of Business Ethics & Conduct (COBEC) Program Development & Monitoring – Your written COBEC and awareness program is the first line of defense when problems arise. Bad things do happen to good people, and no organization is immune to ethical challenges. Should an issue arise, having a functioning Code, ongoing monitoring, and training shows auditors and investigators that you are proactive and can serve to minimize potential fines and penalties. Our experts are adept at assessing risk and crafting practical programs and policies tailored to your workforce’s needs and objectives.
  • Employee Awareness & Training – Our team can help to ensure your Code is more than just a piece of paper. Well-written policies are only as good as your employee training and awareness program. We help you reflect your ethical approach through our program development, training, and awareness support. Our firm teaches nationally for industry organizations, as well as for our clients. When it comes to ethics and corporate compliance, our team can deliver targeted live instruction, web-based training, or even provide SCORM format courses for inclusion in your own learning management system.
  • Internal Compliance & Controls – A robust ethics and compliance program includes comprehensive written policies and procedures to document a company’s commitment to ethical practices and compliance with U.S. Government regulations. Our team has decades of experience supporting the development and improvement of written policies and procedures across the back office of government contractors.
  • Risk Analysis – As a government contractor, the risks to your business abound and are unique based on the agencies you work with, your prime contracts, contract types, employee labor, countries of operation, and many other factors. Our team is adept at understanding and evaluating these risks and identifying resolutions for you to avoid possible ethics violations. Our consultants include expertise from industry specialists, HR, employment law, compliance, and DCAA.
  • Whistleblower Complaints – A whistleblower complaint can be a very alarming experience for government contractors. The DOD (and other fraud referral) hotline is often a tool for an upset employee, but every complaint must be addressed diligently and investigated internally. Our team of experts can not only investigate and document findings but also serve as an objective resource to management in evaluating the veracity of the complaint and necessary actions to ensure compliance.
  • Mandatory Disclosures – Did you know that FAR 52.203-13 requires contractors to timely disclose to the Office of Inspector General (OIG) any credible evidence of potential violations of Federal criminal law such as fraud, conflicts of interest, bribery, gratuity violations, and/or violations of the civil False Claims Act? Everyincident must be investigated rigorously to understand the cause and corrective action required, as well as the need for mandatory disclosure. Our team supports you through this process and works with internal and external counsel to prepare the disclosure and support necessary for corrective actions.

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Jamie M. BrabstonJamie M. Brabston
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RGCI LMS Contractor Code of Business Ethics & Conduct (COBEC) FAR 52.203 13

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