Description
Course Overview
This course will offer attendees an overview of the requirements of FAR 52.203-13, Contractor Code of Business Ethics and Conduct Requirements (COBEC), including the “mandatory disclosure” rule, which requires contractors to self-disclose credible evidence of violations such as fraud, false claims, gratuities, conflicts of interest, and significant overpayments related to federal contracts and subcontracts.
Participants will gain practical insights into compliance obligations, reporting mechanisms, and best practices for establishing and maintaining an effective ethics and compliance program. The course includes real-world examples, best practices, and strategies for navigating contractor compliance requirements, including conflict of interest policies, whistleblower provisions, and the False Claims Act.
Course Objectives
At the completion of this course, participants will be able to:
- Identify the requirements of FAR 52.203-13 (COBEC)
- Understand the mandatory disclosure requirement, including what must be reported, limitations on disclosure requirements and consequences for failure to comply with mandatory disclosure requirements
- Understand how voluntary disclosures and/or FOIA interplay with COBEC
- Identify and understand the FAR’s requirements related to Conflicts of Interest (COI), Whistleblower provisions, and compliance with the False Claims Act (FCA)
Program Content
This course will cover the following topics:
- Introduction to Business Ethics and COBEC Compliance
- Definition of ethics in federal contracting
- Importance of COBEC compliance for contractors
- Types of conduct covered by COBEC
- Establishing compliance with COBEC requirements
- Mandatory Disclosure Rule
- Laws covered under mandatory disclosure
- Compliance requirements and disclosure methods
- Legal decisions interpreting disclosure requirements
- Implications of mandatory disclosure on attorney-client privilege
- Influence of Government Actions and Contractor Conduct
- Definition and examples of improper influence in government contracting
- Identifying and preventing bribes, gratuities, and kickbacks
- Conflicts of Interest (COI) and Organizational Conflicts of Interest (OCI)
- Understanding personal vs. organizational conflicts of interest
- Examples of COIs and OCIs in government contracting
- Developing and implementing an OCI Mitigation Plan
- Whistleblower Provisions and Compliance with the False Claims Act (FCA)
- Whistleblower protections under federal regulations
- FCA compliance and reporting requirements
- Best practices for preventing and addressing FCA violations
- Compliance Initiatives and Best Practices
- Establishing internal reporting mechanisms
- Creating company-wide compliance procedures
- Reviewing applicable FAR clauses related to ethics and compliance
- Consequences for Failure to Comply with COBEC
- Enforcement actions and penalties for noncompliance
- Real-world examples of COBEC violations and lessons learned
Course Run Time
- 4 hours
Customization Options: This course can be customized into a half-day, 1-day, or 2-day training based on your company’s needs.
CPE Credit
- CPE credit is available using the following training methods: Custom Training, In Person Training (Group), In Person Training (Individual), and Live Webinar Training.
- SHRM PDC is available for HR professionals using the following training methods: Custom Training, In Person Training (Group), In Person Training (Individual), and Live Webinar Training.
Redstone Government Consulting, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.
HR Professionals: Earn Professional Development Credits (PDCs)!
Redstone Government Consulting, Inc. is recognized by SHRM to offer Professional Development Credits (PDCs) for
SHRM-CP
or SHRM-SCP.
