CONFLICTS OF INTEREST,
AND DISCLOSURE RULES
WHAT DOES UNCLE SAM HAVE in common with Santa Claus? Sure, they both have white beards and wear funny hats. But for government contractors, the most important similarity goes back to the classic children’s song, “Santa Claus Is Coming to Town.” Like jolly old St. Nick, Uncle Sam wants to know if you have been naughty or nice— and has a lot of rules in place make sure government contractors are on the “nice” list.
As a government contractor, you must avoid specific prohibited activities and comply with a number of ethics requirements, including, in many cases, adopting a written code of compliance and hanging yet another poster. In addition, you should understand and follow the rules regarding conflicts of interest, which can affect your business’s eligibility to receive federal contracts. And you may be required to inform the government of actual or suspected criminal or ethical violations, as in recent years the government has also adopted mandatory disclosure rules.
In this chapter, we’ll discuss these important requirements, helping