The most effective steps a contractor can take to avoid or protect against suspension and debarment are actions that demonstrate they are responsible contractors. Here are a few rules for guarding against a future suspension or debarment.
- Develop and maintain effective standards of conduct and an effective internal control system.
- Take appropriate disciplinary action against individuals in your organization that are responsible for wrongdoing.
- Implement correct actions following the discovery of wrongdoing.
- Continuously review internal control procedures and revise when necessary.
- Implement an ethics training program (now contractually required in many contracts).
- Develop an internal program that illustrates management's commitment to ethical behavior. Set the proper tone at the top.
Establishing these rules is no guarantee that a contractor can avoid a suspension or debarment. Because of this fact and because the financial effect of either action can be devastating, contractors should involve legal counsel in any matter that could lead to a suspension or debarment.
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