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ARTICLE · 23 JUNE 2021

Beyond Whack-A-Mole: Effective Ethics & Compliance Programs For Small Contractors

Small government contractors are in an unenviable position when it comes to developing effective ethics and compliance programs.

United StatesCorporate/Commercial Law

Small government contractors are in an unenviable position when it comes to developing effective ethics and compliance programs.

On the one hand, profit margins are low, competition is fierce, and financial and personnel resources are scarce — particularly for tasks that do not contribute immediately to the bottom line.

On the other hand, government agencies and mature prime contractors expect emerging contractors to reflect the same "culture of ethics and compliance" that large companies commit substantial resources to implementing, and that the government commits substantial resources to policing.

The fear of compliance missteps and attendant risks such as reputational harm, contract termination, suspension/debarment, civil lawsuits and criminal prosecution, keeps many conscientious executives up at night.  They realize that potential disaster looms if they do not commit appropriate resources to building out an effective ethics and compliance program, but

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