Alert 03.17.25
Anti-DEI Executive Orders Are Enforceable, for Now, After Fourth Circuit Lifts Preliminary Injunction
The U.S. Court of Appeals will expedite its review of appeal of preliminary injunction.
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Pillsbury’s Government Contracts team is highly experienced in developing and enhancing existing values-based ethics & compliance programs for federal government contractors.
Given the incredibly tight fiscal environment and competing demands placed on each and every dollar spent by government contractors, it is not surprising that many contractors deprioritize proactive investments in their ethics and compliance programs prior to the occurrence of an ethics or compliance event. Unfortunately, our experience indicates that contractors that minimize the critical importance of proactive investments in ethics and compliance often suffer the consequences of a compliance or ethics event and resulting crisis. These events can be costly to resolve, distract attention from the mission, drain resources, and negatively impact the organization’s reputation. Often, though, these events could have been prevented with a far less significant investment prior to the crisis. Moreover, contractors who have invested in ethics and compliance, fare much better when and if an event ultimately occurs.
Our experienced government contracts lawyers are knowledgeable of the required components of effective values-based Ethics & Compliance (E&C) programs and similarly understand the best practices in ethics and compliance among government contractors of all sizes. Our team is skilled in scaling the “best practices” in ethics and compliance to meet the pragmatic business needs of our clients, including small contractors, medium-sized contractors, and large publicly traded contractors. With this deep knowledge and experience, our team is highly skilled in helping clients implement programs and enhance existing programs by conducting gap analyses and other evaluations.
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We work with clients of all sizes, including small business concerns with revenues less than $15MM, mid-sized companies with revenues of $50 to $100MM, and large contractors with revenues of $1B or more, including publicly traded companies. We are highly experienced in developing appropriately tailored programs based on our client’s unique needs and operations. And our work product has received praise from government officials who have evaluated our clients’ programs and our work product can be efficiently customized for our clients' business needs.
We model our recommendations for E&C Programs off the Federal Sentencing Guidelines for Organizations, Chapter 8, which provides guidance on what it means to possess an “effective” program and Federal Acquisition Regulation (FAR) 52.203-13, Contractor Code of Business Ethics & Conduct, which describes the required components of a values-based E&C Program for government contractors (other than small business concerns).
Because we have deep experience representing contractors in crisis events, including civil False Claims Act matters, debarment matters and criminal proceedings, we also are able to offer our clients insight into the significant ethics and compliance risks that they face as government contractors and can offer guidance on how best to prevent these events from occurring. Our team regularly counsels clients through the developments of E&C programs from scratch and is also highly experienced in evaluating the root causes of compliance events and advising our clients on remedial measures and corrective actions to prevent those events from reoccurring.
Briefly, below is an overview of the best practices in effective ethics and compliance programs: