Small businesses that are trying to gain and keep federal business face a dizzying array of regulations and requirements, including ethics and compliance requirements.
Recognizing that, the Defense Industry Initiative (DII) developed a small business toolkit to help small businesses “design, implement, maintain, and augment business ethics and conduct compliance programs” (Defense Industry Initiative, 2016).
A recent article DII’s National Defense magazine (see Martin, 2017) tells us that the toolkit includes everything necessary for creating a program that complies with federal procurement regulations. It offers information in four major categories: governance & organization; training & engagement; policies & procedures; and auditing, monitoring, & mentoring, and it contains sample communications documents, sample policies and procedures, self-audit tools, training case studies, and more.
For example, the self-audit section walks small businesses through a series of questions related to eight important topics: 1) company values/code of conduct, 2) risk assessment, 3) ethics and business conduct policies, 4) inquiry and reporting mechanisms, 5) awareness training, 6) communication program, 7) program assessment and evaluation, and 8) leadership commitment.
Digging deeper, we see that the questions asked for each topic are not only useful for self-audit, but also offer guidance in setting up related aspects of an ethics and compliance program as well. Here are just two of the major questions covered in
topic #4 (inquiry and reporting mechanisms), as replicated from the toolkit.
Do you have a process for employees to report their concerns about ethics or about violations of laws, regulations, and Company policies? If so, who is responsible for receiving employee calls or concerns? The best practice is to use a third party to receive such calls live on a toll-free line so that there is no concern about the complainant being identified.
If you have a Hotline number, how is it communicated to employees? Ensure that the following are done:
• Posters with the website address and toll-free hotline number are displayed prominently at locations where employees gather frequently (e.g. cafeteria and other common areas).
• The name and contact information of the appropriate Ethics Officer or other appropriate person are noted to allow employees to report a concern in person if they wish to do so.
• Posters state that the concerns can be reported anonymously.
• Posters are changed periodically in designs and colors so that they continue to remain noticeable.
Other questions in this topic area ask about reporting mechanism effectiveness and the investigation process. The toolkit covers each of the eight self-audit topics in similar detail, as it also does for the other categories of information. It is truly a helpful resource for small defense contractors and small businesses in general. In fact, it would be helpful for businesses of any size!
Ethical Advocate assists companies of all sizes in creating a culture of ethics and accountability by providing ethics and compliance training, confidential and anonymous hotlines, and assistance in meeting regulatory and reporting needs. Contact us for more information.
Defense Industry Initiative. The Small Business Toolkit, May 2016 (Request a copy at http://www.dii.org/resources/small-business-toolkit-introduction)
Martin, Ellen. “An Ethics Toolkit for Small Businesses.” National Defense, April 19, 2017. http://www.nationaldefensemagazine.org/articles/2017/4/19/an-ethics-toolkit-for-small-businesses