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Focusing on Right and Wrong

Focusing on Right and Wrong

MARCH 2, 2015

Today, March 2, 2015, the new Federal Acquisition Regulations (FAR)  “Ending Trafficking in Persons” take effect.

The new FAR requirements are broad and apply in one form or another to contractors and subcontractors and make contractors responsible for their subcontractors.

Among other requirements, the contractor must notify the Contracting Officer and the agency Inspector General of any credible information of violations and the contractor is required to cooperate with the agency’s investigation.

As with any broad regulation, there are numerous technical requirements as well.

These comprehensive regulations are necessary to protect workers unable to fend for themselves.

However, my concern is one I have often voiced. Regulations can lead an organization to do the minimum necessary to comply and focus its attention on what can be done without violating the regulations.

Instead, the organization should be focusing on what is right and what is wrong, not only what is allowable or what is prohibited.

Indeed, it is in an organization’s best interest to focus on ethics and not just compliance. Ethical thinking acts as a safety net for all the decisions which may not be governed by the regulations, but which can be costly to the company in reputation and revenue.

We see this issue time and time again in the companies for which we draft codes of conduct, audit compliance programs and help them achieve best practices while improving overall corporate performance.

About the author

schwartz_bBART M. SCHWARTZ

Bart M. Schwartz is the chairman of Guidepost Solutions LLC, a global leader in investigations, due diligence, security and technology consulting, immigration and cross-border consulting, and monitoring and compliance solutions. Bart can be reached at


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