The Procurement Integrity Act

April 9th, 2015

Tips from the biggest procurement organization in the world; The U.S. Government

 

Today’s blog is from Michael Figueroa, Project Manager at SafeSourcing.
 
Depending on your political leanings, the government might not be your first choice of where to get guidance on integrity. I would suggest, however, that the government guidelines may not be the end-all source for all of your policy development, but it may be a great starting point. When experts speak about business ethics, they usually talk ethics as a spectrum of more ethical and less ethical, not as an on/off switch. The starting point of that threshold for most ethicists is the law. So even though you may want to go above and beyond the law for determining how you conduct your business, the law is where you would start for ensuring your policies are compliant, and you may want to begin with the government’s procurement integrity policies when developing your own.
 
The purpose of the Procurement Integrity Act is to prevent the award of contracts based on corporate espionage or bribery. The intention is for this act to encourage contracts that provide the best value to the government and, by proxy, its citizens. Below we will summarize a few key concepts from the Procurement Integrity Act for you to consider:
 
Communication must be much more regulated after a formal request for proposal has been released: It is expected that before the release of an RFP, a government procurement representative will be conducting industry research that may involve direct communication with the vendor community. However, after the release, communication must be well documented and must not include information that would give advantage to any one vendor over another.

Conflicts of interest: If you are advising the government in a procurement project and yourself, a family member, or company you are involved with have a financial interest in the project, criminal law may prevent you from working on the project. This policy applies to both giving AND receiving gifts between the purchaser and the vendor, applicable to gifts and other “perks” as well.

If you think it would be inappropriate for you to be involved on a project, speak with an agency ethics officer: Not many private companies have an ethics officer, but it should be within your policy to have the ability to notify a supervisor and self-identify any reasons why an employee shouldn’t be involved on a project when warranted.

Obligate participating vendors to minimize exposure to competitor information: It should be within your terms of participation that a company should never knowingly obtain confidential competitor information, and if ever erroneously receiving such information, they agree to minimize that exposure. In other words, the error should be immediately disclosed and information destroyed, not further disseminated. It does not benefit the purchasing party to have any one vendor have an informational advantage over another.
For more details, we recommend further study of the resources available at the website for the Office of Government Ethics at: http://www.oge.gov/

For more information on how SafeSourcing can assist your team in this process, please contact a SafeSourcing Customer Service Representative.  We have an entire customer services team waiting to assist you today.
 
We look forward to your comments.

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