January 2015

Focus on Abt Policy:

Internal Control Policy

Internal controls are systems and processes implemented to ensure that the Company is generating reliable financial reports and information, is in compliance with all applicable laws and regulations, can detect and prevent improper conduct, and that management has an understanding of the extent to which Abt is achieving its objectives.

Abt management maintains the Company’s internal control system by:

·         Implementing the Code of Conduct and related policies and procedures to achieve Abt’s business objectives

·         Conducting an annual enterprise risk assessment to identify the key risks and using the results to develop and monitor action plans to address the identified risks

·         Conducting an annual assessment of the Company’s information systems, security, processes and controls, and using results to implement improvements

·         Developing and implementing an internal audit plan to focus on areas of high risk, monitor compliance with policies and procedures, and evaluate the effectiveness of Abt’s internal control system

Spotlight on Abt Code of Conduct:

Protecting Confidential Information

All employees sign a non-disclosure agreement upon starting their employment with Abt (and are bound by applicable terms if they should leave the Company) that prohibits the disclosure of Company proprietary information to third parties.  Employees are responsible for protecting confidential information belonging to Abt or entrusted to it by third parties. Confidential information includes all proprietary information that is not generally available to or known by the public.

How can you ensure you protect confidential information?

·         Know what information is considered proprietary and ask if you are unsure. Examples of proprietary information are included in the Code of Conduct.

·         Do not disclose Company information to others unless they have a legitimate need to know it to perform their jobs

·         Protect the confidentiality of all personally identifiable information and any confidential information entrusted to Abt by third parties

·         Prior to preparation of a business proposal, ensure that any business partners sign a mutual non-disclosure agreement so that both parties clearly understand the extent of appropriate communications and data use.

Ethics & Business Conduct for Government Contractors Online Training

Thank you for your participation in the recent company-wide training and for your commitment to ensuring Abt maintains a strong ethics and compliance program. 100% of our domestic staff and over 75% of our international staff completed the training, with the remainder awaiting appropriate translations.

Upcoming Ethics and Compliance Training for Senior Management

Abt SRBI NYC- 2/2/15

Abt SRBI Silver Spring- 2/25/15

Abt Bethesda- 3/11/15

Abt Cambridge- 3/12/15

Compliance Case Study

The Justice Department announced on December 12, 2014 that Derish Wolff, the former President and CEO of Louis Berger Group Inc. (“LBG”), a New Jersey-based government contractor, pleaded guilty to conspiracy to defraud the federal government for overbilling USAID for reconstruction contracts in Iraq and Afghanistan from 1990 through July 2009.

Wolff, according to the Department of Justice statement, targeted an overhead rate irrespective of the actual rate and ordered subordinates to charge that target rate through a variety of fraudulent means. In a 2001 LBG annual meeting, when the controller presented an overhead rate that was significantly below Wolff’s target, Wolff called the controller an “assassin of the overhead rate and ordered him to target a rate above 140 percent, meaning that for every dollar of labor devoted to a USAID contract, LBG would receive an additional $1.40 in overhead expenses supposedly incurred by LBG.” According to the statement, Wolff ordered subordinates to “instruct the accounting department to pad its time sheets with hours ostensibly devoted to federal projects when it had not actually worked on such projects” and to charge commonly shared expenses, such as rent at LBG’s DC office, to USAID even though that office supported many non-USAID projects.

In 2010, two other LBG executive plead guilty to conspiracy to defraud the federal government, and LBG entered into a settlement to resolve criminal and civil fraud charges related to Wolff’s and the others’ conduct. LBG agreed to pay $18.7 million in criminal penalties and $50.6 million in civil penalties, and to adopt effective standards of conduct, internal control systems, and ethics training programs for employees.  

Compliance Hotline Numbers

The Ethics and Compliance Helpline

Phone: 888-928-4231 (helpline int’l phone access codes)
Web: http://www.integrity-helpline.com/abtassoc.jsp

The Audit Committee Helpline

Phone: 888-309-1558 (helpline int'l phone access codes)

Web: http://www.AbtAssocAuditCommitteeHL.alertline.com

Compliance Steering Committee

Rich Small (CFO/Chief Compliance Officer) – 617-349-2580, richard_small@abtassoc.com  

Clarissa Peterson (CHRO/Chief Ethics Officer) – 301-347-1460, clarissa_peterson@abtassoc.com

Brian Roemer (General Counsel) – 301-347-5816, brian_roemer@abtassoc.com