October 2014

Focus on Abt Policy:
Gift Policy

Abt employees or members of their families are prohibited from giving or accepting gifts greater than $50 in a 12-month period to or from any person or organization with which Abt does business.

Does this apply to government employees?  Abt employees should never provide gifts regardless of value to US federal, state, or local government officials, as doing so may jeopardize compliance with the FAR, the regulations set forth by the U.S. Office of Government Ethics, and may  create an actual or perceived conflict of interest. 

What is a gift? Gifts are not always physical objects. They may also be services, favors, loans, or other items of value.

Are there exceptions to this policy?: Yes, there are a limited number of exceptions which are listed in the Gift policy available on AGI. Examples include:

·   The exchange of gifts of the same approximate value between Abt employees and their personal friends who happen to be members of organizations with which we do business, except for employees of the US Government as noted above.

·   Gifts between Abt employees for special occasions such as births, deaths, etc. as long as the gifts are appropriate and avoid extravagance.

What should you do if you receive a gift? Gifts received other those that are impractical to return should be returned with a letter explaining Abt’s gift policy. It is suggested that perishable gifts, such as food or fruit, be given to a church or charitable organization or shared with other employees with whom the recipient works.

Spotlight on Abt Code of Conduct:

Non-Partisanship

Abt’s clients rely on the integrity of the Company’s methods and findings, the objectivity of our thinking, and the practical utility of our results. Abt does not make political contributions or support political candidates; however, employees, officers, and directors may make lawful political contributions and be involved in political activity on their own behalf.  In order to ensure Abt’s work remains nonpartisan and avoids even the appearance of bias,  the Code of Conduct requires all staff to follow the following guidelines:

·     Staff who publish partisan political opinions must do so as private individuals using a personal address or email address (not their Abt email address) and may not reference their position or employment at Abt

·     Any employees who perform volunteer work related to partisan political activities must do so without any Abt resources and such activity must be conducted during non-work hours

·     Employees may not use Company funds to make political contributions nor seek reimbursement for any political contribution

·     Do not post partisan political materials on doors, walls, or any location within Abt’s offices

·     Do not use Company resources or facilities including Company phones, computers, printers, copiers, or fax machines to support political candidates or parties

·     Make sure that your individual political views and activities are not viewed as those of Abt Associates.

The Code of Conduct is available in several languages on AGI

https://abtassoc.sharepoint.com/departments/
EthicsCompliance/Pages/Code-of-Conduct.aspx

Compliance Case Study

Just prior to a major contract award, a Department of Defense Bureau Director went out to dinner with one of the potential competitors at a swanky Washington restaurant. The wine alone cost over $100 per bottle. Unbeknownst to the director or the contractor, a Washington Post reporter was dining at the next table. The story received front page coverage in the next day’s newspaper, and by that afternoon, the Director had resigned from his post and accepted a job in the private sector. (Example taken from DoD General Counsel’s “Encyclopedia of Ethical Failure.”)

The standards of Ethical Conduct for employees of the Executive Branch (5 C.F.R. Part 2635) generally prohibit Federal personnel from accepting gifts (including meals) from persons who do business or seek to do business with the employee’s agency. Abt’s gift policy also prohibits any employees from providing gifts, favors, or entertainment to U.S. federal, state, or local government officials. Adherence to this policy is important for the company to comply with the FAR and also to avoid actual or perceived conflicts of interest.  

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

Employees of government contractors may be entitled to additional protection under federal law if you
have reported misconduct and believe you have suffered reprisals or retaliation for doing so.