March 2014

Focus on Abt Associates Policy:
Disclosure of Improper Conduct on Government Contracts

Abt’s Disclosure of Improper Conduct on Government Contracts establishes a process for internal reporting of improper conduct.  Although it is no substitute for reading the policy in its entirety, a brief summary of salient points is below:

·         Abt is required under the Federal Acquisition Regulations (FAR) to establish and maintain specific internal controls to detect and prevent improper conduct in connection with the award or performance of any Government contract or subcontract.

·         Abt is required  to disclose  the  agency OIG, with a copy to the Contracting Officer, whenever Abt has credible evidence that any employee or subcontractor has committed a violation of Federal criminal law involving fraud, conflict of interest, bribery, or gratuity violations, or a possible violation of the civil False Claims Act

All managers are required to  immediately notify the company’s General Counsel (or the Chief Financial Officer in the General Counsel’s absence) , if and when they become aware of any suspected misconduct and violations of the Company’s Code of Conduct and related policies, or of Federal law involving fraud, conflict of interest, false claims, bribery or gratuity violations.

Spotlight on Abt Code of Conduct

The following excerpt from Abt’s Code of Conduct is intended to highlight proper procedures for reporting ethical issues:

Seeking Guidance and Reporting Issues

Employees of Abt Associates operate at the highest levels of ethical behavior. If you have questions about the Code of Conduct, or are concerned about conduct that you believe violates Abt Associates standards or the law, talk to your manager. If this seems inappropriate, or if you don’t believe the person to whom you’ve reported your concern has taken appropriate action, you may also talk to:

·         A higher level of management

·         Human Resources

·         A member of the Ethics and Compliance Steering Committee

·         The Ethics and Compliance Helpline

All of these resources are available to you. Regardless of the resource you choose to talk to, the Company is committed to responding to each situation quickly and completely.

Ethics and Compliance Steering Committee

To provide employees with a local resource for ethics and compliance questions or concerns, Abt Associates has created a cross-divisional and cross-departmental Ethics and Compliance Steering Committee.  A list of the members of the Ethics and Compliance Steering Committee may be found on AGI.

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

In July 2013, USAID contractor Black & Veatch (B&V) terminated the employment of an Afghan deputy administrative procurement manager who was working on a USAID-funded project. An OIG investigation established that the former employee knowingly selected a relative to receive a $277,000 diesel fuel subcontract.

B&V acknowledged the former employee did not enforce its procurement procedures effectively. B&V reported that it will implement internal controls aimed at preventing similar problems in the future.

Compliance Calendar

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 international 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