Research law and regulatory affairs update: codes of business ethics, codes of conduct and conflict of interest

Federal regulations require that government contractors and grantees conduct themselves with the highest degree of integrity and honesty. Both contract and grant regulations require a written code of business ethics and conduct, as well as an employee business ethics and compliance training program. The most explicit policy at 48 CFR (FAR) 3.1002 applies as guidance to all Government contractors. The contractual requirements set forth in the clauses at 48 CFR 52.203-13, Contractor Code of Business Ethics and Conduct, and 48 CFR 52.203-14, Display of Hotline Poster(s), are mandatory if the contracts meet the conditions specified in the clause prescriptions at 48 CFR 3.1004. A similar but less explicit requirement is in place for grants. Under 2 CFR 215.42, Codes of Conduct, grant recipients must maintain written standards of conduct governing the performance of their employees engaged in the award and administration of contracts under a grant or cooperative agreement.