Subject: Ethics and Compliance Newsletter July 2014
From: Brian Roemer <[email-masked]>
To: Brian Roemer <[email-masked]>
Date: Wed, 02 Jul 2014 15:37:41 +0000

July 2014

Focus on Abt Policy:
Conflicts of Interest with Hiring Current and Former Government Employees

Current and former Government Employees are subject to federal conflict of interest laws and regulations that may limit the ability of Abt to recruit and hire certain individuals, and if hired, may limit the activities they will be able to perform for the Company.

·         Abt employees may not have discussions concerning possible employment, whether in person or by telephone, fax, or email, with a potential new hire who is either a current U.S. Government employee or has left the Government within the last twelve months without prior authorization from the Chief Human Resources Officer or the General Counsel.

·         An actual conflict of interest does not need to exist to constitute a violation of the Company’s Conflict of Interest Policy. Activities that create the appearance of a conflict of interest must also be avoided to ensure that the reputation of Abt and its employees are not harmed.

If you are not sure whether an activity would constitute an actual or perceived conflict of interest, it is best to disclose it to the General Counsel or Chief Ethics Officer so the situation can be reviewed. This protects both you and the Company.

Spotlight on Abt Code of Conduct:

Procurement Integrity

All Abt employees are obligated to comply with the rules and regulations set forth in the Procurement Integrity Act. As a result of these rules and regulations, all Abt employees are prohibited from:

·         Receiving from any unauthorized source, including government personnel, disgruntled employees, or consultants, a competitor’s bid or proposal information or other confidential information prior to the award of the related contract

·         Having undisclosed employment discussions with a government employee who in engaged personally and substantially in the procurement process

·         Compensating a former government employee who served as a procurement official during the preceding one-year period

·         Improperly using an Abt partner’s cost and pricing information or other confidential information that has been entrusted to the Company when competing against it on other projects

These rules and regulations are designed to ensure that all U.S. Government contracts are awarded fairly and do not give one contractor an undue advantage over any others.  If you have any questions regarding procurement integrity, please contact the General Counsel or Chief Ethics Officer.

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 May 2014, the Washington Post published an article questioning various practices of the International Relief and Development Foundation (IRD), a non-profit organization based in Arlington, Virginia. Among the practices discussed in the article were two potential conflicts of interest, including the payment of high bonuses to senior staff and family members and the hiring of former USAID employees.

IRD hired at least 19 employees from the agency, including former top-level employees such as the former deputy assistant administrator, the director of contracts, and a key operations officer.  One former USAID employee hired by IRD had previously supervised an IRD program in Baghdad. IRD also hired the daughter of the former director of the USAID Mission Office in Baghdad, despite the fact that the director had previously overseen an IRD program. Following the publication of the article, the USAID Inspector General’s Office announced it would examine the “revolving door” of employees between USAID and IRD or other contractors.

The article indicated that IRD employs multiple family members, and according to the Post, the four family members employed at IRD collectively received over a million dollars in bonuses between 2008 and 2012.

While the “revolving door” of personnel moving between the public and private sector or the employment of relatives within an organization is not prohibited or even uncommon, it is important to carefully consider whether a situation could constitute an actual or perceived conflict of interest.  Abt’s Conflict of Interest Policy calls for informing the Chief Ethics Officer or General Counsel regarding any perceived or actual conflict 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, [email-masked]

Clarissa Peterson (CHRO/Chief Ethics Officer) – 301-347-1460, [email-masked]

Brian Roemer (General Counsel) – 301-347-5816, [email-masked]