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The Compliance Mentorship Program: Improving Ethics and Compliance in Small Government Contractors.  

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The Compliance Mentorship Program: Improving Ethics and Compliance in Small Government Contractors.

Jessica Tillipman and Vijaya Surampudi.

Unlike their large counterparts, many small government contractors are largely unable to keep up with the rapidly evolving trends and best practices in ethics and compliance. Their inattention to this critical area leaves them at risk for compliance failures, fraud, and corruption. As a result, small contractors are more likely than their large counterparts to be debarred from the U.S. procurement system.  Despite the harsh consequences of compliance deficiencies, few small contractors are likely to dedicate resources to the development of vital compliance policies and internal controls because of the reality of limited resources. This has created a critical gap in the defense industry supply chain, as many large contractors may partner with small companies that lack the sophistication and resources necessary to ensure compliance with the many government contracts compliance requirements.

This article recommends incentivizing large businesses to utilize their vast resources to assist their small business partners with the development of internal ethics and compliance programs in order to improve the overall integrity of the government procurement system. It analyzes the development of global anti-corruption compliance standards through an overview of noteworthy changes in laws, regulations and enforcement, as well as the current compliance risks that large companies face when contracting with smaller companies who lack robust compliance systems and internal controls. The article concludes by recommending the adoption of a corporate mentor-protégé program that incentivizes larger companies to dedicate resources to helping smaller contractors develop anti-corruption compliance programs. 

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