Question: If a large privately held company that mostly does private construction work but may have a federal government contract or subcontract once in a while (that triggers 3.10 Code of Business Conduct and Training) train all of its employees or just the ones that are working on federal goverment projects. Also, what if the employees are incidental to the project such as a trucker or a janitor. I have reviewed the Code and Federal Sentencing Guidelines but it does not answer the question. I believe that all employees must be trained but I was wondering if there is a FAR or other regulation that says otherwise.

See the clause at FAR 52.203-13.

Paragraph ((1)(ii) requires the contractor to provide a copy of its code of business ethics and conduct to "each employee engaged in performance of the contract."

The requirement for training is in paragraph ( c)(1) and mentions only "employees." However, I think it would be reasonable in light of paragraph ((1)(iii) to conclude that it means employees engaged in performance of the contract.

Thanks Vern: Great point you make and great insight.