| Industry: | Government Contracting |
| Underlying Misconduct: | Procurement Integrity |
| Matter Type: | Suspension & Debarment |
| Relevant Jurisdiction(s): | Air Force Office of Suspension & Debarment |
| Penalties: | |
| Fine Amount: | |
| Reporting Agencies: | Department of the Air Force |
| Resolution Form: | Administrative Agreement |
| Agreement Date: | May 1, 2014 |
| Monitor Reference Term: | Independent Monitor |
| Monitor Identity: | Affiliated Monitors |
| Monitorship Term: | 3 Years |
| Monitor Selection Process: | Though the Administrative Agreement is dated May 1, 2014, Host Organization engaged entity selected as the Monitor on January 27, 2014, shortly after being Suspended on January 10, 2014. Reporting Agency permitted entity to continue in the Monitor role. No selection process was detailed in the Agreement.
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| Time to Propose Monitors: | Not Applicable |
| Time to Engage Monitor: | Not Applicable |
| Time to First Report: | Approximately 4 Months |
| Reporting Frequency: | Quarterly |
| Monitor Required Qualifications: | None specified. Monitor was engaged prior to the Agreement and permitted to continue.
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| Summary of Monitor's Scope: | Appears that the Monitor was engaged and provided compliance consulting services whose scope was negotiated and agreed to between the Monitor and Host Organization privately, and prior to the Agreement. The Agreement adopted at least part of the scope of the private agreement, the details of which appear in the Activities section below, and focus on Host Organization's compliance and ethics program.
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| Summary of Monitor's Activities: | Prior to Administrative Agreement and adopted therein: 1) evaluate existing ethics and compliance program; 2) assess ethical culture, particularly with regard to government contracting activities; 3) review policies and procedures, training programs, and practices related to ethics and compliance; 4) assess the measures implemented to ensure (two particular persons are named) do not exercise ownership or control over Host Organization; and 5) prepare a detailed report of findings and recommendations as to specific measures and internal controls that Host Organization should adopt to establish a comprehensive, values-based ethics and compliance program.
Additionally, per the Administrative Agreement, the Monitor shall submit reports that include: 1) summaries of actions taken the Monitor and recommendations provided by the Monitor to Ahntech pursuant to the pre-Administrative Agreement work of the Monitor; 2) indications of any problems or weaknesses identified by the Program, the corrective action(s) proposed or undertaken, and the status of such corrective action(s); and 3) any recommended updates or enhancements to Ahntech's Code, along with recommendations for updated Code training materials.
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| Monitor's Restrictions: | None Specified
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