Contractor Code of Business Ethics & Compliance Program Requirements

Contractor Code of Business Ethics & Compliance Program Requirements NNS Supplier Quality Team February 2023

Purpose 2 What is an Ethics an Compliance Program? Why is an Ethics and Compliance Program required? Purchase order resources – Appendices – Contract flow down (FAR, DFARS) What triggers an Ethics and Compliance audit? SQ assessment questions Ethics and Business Conduct Supplier Tools SQ Email Contact Ethics and Compliance is everyone’s responsibility HUNTINGTON INGALLS INDUSTRIES/NEWPORT NEWS SHIPBUILDING PROPRIETARY

What is an Ethics and Compliance Program? A program designed to promote an organizational culture that encourages ethical conduct and compliance with applicable laws, regulations, and policies. – Company Values – Code of Conduct – Procedures and processes established to monitor, detect, and report suspected instances of improper conduct – Training – Periodic evaluation of the effectiveness of the program Ethics and Compliance is everyone’s responsibility HUNTINGTON INGALLS INDUSTRIES/NEWPORT NEWS SHIPBUILDING PROPRIETARY 3

Why is an Ethics and Compliance Program Required? NNS expects suppliers to have an Ethics and Compliance program NNS contracts flow down applicable FAR and DFAR requirements – FAR 52.203-13 , Contractor Code of Business Ethics and Conduct – FAR 52.203-14, Display of Hotline Poster(s) – FAR 52.203-15, Whistleblower Protections – DFARS 252.203-7002 , Requirement to Inform Employees of Whistleblower Rights – DFARS 252.203-7004, Display of Hotline Posters Ethics and Compliance is everyone’s responsibility HUNTINGTON INGALLS INDUSTRIES/NEWPORT NEWS SHIPBUILDING PROPRIETARY 4

Purchase Order Resources - Appendices Specific FAR and DFAR requirements can be found under NNS Appendix A-DOD Contracts, Provision 50 HUNTINGTON INGALLS INDUSTRIES/NEWPORT NEWS SHIPBUILDING PROPRIETARY 5

Purchase Order Resources – Contract Flow downs FAR and DFARS websites can be accessed via the Purchase Order Resources section of the External Supplier website – Federal Acquisition Regulations (FAR) – Defense Federal Acquisition Regulations Supplement (DFARS) Search by FAR or DFAR Part/Subpart for clause requirements HUNTINGTON INGALLS INDUSTRIES/NEWPORT NEWS SHIPBUILDING PROPRIETARY 6

What triggers an Ethics and Compliance audit? Ethics and Compliance is audited or assessed every time: – A QMS or NAV 20 Contract Review audit is conducted, – An Appendix A audit is conducted – During an ISA/STAV, the Ethics and Compliance program is assessed A dedicated Ethics and Compliance audit can occur: – When requested, any purchase order that meets the threshold for an Ethics and Compliance program – Special requests from management HUNTINGTON INGALLS INDUSTRIES/NEWPORT NEWS SHIPBUILDING PROPRIETARY 7

Supplier Quality Assessment Questions Do you have solicitations or contracts with sub-tiers that exceed the FAR/DFAR contract value and have a performance period of 120 days or more? Do you have an Ethics and Compliance program? Do you have a written Code of Ethics? Do you have an Ethics and Compliance training program? What is your process for communicating this information to your employees? What is your process for reporting FAR Mandatory Disclosure violations? What is your process for ensuring complaints are addressed in a timely manner? In the event a misconduct occurred, do you have a Corrective and Preventive process to prevent a similar misconduct? HUNTINGTON INGALLS INDUSTRIES/NEWPORT NEWS SHIPBUILDING PROPRIETARY 8

Ethics and Business Conduct Supplier Tools External Supplier website provides Supplier Ethics and Compliance resources for the Supply Base. HUNTINGTON INGALLS INDUSTRIES/NEWPORT NEWS SHIPBUILDING PROPRIETARY 9

Ethics and Business Conduct Supplier Tools You are free to use this information to support your program. Provides quick links to content and tools Provides template examples of procedures, Code of Ethics, and posters Provides other DoD Hotline Resources HUNTINGTON INGALLS INDUSTRIES/NEWPORT NEWS SHIPBUILDING PROPRIETARY 10

Questions Any questions concerning this material can be sent to: [email protected] HUNTINGTON INGALLS INDUSTRIES/NEWPORT NEWS SHIPBUILDING PROPRIETARY 11

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