Recently, contractors have begun receiving formal requests for information from the Defense Contract Audit Agency (“DCAA”). The purported purpose of these requests is to “[o]btain an understanding of the management control environment” of major government contractors. In pursuit of this goal, DCAA has crafted a letter that demands, among other things, the following:
- A list of all ethics training, copies of agendas, and attendee lists
- Copies of the company’s written Codes of Conduct, copies of the policies dealing with communications of the Code, and a list of employees who have acknowledged receiving the Code over the past 12 months
- A list of all violations of the Code over the past 12 months
- All “noncompliances” reported through the contractor’s internal control system (such as a hotline) within the past 12 months
- A “company-wide list of any current open investigations”