I.  Miscellaneous Comments

The Councils considered, but did not implement, a variety of additional comments. These included suggestions that the rule require the following:

Use of a standard non-disclosure agreement form, to be published by the Government.

Use of a standards financial disclosure form, to be published by the Government.

Placement of responsibility for compliance at a "high level" within the contractor organization.

Use of established structures required for implementation of the Contractor Code of Business Ethics for implementation of these requirements.

Certification from the contractor that no personnel have a personal conflict of interest.

Establishment of training programs for contractor personnel.

In each of these cases, implementation of the recommendation is neither necessary nor desirable, because establishing additional structural requirements would eliminate the flexibilities provided to contractors. The proposed rule sets out the requirements with which each contractor must comply, but allows latitude for the application of business judgment in structuring internal programs to achieve that compliance.

Comment: Finally, one respondent suggested that the proposed rule should require "that a contractor certify that * * * no covered personnel have a personal conflict of interest."

Response: A certification requirement would not add any substantial protections not already present in the rule.