Procurement Ethics & Compliance

We maintain the highest ethical and business standards and follow established guidelines when working with suppliers. We maintain a strict code of conduct with ethical behavior required of all team members.

Learn more about our Third Party Code of Business Conduct

Government Compliance

Another part of our job is administering government contracts like Medicare, the Federal Employees Health Benefits (FEHB) Program, and the Children's Health Insurance Program (CHIP).

In our work under these contracts, and when we acquire related goods and services, we have to meet contractual, regulatory, and statutory requirements including provisions within the Federal Acquisition Regulation (FAR) and other state and federal statutes and regulations.

Some of these requirements include:

  • Prior Notification/Approval: All procurements defined as subcontracts that allocate $25,000 or more to the federal government must have prior notification or approval. This can add 20 to 60 days to the processing of purchase orders and contracts and must be performed before awarding any commitments to a supplier. All commodity and procurement teams should keep this in mind in the beginning stages of their planning and solicitations.
  • Flow Down Clauses: Procurements defined as subcontracts that allocate $25,000 or more to the federal government must include government-defined contract clauses. These flow-down clauses must be included in either the purchase order or contract.
  • Maximize Competition: Sealed bidding and competitive negotiations are the two main solicitation methods approved and promoted by the FAR. The competitive process starts at purchases exceeding $2,500. The specific process used is determined by factors like complexity and dollar threshold. For large and complex procurements, a Request for Proposal (RFP) or Request for Quotation (RFQ) is often used to facilitate competition.
  • Supplier Certification: We may choose not to work with suppliers if they have been debarred, suspended, or otherwise excluded from certain activities by the government. Before placing orders with suppliers using government-allocated dollars, we verify the supplier’s debarment status.
  • Documentation Requirements: The government confirms compliance with its requirements based on documentation. When audits are performed, documentation must be available that proves these regulations are being adhered to.

For more information, contact Corporate Procurement at