Audit Report

01-24-2013
Contract Management
Defense Advanced Research Projects Agency's Ethics Program Met Federal Government Standards (Project No. D2012-D000AB-0119.000)
DODIG-2013-039

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What We Did

Our audit objective was to determine whether DARPA ethics policies and program implementation were consistent with Federal Government conflict-of-interest mitigation standards and whether DARPA personnel were properly trained and following their policies. In addition, we determined whether DARPA awarded BAE contracts as a result of undue influence from former BAE Systems employees in the DARPA Information Innovation Office.

What We Found

The DARPA ethics policies and program implementation were consistent with Federal Government conflict-of-interest mitigation standards, and the DARPA personnel we selected for review were properly trained and followed DARPA policies. In the last 3 years, DARPA officials issued standard ethics guidance and operating procedures that implemented ethics laws and regulations. The only DARPA ethics rule change was to the broad agency announcement process and the recusal rules interpretation for employees covered by the Intergovernmental Personnel Act.

DARPA’s ethics program appropriately mitigated the potential for conflicts-of-interest. In addition, DARPA’s ethics training followed Federal Government ethics rules and regulations, and for its annual training, the DARPA Deputy Designated Agency Ethics Official (DAEO) used the ethics training material developed each year by the DoD Standards of Conduct Office. Finally, we determined that the program management and contract award process participation of the DARPA employees who formerly worked for BAE Systems or its subsidiary, AlphaTech (BAE/AlphaTech), did not create a conflict-of-interest between the two entities. In addition, DARPA did not award BAE Systems contracts as a result of undue influence from former BAE employees in DARPA’s Information Innovation Office.

Management Comments

We do not require a written response to this report.


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