Ethics Advantage Clause Samples

Ethics Advantage. UTC's Ethics Advantage system, used for tracking compliance investigations, contains a series of fields that address specific compliance concerns, which can then be used to identify specific matters that should be elevated within the company. For instance, if the "FAR Reviewable" box is checked for a matter, which is the default for any new entry, the Vice President, Global Compliance or his designee must review the matter to determine whether it concerns significant contract overpayments, violations of federal criminal law involving fraud, conflict of interest, bribery and gratuities, or violations of the civil False Claims Act, the disclosure of which is mandatory under the FAR. New matters for which the "FAR Reviewable" box has been checked also are referred to legal counsel for further review.