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The article examines the potential impact of FAR Subpart 3:10, Contractor Code of Business Ethics and Conduct on the system for regulating defense procurement integrity. The article argues that the adoption of the new Contractor Code of Business Ethics and Conduct will not change the already heavy emphasis placed on full compliance with criminal and civil statutes directed at protecting procurement integrity. The article also argues that the defense procurement integrity program should devote equal attention to adoption of non-criminal standards of conduct directed at assuring the impartiality and objectivity of contractor employees. Finally, the article argues that in order to rebuild public trust in contractor employees the FAR Council should require contractor employees who perform duties similar to full-time federal employees to comply with a new uniform set of non-criminal standards of conduct rules directed at assuring the impartiality and objectivity of contractor employees.

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