Gallup is making changes to its ethics and compliance practices as part of an agreement with the Department of Homeland Security. Among the changes Gallup agreed to:
» Install a toll-free, third-party hotline for confidential reporting of suspected misconduct.
» Appoint an ethics officer who reports directly to the board. Gallup named general counsel Steven O'Brien.
» Update its business ethics code.
» Require each employee to read the updated code upon hire, discuss it with a manager, then read it again annually. Senior managers now have one hour of in-person ethics training annually.
» Appraise managers and supervisors annually on their adherence to and promotion of the ethics program. The company said that it already does this and that failure to follow Gallup's ethics and compliance programs is cause for termination.
» Create an “internal controls system” to uncover improper conduct in connection with government contracts and to ensure corrective measures are carried out.
» Company compliance officer William Kruse, who reports to the board, will make twice-annual written reports to Homeland Security describing measures taken by Gallup to implement the business ethics program and comply with the non-prosecution agreement.
» Prohibit giving any gifts, food, drink or entertainment to a government employee.
» Comply with annual external audits.
» Never employ or do business with three former employees involved in alleged unethical behavior: Warren Wright and Tim Blass, who were involved with trying to hire a FEMA employee, and Sameer Abraham, accused of working to overbill the government on contracts.