GE does business with a wide spectrum of federal, state and local governments, as well as with customers funded by those governments. The breadth of our government-business portfolio has grown in recent years through a series of acquisitions, primarily in the Aviation, Oil & Gas, Energy Connections and Power businesses. While still focused predominantly on private-sector customers, we recognize that our managers and employees must take special care to understand what makes government customers different from commercial customers.
The government customers who acquire our products and services also serve to fulfill public policy objectives, and therefore may request unique contract requirements such as domestic preference restrictions, socioeconomic provisions, and especially stringent business ethics and compliance obligations. GE employees recognize that government customers have a variety of means to enforce these unique requirements (both contractual and non-contractual, including civil and criminal sanctions and administrative judgments) that go well beyond remedies available to GE’s commercial customers.
GE’s compliance and integrity culture places the Company in an excellent position to pursue and perform work compliantly for governments and government-funded contractors. But our culture is not enough; we must continue to emphasize with our employees and executives, the uniqueness of working with governments. For example, our Company-wide Government Business Center of Excellence (GBCOE) features a well-established Government Business Practice group, whose members represent each GE business. This group meets twice a month and serves as the conduit for government business–related communications both to and from GE businesses, many of which, in turn, have formed business-level GBCOEs to build capability at the local level and elevate issues to the corporate GBCOE level as needed. The GBCOE conducts monthly training on contemporary government-business topics, hosts an annual in-person conference for more intense training and networking opportunities, and periodically provides in-person training for specific GE businesses upon request. The GBCOE intranet site hosts a wealth of information on government policies and processes, as well as training materials to support GE businesses that work with government customers. Each year, the site is visited thousands of times, with GE employees accessing the hundreds of sources of helpful tools residing there.
In 2016, the GBCOE and the Policy Compliance Review Board (PCRB) continued their Company-wide focus on government business, and the Company remains well prepared to meet the unique demands of government customers and flourish in this highly regulated environment. The following steps have been taken to ensure our readiness:
- We solicited and compiled detailed information from GE businesses doing business with U.S. federal, state or local government agencies, based on our own eight (8) GE Government Business Standards. These self-assessments highlighted the nature and type of government business GE businesses are performing (including a risk profile); identified best practices and potential weaknesses relative to the Standards; and enabled GE to better orient future government-business training curricula.
- We conducted numerous training sessions in 2016, including monthly webinars, reaching employees in every GE business, on key government-business topics.
- We conducted a Company-wide government-business conference for over 100 GE employees doing business with U.S. federal, state and local government agencies.
- We conducted a number of in-person government-business training sessions at recently acquired businesses, introducing newly acquired personnel to the GBCOE, GE Government Business Standards, and best practices tailored to the needs of the businesses.
- We continued to support the integration of former Alstom entities with Energy Connections, Power and Renewables.
- We partnered with GE government compliance counsel to reinforce “pay to play” restrictions in key U.S. states where GE does business, and provided guidance when needed.
- We monitored the Federal Procurement Data System to identify any inaccuracies in the reporting of procurements awarded to GE or misrepresentations of our company size and the basis of the awards.
- We dedicated specific attention and resources to state and local contracting issues, which for many GE businesses represent all or substantially all of their government-business activities.
- We developed GE-wide implementation policies for many complex new procurement regulations to ensure a consistently high level of compliance.
- We continued to closely monitor both final and proposed changes to government procurement–related legislation, policies and regulations in order to assist businesses in understanding new requirements and establishing the appropriate compliance processes in a timely manner.
- Together with Corporate Litigation, we improved a process for quickly identifying responsibility matters that may be reportable to U.S. federal, state or local government customers.