Moving Companies Forward

DCLC Culture and Ethics

A member of APMP, a Shipley Associate, and retired Air Force Officer; I have experience with Fortune 500 companies, mid sized organizations, small businesses, and start ups.  Because I have been part of a wide range of organizations, I understand how to move quickly into your corporate culture.  On day one, I make a plan and discuss the deliverables to be sure you obtain what you need.  In a very short time I am making progress, moving from nothing to something, then from something to the completed project.

Once I start, I do not stop, I collaborate with your staff, look for common ground on each topic, and do not get distracted until the solution is implemented; I bring your task to close, hand you the right deliverable, on time, built the right way.

There are four pillars that drive the ethics and culture of my company – respect, responsibility, integrity and accountability.  These pillars guide my daily activities.  I apply these values to business relationships, contract environment, and fiscal controls.   I have established the DC Livingston Consulting (DCLC) Code of Ethics (CoE) that drives the way I conduct myself in a clients workplace or when working out of my office.

My continued success depends on doing the right thing at all times and maintaining the highest ethical standards possible. Only in this way, can I continue to earn and maintain the trust of my clients.  What follows are the essential elements of the DCLC CoE .


Equal Employment and Nondiscrimination.  DCLC will not tolerate discrimination, harassment, intimidation or coercion related to race, color, religion, sex, age, national origin, disability, or sexual orientation. This policy extends to all phases of subcontractor relationships, including selection, placement, transfer, training, and the use of facilities.

Political Involvement.  DCLC strives to give back to our communities by becoming involved in the political process. However, it is important the involvement does not create the appearance that DCLC is endorsing the specific political activity.  The company name and company resources will not be used to support the political process unless approved by the Company President.

Record Management.  DCLC and all subcontractors will conform to, the government’s document retention policy as well as the client’s recordkeeping and reporting procedures.  DCLC and all subcontractors will take aggressive steps to protect client information including employment data and especially medical data.  All company and client communications, correspondence, and records will be accurate, complete, and timely.

Government Property.  DCLC and all subcontractors will only use Government property as authorized under the terms of our contract or subcontract.  All Government-approved property in control of the client will be maintained in accordance with applicable regulations and the terms of applicable contracts.


Classified Information.  DCLC sand subcontractors are required to properly safeguard and control access to Government that is classified as national security information in accordance with the security guidelines prescribed by Federal agencies and the terms of applicable contracts.  DCLC will immediately report any known or suspected security infraction or violation to the client’s Facility Security Officer (FSO).

Drugs and Alcohol.  DCLC and all subcontractors will report to work as agreed and service contract obligations productively and safely.  Drug and alcohol abuse will not be permitted; DCLC will take the appropriate action to maintain compliance with this policy and protect the clients interests..

Electronic Technology.  DCLC and all subcontractors will not install software or modify the configuration of client systems, desktops, or laptops without appropriate authorization.

Investigations and Audits.  DCLC and all subcontractors will fully cooperate with investigations and audits.  During company or government investigations (including corporate Investigations, internal audit, or litigation); DCLC and all subcontractors will cooperate fully with investigative instructions and tell the truth.  We will maintain the confidentiality of all information communicated to us in the course of an investigation, audit or litigation matter; permit the professionals to investigate; and we provide information only to designated personnel.


Export Restrictions.  DCLC and all subcontractors are responsible for complying with all export laws, and we will obtain licenses or other government approvals prior to exporting products and technology controlled by the Government.  We must immediately report any known or suspected trade control violation to more than one client Vice President.

Procurement Integrity.  DCLC and all subcontractors will not disclose or receive confidential contractor bid or company information or source selection information to or from unauthorized parties.  Source selection information includes prices, technical evaluation plans, competitive range determinations or ranking of proposals.

Quality Assurance and Material Sourcing.  DCLC and all subcontractors will provide to the Government only those products and services that conform to contract requirements and we will ensure that suppliers of raw materials, parts and components used in our products have an acceptable quality control system.  We will not supply a product to the government or certify its origin unless we are sure that the product’s country of origin complies with all applicable domestic sourcing and trade agreement laws and regulations.

Charging Costs to a Contract.  When DCLC and all subcontractors work a contract or subcontract we will accurately record the hours worked and properly allocate the hours worked to the project.  We will charge all labor and material costs to the proper contract and charge indirect costs properly.


Accurate Statements.  During the government procurement process, DCLC and all subcontractors may be required to complete and sign prescribed Government forms.  Each time these forms are executed, we are making a representation to the Government.  We will be truthful and accurate when preparing and signing government documents.

Conflicts of Interest.  DCLC and all subcontractors will not engage in activities that could impair the ability of the client to render impartial services pursuant to a contract directly or indirectly with the government or could give an unfair advantage in competing for a contract because of access to information obtained as a result of certain contractual relationships with the government.

Gifts and Business Courtesies to Government or Political Entities.  DCLC and all subcontractors will not offer or give any item of value to any client employee except for infrequent common hospitality of very low value (under $5.00), such as soft drinks, coffee and light snacks at business meetings, or advertising or promotional items of very low value such as calendars, pens and coffee cups (under $5.00).

Graft and Bribery.  DCLC and all subcontractors will avoid the solicitation or reception of anything of value in consideration for influencing the direction of a government program or a government contract.  Items of value include but are not limited to the payment of any favors, personal services, fees, commissions, bonuses, or procurement a loan with favorable terms of repayment from a financial institution.