Proposed changes to the FAR 72 Fed. Reg. 7588 (Feb. 16, 2007) (to be codified at 48 C.F.R. subpart 3.10, http://a257.g.akamaitech.net/7/257/2422/01jan20071800/edocket.access.gpo.gov/2007/pdf/07-698.pdf) would require companies receiving a federal prime contract or subcontract in excess of $5 million to (1) adopt a written code of ethics and business conduct; (2) adopt an employee ethics and compliance training program; (3) adopt an internal control system; and (4) display agency Office of Inspector General hotline posters in common work areas where covered contracts are being performed. Contracts performed outside of the United States, whose performance period is less than 120 days, or that are “commercial item” contracts under FAR Part 12, would be exempt.