ServiceNow embroiled in DOJ probe of government contract award

Iyer “did the right thing by clearing the job with the appropriate DOD people,” but others at ServiceNow might have had different expectations, Rasch said. “The COO could have expected him to do things that would have violated conflict-of-interest rules and that’s why they hired him. There are rules about what you are allowed to do and what you are not allowed to do. You absolutely don’t want to push that.”

New reporting guidelines

Another former federal prosecutor, also unconnected with the investigation, said much of this case likely involves how things look. 

“When employees take actions which, at minimum, create a significant appearance of impropriety, without first discussing the issue with management and/or the board, it suggests a lack of judgment,” said Brian Levine, who now serves as managing director at Ernst & Young. Such action “makes it hard for the company to have continued confidence and trust in the employee. Thus, management changes should come of no surprise,” he said.