this conduct suggests deficiencies in Company A’s internal controls.
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non-public bid information from Company A’s
Company A will need to build a new road from its facility to the port that can
to build the road The agent informs Company A’s vice president for international
non-discretionary governmental service that Company A is entitled to receive (i.e.
the successor company assumes the predecessor
due diligence helps an acquiring company
four executives from the predecessor company
and any other corruption-related issues that have surfaced at Foreign Company over the past ten years.
whether Foreign Company’s employees have been adequately trained regarding those policies
Company A discloses the conduct to DOJ and SEC
and its review of Foreign Company’s data
an employee in Company A’s international sales office (Sales Employee) learns
Company A stops the payments and DOJ and SEC investigate.
whether Company B’s employees have been adequately trained regarding those policies