Posts Tagged ‘bribery’

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Episode #53

In Comverse Technologies,Declinations,Due Diligence,Esquinazi,Hewlett Packard Co.,NCR,O'Shea,Self-disclosure,Speaking Engagements,TWIFCPAVideocast on September 16, 2012 by Howard@OpenAir Tagged: , , , , , , , , , , , , , , , , , , , ,

Tom and I discuss HP, NCR & how NOT to react to whistleblowers, the new and improved DOJ web site, Comverse Technologies and a lenient sentence for Paul Cosgrove. Episode #53.

00:39: More than you wanted to know about Howard’s new site (the redesigned Open Air Blog)
01:51: Have a happy new year
02:55: Hewlett Packard (Howard recuses himself from the discussion, so this is all Tom)
06:09: You missed my birthday. Don’t worry, you don’t have to apologize
06:43: NCR shows considerable skill at treating a whistleblower complaint in exactly the wrong way. Tom & I talk about how to handle a whistleblower better. And here’s the link to Mike Volkov’s video.
18:12: DOJ improves their already-great Web site. And they work really, really hard
23:07: Tom is speaking in Singapore. If you’re anywhere close, you really need to go. Here’s the link to the conference. And in San Diego. The San Diego one is on diligence, and is with Mike Volkov
27:32: Comverse: we can’t guarantee that we won’t screw up…again. Ooookkkaaaayyyy, Comverse. Thanks for sharing. And how to actually have consistent messaging.
36:44: Paul Cosgrove, former global head of Sales at Control Components, Inc. (CCI), gets sentenced. Ending a very interesting case. And neither Howard nor Tom are Supreme Court scholars. Little help, anyone? And Howard is going to be in the same room with Lanny, in the near future, in London!

Articles

Episode #52

In disclosure,Harris Corp.,News Corp.,Safran,State-Owned Entities,TWIFCPAVideocast,UK Bribery Act,Wal-Mart on September 10, 2012 by Howard@OpenAir Tagged: , , , , , , , , , ,

Tom and I talk about Tom’s talk tomorrow in Chicago, News Corp.’s latest arrest, Safran’s ridiculously low fine, how much an investigation should cost (more if you’re Walmart, versus ABM), the SFO and gifts, Harris Corp. and gifts, and more!

Show notes:

00:41: Go hear Tom in Chicago, Tuesday morning at the University Club of Chicago, hosted by Kreller, along with Stephen Martin of Baker McKenzie. They’ll be talking about the 5 key elements of a corporate compliance program

02:15: Is the SFO backing off prosecution of the UK Bribery Act? So argues Alexandra Wrage.

16:03: Mike Koehler is amazing. And, he writes. What is a government instrumentality, he asks, now that the Conflict Minerals rule defines it as when a foreign government owns 51% or more of the third party.

23:19: Anytime a lawyer gets arrested, we take notice. The head of legal for News of the World gets arrested.

26:48: How much should FCPA investigations cost? For Walmart, $51 million. For ABM, $3.3 million

29:27: Safran pays a “fine.” €500,000 to get a €170 million contract. Or, as I call it, cost of sales. Could it be because they’re 1/3 owned by the French government? Hey, DOJ/SEC: do something about this. Please.

35:05: NYU study on self-disclosure. Does self-disclosure have an effect on the penalty?

40:07: Harris Corp. investigating itself. Over gifts. “Why? Why? Why?,” I cry. And a question to ponder: is it possible to retain revenue going forward when you find old contracts were obtained through bribery?

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Episode #50

In Pfizer on August 17, 2012 by Howard@OpenAir Tagged: , , , , , , , , , , , , , , , , ,

Tom and I talk about the Pfizer DPA, and what lessons we can learn from a company that’s been doing it right for more time than most companies have even heard of the FCPA.

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