Author Archive | Kendra & Justin

Walmart Fined $282M for FPCA Violation

Yesterday, Walmart entered into a Non-Prosecution Agreement to settle allegations that it violated the Foreign Corrupt Practices by paying an intermediary in Brazil for help obtaining construction permits and operating without a system of sufficient anti-corruption related internal accounting controls in Brazil, China, India, and Mexico.  Walmart Inc. will be required to pay the DOJ […]

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Kendra Cook Named IEEE Aerospace Conference Chairman

C2I founding partner Kendra Cook was named Chairman of the IEEE Aerospace Conference this week in Big Sky, MT. The international IEEE Aerospace Conference, with AIAA and PHM Society as technical cosponsors, is organized to promote interdisciplinary understanding of aerospace systems, their underlying science and technology, and their applications to government and commercial endeavors.   […]

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Zero-tolerance policies are dishonest and damaging

By Marc Le Menestrel, original post on FCPA Blog, February 6, 2019 (http://www.fcpablog.com/blog/2019/2/6/zero-tolerance-policies-are-dishonest-and-damaging.html) These days, I sometimes begin my classes on corruption with an unusual admission. I announce to my students — who may be judges, police officers, military investigators, bureaucrats or any other variety of public official — that corruption is not a problem removed […]

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What is corruption? Depends on who’s looking.

By William N. Weaver, originally posted on The FCPA Blog January 29, 2019 (http://www.fcpablog.com/blog/2019/1/29/what-is-corruption-depends-on-whos-looking.html) For those interested in the study of corruption from the scientific perspective one thing stands out: actual corruption is essentially unmeasurable.  It could also be observed that our imperfect measurements of corruption, even more accurate random forced response surveys, have found […]

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Chinese Company Required to Hire U.S. Compliance Officers

In April, ZTE, China’s largest telecommunications equipment manufacturer, was sentenced to a seven year denial of export privileges for illegally shipping telecommunications equipment to Iran and North Korea.  The export denial bars American companies from selling components to the Shenzhen-based company.  ZTE depends on U.S. companies for parts used in its networking gear and smartphones.  […]

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Kendra Cook Named Vice Chair of IEEE Aerospace Conference

C2I founding partner Kendra Cook was named Vice Chair of the IEEE Aerospace Conference this week in Big Sky, MT. The international IEEE Aerospace Conference, with AIAA and PHM Society as technical cosponsors, is organized to promote interdisciplinary understanding of aerospace systems, their underlying science and technology, and their applications to government and commercial endeavors. […]

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Whistleblower Reality

On November 1, the FPCA Blog published a post from an anonymous contributor who is a whistleblower.  In the very candid article, the whistleblower describes what it’s like to repeatedly attempt to report issues internally, only to be turned away.  This person’s compliance department warned them not to send or distribute the information that was […]

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Understanding What Your Code Of Conduct Can And Should Be – By Joel A. Rogers

At the simplest level, a Code of Conduct should be a user-friendly guide for employees, written in plain language, that helps them navigate ethical issues in their everyday business activities. When they function at their best, good Codes of Conduct deliver a powerful message to readers both inside and outside of the company. They communicate to […]

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