How To Turn A Season Around

Thomas Fox - Compliance Evangelist
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One of the more enjoyable aspects of a baseball season is its length. The fortunes of a team can ebb and flow over the course of a 162 games season. So even if a team starts out abysmally, it can pick things up over the course of the spring and summer and give some hope to the team in September and perhaps even into the next year. With this in mind, we posted the question in an April post as to who would have the better season, the Houston Astros, who started the season at 0-8, or Hewlett-Packard (HP) which, at that time, had announced that it was under an investigation for alleged Foreign Corrupt Practices Act (FCPA) violations regarding the sale of computer hardware in Russia. I’m happy to report that after an anemic start the Astros have played .500 ball, going 71-71 and even have one of the better records in the National League since the All-Star Game. However, the season may not be going along in such an upbeat manner for HP.

As reported on Friday in the Wall Street Journal (WSJ), the HP bribery probe has widened and HP, itself, has announced that investigators have “now expanded their investigations beyond that particular transaction.” This original investigation pertained to an investigation of allegations that HP, through a German subsidiary, paid bribes to certain Russian officials to secure a contract to deliver hardware into Russia. The contract was estimated to be worth approximately $44.5 million and the alleged bribes paid were approximately $10.9 million. In a 10-Q filing made with the Securities and Exchange Commission (SEC) last week, HP stated that the investigation has now expanded into transactions “in Russia and in the Commonwealth of Independent States sub region dating back to 2000.” The WSJ noted that US public companies, such as HP, are only required to report FCPA investigations in SEC filings if they “are material for investors.”

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

© Thomas Fox - Compliance Evangelist

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Thomas Fox - Compliance Evangelist
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