I do not know if Wal-Mart had a “hotline” in 2005, but in order to give employees and/ or third parties the tools necessary to alert executives or members of the Board of Directors to potential illegal or questionable...more
The old DC adage, never do anything you wouldn’t want to see reported on the front page of the New York Times, must have taken on a very personal meaning to the senior management and directors of Wal-Mart and News Corp. Both...more
Originally publish in The New York Times on April 25, 2012 A decade ago, the Foreign Corrupt Practices Act, which bars American companies from bribing officials overseas, was rarely enforced or discussed. Today, it...more
Will the Wal-Mart bribery case in Mexico have a lasting effect on compliance? Or is it a fleeting headline? This article discusses some reasons they this FCPA case will matter....more
Originally published in Law360, New York (April 23, 2012, 9:40 PM ET) Wal-Mart Stores Inc. and some of its executives may face criminal charges and millions of dollars' worth of civil penalties in the wake of a report...more
Over the weekend, The New York Times broke a major story, publishing a highly detailed 8,000-word article that seems to indicate that Wal-Mart not only engaged in a pattern of bribery of Mexican government officials in the...more
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