Organizational Integrity Shorts: Don’t Just Let the Dominoes Fall; Understand the Paths They Might Take

Sheppard Mullin Richter & Hampton LLP
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Let’s say you’re a publicly traded manufacturer of a popular medical device, which you sell commercially as well as to a number of VA hospitals. You receive an anonymous internal hotline complaint alleging that certain unauthorized, reverse-engineered components were used in the manufacturing process and that certain quality tests were skipped in the interest of “efficiency.” You triage the complaint, do your preliminary diligence, determine the complaint isn’t frivolous, and launch a privileged internal investigation.

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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.

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