Inside this Edition:
You Can’t Make This Stuff Up (3)
Dear Tiger: Does Winning Really Take Care of Everything?
New NLRB Confidentiality Language for Your Code
WalMart Links Exec Pay to Compliance
This Week’s Highlighted Story:
SEC Press Release in Ralph Lauren DPA Cites Cooperation & Significance of “Effective Compliance Programs”
SEC.org, April 22, 2013
In announcing the Ralph Lauren DPA this week settling illegal payments by its Argentinian subsidiary, the SEC cited the company’s cooperation and also its compliance efforts, confirming the value of “effective compliance programs” and “selfpolicing.” The company discovered the bribes to custom officials after a new FCPA compliance program and audit in the region surfaced the issues.