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When one company makes an error, dig to see if it’s a trend


By Flickr user briweldon

Stephen Gandel of Fortune raised an issue I didn’t see last week in a lot of the coverage surrounding the Wal-Mart bribery allegations: Is it common?

He writes:

“There are at least 81 public companies under investigation by the Securities and Exchange Commission or the Department of Justice for running afoul of the Foreign Corrupt Practices Act, which makes bribery in foreign countries punishable in the U.S. In addition, a growing number of companies have started placing disclosures in their financial documents that say their employees may at times violate the U.S.’s overseas bribery law, despite the company’s best efforts to prevent it.”

Today’s Tip: Check to see if “everyone does it.”

When covering potential wrongdoings, checking to see if the behavior is a trend can help put the story into perspective.

Stephen Gandel

Stephen says his sources mentioned the number of open investigations regarding the Foreign Corrupt Practices Act. The tip got him thinking. 

“I thought that number was surprising,” he says. “So it seemed obvious that the next step was to try to find out which companies were being investigated.”

As he notes in the story, disclosures in financial filings often provide clues. For this story, someone recommended Stephen contact Richard Cassin, an FCPA expert. Then, while researching for a database of FPCA violations, Stephen came across Cassin’s blog, he says.

That leads to his next bit of advice: “Always ask who the experts are,” he says. “Don’t worry about offending the person you are talking to.”



In Featured, Retail | Lifestyle.

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