When apparel maker Ralph Lauren Corp. first discovered that one of its employees had been bribing custom officials in Argentina, the company immediately notified the U.S. government, offering its employees for interviews and turning over documents. In exchange, Ralph Lauren on April 22 obtained nonprosecution agreements with both the U.S. Justice Department and the U.S. Securities and Exchange Commission. The company agreed to pay about $1.6 million in penalties to resolve claims that it violated the Foreign Corrupt Practices Act (FCPA).
“Ralph Lauren Corporation did all of the right things when these issues surfaced in Argentina: it investigated, self-reported, cooperated fully with the authorities, conducted a world-wide risk assessment and implemented a series of remedial measures, including enhanced compliance programs and training,” Ralph Lauren attorney Tom Hanusik, a partner at Washington’s Crowell & Moring, told The National Law Journal by email. “The unprecedented use of non-prosecution agreements by both DOJ and SEC reflects these efforts and is a direct result of the terrific tone from the top that exists at this company.”
