In this electronic age, ubiquitous email can be the smoking gun that enforcement agencies rely on to demonstrate corporate wrongdoing. But the savvy and unscrupulous look for new ways to erase their email tracks and avoid detection. For compliance officers, that means having a clear understanding of how employees may be misusing technology to dodge the rules.
According to an article in the Wall Street Journal last week, a marketing manager named Ruiting “Candy” Chin at British drug maker GlaxoSmithKline specifically instructed her sales team members to use their personal email accounts, rather than their work accounts, to conduct some of their business. Portions of the email were made public last week in light of allegations that the company bribed doctors in China in order to encourage them to prescribe the company’s drugs. Although GSK had been embroiled in allegations of bribery in China since 2010, the company received renewed attention last week when it was disclosed that Chinese authorities had recently detained several former GSK employees and that those employees had since admitted to making payments to doctors.
