Brooks is a vice president who mainly deals with domestic jobs, but has a new project working with a foreign government. It just so happens that Brooks has a personal relationship with a Foreign Official from that country and knows him and his family well. Brooks, however, has not disclosed this relationship to the Company. When the Official called one day and asked her to find an internship for the Official 's daughter at the company, Brooks thought nothing of it. It was something she would do for any friend, and helping the Official 's daughter could only have a positive effect on the pending deal between the Company and the Country.
When she called H.R. to inquire about a possible internship and explained the situation; Ken, the H.R. manager that she spoke with, marked the daughter’s file as "Referral, Special" and put it on the top of the file. When the time to conduct interviews came there were more qualified candidates than the foreign official 's daughter. However, the interviewer noticed the note left on the file and selected the daughter for the next round of interviews anyway.
The next round was with Ken, who after interviewing the daughter called Mac a member of Brooks’ team to express her concerns about the daughter saying she was "not a skill match," and "did not meet the minimum requirements for moving forward with an offer". Mac replied "I know this is a pain, but I think we 're operating under a different Paradigm here than a normal hire no hire decision tree. The foreign official is a close friend of Ken, and we do a great deal of business with him, and are hoping to do more." The daughter was offered the internship the next day.
You can see from...
... middle of paper ...
...hink something unethical occurred is occurring your first call should be to the compliance office. They can access the conflicts of interest registry, and will be able to find out if the person in question has registered a conflict of interest. If there is not conflict but you are still concerned about possible unethical actions you can reach back out to compliance or submit a ticket to our confidential whistle blowing service on the intranet (Policies>Whistle blowing services). This is web based anonymous and confidential third-party service for reporting any potential unethical practices.
This case study information and quotations were taken from a settlement agreement between the U.S. Securities and Exchange Commission and a U.S. based multinational company. The settlement agreement included a $7.5 million ($9.84 million CAD) penalty for their unethical actions.
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