Ralph Lauren Corporation ("RLC") is incorporated in Delaware with its principal place of business in New York, New York. RLC is a world-wide designer, marketer and distributor of premium apparel, accessories, fragrances and other products. RLC's stock is registered pursuant with the SEC and is listed on the New York Stock Exchange.
P.R.L. - S.R.L. ("RLC Argentina") was an indirect wholly-owned subsidiary of RLC headquartered and incorporated in Argentina. RLC Argentina marketed and sold RLC and other merchandise, including merchandise that was imported from outside Argentina.
From approximately 2004 through approximately 2009, RLC Argentina's General Manager and others who worked at RLC Argentina approved bribe payments of approximately $580,000 to be made to Argentine customs officials through Agent 1 to assist in improperly obtaining paperwork necessary for RLC products to clear customs, to permit clearance of items without the necessary paperwork, to permit the clearance of prohibited goods, and to avoid inspection of products by Argentine customs officials.
On April 22, 2013, the DOJ entered into a two year Non-Prosecution Agreement with RLC. Under the terms of the NPA, RLC agreed to pay a monetary penalty of $882,000, to continue to implement and enhance its anti-corruption compliance policies and procedures, and to submit annual reports to the DOJ for the duration of the NPA on the progress of its anti-corruption compliance. The DOJ determined that an NPA was appropriate due to RLC's discovery and self-report of the misconduct as well as the company's extensive, thorough, real-time cooperation with the DOJ and SEC and its extensive remedial efforts.
In a related proceeding on April 18, 2013, the SEC entered into a Non-Prosecution Agreement with RLC. Under the terms of the NPA and without admitting or denying the allegations in the NPA's statement of facts, RLC agreed to disgorgement of $593,000 plus prejudgment interest of $141,846. The SEC determined that an NPA was appropriate due to RLC's discovery and self-report of the misconduct as well as the company's extensive, thorough, real-time cooperation with the SEC and DOJ and its extensive remedial efforts.
