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 | Investigations Dataset

Stanford Foreign Corrupt Practices Act Clearinghouse a Collaboration with Sullivan & Cromwell LLP

Investigations Dataset

 
Investigation into Lennox International's Activities in Russia · Lennox International Inc.

Information & Summary

Investigation into Lennox International's Activities in Russia

Related FCPA Matter:   Lennox International's Involvement in Russia Information

Information & Summary

Investigation Name:    Investigation into Lennox International's Activities in Russia

Trend:    None

Type of investigation:    Internal, SEC, DOJ

Other Agencies Investigating/Assisting with SEC/DOJ Investigation:    Unknown

Whistleblower:    Unknown

Summary

Lennox International Inc. ("Lennox"), a Delaware corporation with headquarters in Texas, is a global provider of climate control solutions. Founded in 1895, it designs, manufactures and markets a broad range of products for the heating, ventilation, air conditioning and refrigeration markets.

According to the company's 10-Q filing, in October 2016, Lennox self-reported to the SEC and DOJ an alleged payment made by the company's Russian subsidiary in the amount of 30,000 rubles (approximately US $475) to a Russian customs broker or official. The alleged payment was purportedly made to release a shipment of goods being held by Russian customs officials due to inaccurate paperwork. The value of the shipment was approximately €62,000 (approximately US $68,500).

The company, under the oversight of its Audit Committee, initiated an investigation into this matter with the assistance of external legal counsel and external forensic accountants. The investigation has not resulted in any evidence of other potentially improper payments, although it has raised questions regarding possible irregularities with respect to other Russian customs documents. Lennox has disclosed that it intends to cooperate with the SEC and the DOJ regarding this matter.

In its February 21, 2017 10-K filing, the company had expanded its internal investigation to include possible non-compliance with customs documents and procedures in Poland because its operations there used the same third-party logistics providers as in Russia.

In its April 24, 2017 10-Q filing, the company announced it had expanded the internal investigation to include Ukraine.

In its April 23, 2018 10-Q filing, Lennox disclosed that the DOJ had closed its investigation into the company and would pursue no further action.

The 10-K filed on February 19, 2019 contained the last mention of the SEC investigation.

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