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 | Investigations Dataset

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

Investigations Dataset

 
Investigation into Becton, Dickinson and Company's Activities in the U.N. Oil-for-Food Program · Becton, Dickinson and Company

Information & Summary

Investigation into Becton, Dickinson and Company's Activities in the U.N. Oil-for-Food Program

Related FCPA Matter:   Becton Dickinson's Involvement in the U.N. Oil-for-Food Program Information

Information & Summary

Investigation Name:    Investigation into Becton, Dickinson and Company's Activities in the U.N. Oil-for-Food Program

Trend:    United Nations Oil-for-Food Program

Type of investigation:    Internal

Whistleblower:    Unknown

Summary

Becton, Dickinson and Company (BDC), incorporated and headquartered in New Jersey, is a global medical technology company that develops, manufactures and sells medical devices, instrument systems and reagents. Its common stock was traded on the New York Stock Exchange.

As disclosed in BDC's SEC filings, Becton Dickinson France, S.A. (BD-France), a subsidiary of BDC, was listed among approximately 2,200 other companies in an October 27, 2005 report of the Independent Inquiry Committee (“IIC”) of the United Nations (“UN”) as having been involved in humanitarian contracts in which unauthorized payments were suspected of having been made to the Iraqi Government in connection with the UN’s Oil-for-Food Program (OFFP).

In connection with the IIC’s report, Becton Dickinson AG (BDAG), a Swiss subsidiary of BD, received a letter of inquiry from the Vendor Review Committee (“VRC”) of the United Nations Procurement Service dated November 22, 2005. The letter of inquiry said that the VRC is reviewing BDAG’s registration status in light of BD-France being listed in the IIC’s report and asked BDC for any information it might be able to provide relating to the findings of the report.

BDC conducted an internal review and found no evidence that BDC or any BDC employee made, authorized, or approved improper payments to the Iraqi Government in connection with the OFFP.

The representative utilized by BDC in Iraq also unequivocally denied having made any such payments, and BDC was unable to find any evidence of such payments being made by this representative.

BDC reported the results of its internal review to the VRC.

In May 2008, BDC received a letter from the UN stating that BDAG had been suspended from the UN Secretariat Procurement Division’s vendor roster for a minimum period of six months.

In May 2007, the French Judicial Police conducted searches of BD-France’s offices in France with respect to the matters that were the subject of the 2005 IIC report.

In June 2009, the Belgian Federal Police contacted BDC to interview certain individuals and review documents related to sales made under the OFFP.

BDC’s November 23, 2011 10-K filing was the last disclosure made regarding this investigation. There was no indication by BDC that US authorities became involved in this matter. The investigation is likely complete.

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