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 | Investigations Dataset

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

Investigations Dataset

 
Investigation into Evergreen Packaging Shanghai's Activities in China · Pactiv Evergreen Inc.

Information & Summary

Investigation into Evergreen Packaging Shanghai's Activities in China

Related FCPA Matter:   Pactiv Evergreen's Involvement in China Information

Information & Summary

Investigation Name:    Investigation into Evergreen Packaging Shanghai's Activities in China

Trend:    None

Type of investigation:    Internal, SEC, DOJ

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

Whistleblower:    Unknown

Summary

Pactiv Evergreen Inc. (Pactiv), a Delaware corporation with principal offices in Illinois, manufactures fresh food and beverage packaging for the worldwide market. Its common stock is traded on the Nasdaq Global Select Market.

In its registration statement issued on September 8, 2020, Pactiv disclosed that it had identified certain practices in the company's Evergreen Packaging Shanghai business (“EPS”) that involved acts potentially in violation of the FCPA. Pactiv initiated an internal investigation, which was conducted by external counsel, accountants, and other advisors. Though the investigation was not complete at the time of the registration statement, Pactiv had identified the occasional giving of gift cards representing relatively minor monetary values to government regulators in China and/or employees of one or more state-owned enterprises in the country. Additionally, Pactiv determined that it was possible that EPS potentially violated the FCPA by engaging external consultants to interact with government regulators in China to avoid potential adverse action by those regulators. The company disclosed that it had initiated procedures to remediate such practices, including discontinuing the giving of gift cards and the engagement of any such consultants.

Pactiv also said that it had voluntarily self-reported these matters to the DOJ and SEC and that it intended to cooperate fully with the agencies' reviews of the matter, and in February 2021, the company presented the findings of its internal investigation to the agencies.

In its 10-Q filed on May 6, 2021, Pactiv disclosed that the DOJ had closed its investigation and did not intend to pursue any further action.

In its 10-Q filed on August 5, 2021, Pactiv disclosed that the SEC had informed the company that it intended to close its investigation without any further action.

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