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 | Investigations Dataset

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

Investigations Dataset

 
Investigation into Tyco's Activities in Multiple Countries · Tyco International Ltd./TE Connectivity/Covidien

Information & Summary

Investigation into Tyco's Activities in Multiple Countries

Related FCPA Matter:   Tyco International's Involvement in Multiple Countries from 2006 to 2009 Information

Information & Summary

Investigation Name:    Investigation into Tyco's Activities in Multiple Countries

Trend:    None

Type of investigation:    Internal, SEC, DOJ

Other Agencies Investigating/Assisting with SEC/DOJ Investigation:   

  • Italian Public Prosecutor of Milan

Whistleblower:    Unknown

Summary

Tyco International Ltd. ("Tyco") was a leading global provider of security products and services, fire detection and suppression products and services and life safety products.

In 2005, Tyco informed the DOJ and the SEC that it had retained outside counsel to perform a company-wide baseline review of its policies, controls and practices with respect to compliance with the FCPA and that it would continue to investigate and make periodic progress reports to these agencies.

According to its July 29, 2010 10-Q, Tyco reported to the DOJ and the SEC the investigative steps and remedial measures that the company took in response to allegations of improper payments by subsidiaries and internal investigations regarding those allegations.

Tyco communicated with the agencies to provide updates on the baseline review and follow-up investigations, including briefings concerning additional instances of potential improper conduct identified by the company in the course of its compliance activities.

Further disclosed in its SEC filings was the fact that Covidien Public Limited Company and Tyco Electronics Ltd., both former subsidiaries, agreed, in connection with a separation agreement from Tyco, to cooperate with the company in its responses regarding the investigations.

On September 24, 2012, Tyco settled the charges related to the alleged improper payments with the DOJ and the SEC, and a subsidiary of the company (which is no longer part of Tyco as a result of the 2012 Separation) pleaded guilty to one count of conspiracy to violate the FCPA.

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