SL Industries’ Gifts and Entertainment Disclosure

From the ‘investigations’ index of ethiXbase, here is SL Industries Inc.’s FCPA disclosure in its latest Form 10-Q filed May 10, 2012.

The New Jersey-based company designs, manufactures, and markets electronics and power protection equipment used in the aerospace, computer, telecom, medical, and transportation industries.

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Excerpt

The Company has been and is conducting an investigation to determine whether certain employees of SL Xianghe Power Electronics Corporation, SL Shanghai Power Electronics Corporation and SL Shanghai International Trading Corporation, three of the Company’s indirect wholly-owned subsidiaries incorporated and operating exclusively in China, may have improperly provided gifts and entertainment to government officials (the “China Investigation”). Based upon the initial investigation, which is ongoing, the preliminary estimate of the amounts of such gifts and entertainment does not appear to be material to the Company’s financial statements. There can be no assurance, however, that after further inquiry the actual amounts will not be in excess of what is currently estimated. Such estimate does not take into account the costs to the Company of the investigation or any other additional costs. The Company’s investigation includes determining whether there were any violations of laws, including the U.S. Foreign Corrupt Practices Act. Consequently, on March 29, 2012, the Company’s outside counsel contacted the DOJ and the Securities and Exchange Commission (the “SEC”) voluntarily to disclose that the Company was conducting an internal investigation, and agreed to cooperate fully and update the DOJ and SEC periodically on further developments. Since then, the Company’s counsel has done so, and the Company has continued to cooperate fully with the DOJ and the SEC. The Company has retained outside counsel and forensic accountants to assist in its investigation of this matter. Because the investigation is on-going, the Company cannot predict at this time whether any regulatory action may be taken or any other adverse consequences may result from this matter.

Title                          SL Industries Inc. – 5/10/2012

Document URL     investigations_disclosure/memofile3 [pdf embedded]

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