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Grainger Investigation Over, No Big Discoveries

Industrial supplier WW Grainger Inc said last week that its internal investigation didn’t substantiate ‘significant use of gift cards for improper purposes in China.’

in March, Illinois-based Grainger said gift-giving practices by employees in China triggered an FCPA investigation. It said then it had launched an internal investigation.

On Thursday last week, Grainger said in an SEC filing that it has completed the investigation and reported the results to the DOJ and SEC.

The company said the investigation ‘did not substantiate initial information suggesting significant use of gift cards for improper purposes.’

Grainger said it can’t predict whether the DOJ or SEC will take any enforcement action against it.

*     *     *

Grainger’s full FCPA disclosure in its July 26 10-Q said:

As previously reported, the Company has been conducting an inquiry into alleged falsification of expense reimbursement forms submitted by employees in n certain sales offices of Grainger China LLC, a subsidiary of the Company. In the course of the investigation the Company learned that sales employees may have provided prepaid gift cards to certain customers. The Company’s investigation included determining whether there were any violations of laws, including the U.S. Foreign Corrupt Practices Act. The Company retained outside counsel to assist in its investigation of this matter. On January 24, 2012, the Company contacted the U.S. Department of Justice and the Securities and Exchange Commission (SEC) to voluntarily disclose that the Company was conducting an internal investigation, and agreed to fully cooperate and update the DOJ and SEC periodically on further developments. The results of the investigation, which have been submitted to the DOJ and the SEC, did not substantiate initial information suggesting significant use of gift cards for improper purposes. The Company cannot predict at this time whether any regulatory action may be taken or any other potential consequences may result from this matter.


Research courtesy of ethiXbase, the world’s largest database of anti-corruption legislation, gift-giving regulations, investigations, and enforcement actions.


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