Tagged: expense report

Deere’s Bribery Schemes — Circumventing Expense Controls (Part II of II)

Deere’s Bribery Schemes — Circumventing Expense Controls (Part II of II)

The Deere case is an important reminder for companies to devote proper attention to ensuring robust integration planning for acquired companies.  DOJ has provided important guidance on acquisition practices and the need to integrate acquired companies into the acquiring company’s ethics and compliance program and internal controls.  Deere made little effort to integrate Wirtgen into its ethics and compliance program and control environment.  As a...