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Pharmaceuticals /Medical Devices /Health
Barcelona, Spain
Nationality of Foreign Officials: Italy
Summary of Allegations:
In its Form 6-K filed with the U.S. Securities and Exchange Commission ("SEC") on 6 May 2014, Grifols disclosed that U.S. Foreign Corrupt Practices Act ("FCPA") investigation by the U.S. Department of Justice ("DOJ") has been opened in Italy, in relation with the criminal prosecutions in Naples against five Grifols employees, including the former General Manager.
Approximate Alleged Payments to Foreign Officials: Unspecified
Business Advantage Allegedly Obtained: Unspecified
Nationality of Foreign Officials: Unspecified
Summary of Allegations:
In July 2009, the Talecris Group voluntarily contacted the DOJ to inform them of an internal investigation that Talecris was carrying out regarding possible violation of the FCPA in sales to central and East European countries. Actions at issue by Talecris took place while it was part of the Bayer Group, prior to the acquisition of Talecris by Grifols.
Approximate Alleged Payments to Foreign Officials: Unspecified
Business Advantage Allegedly Obtained: Unspecified
Agencies: Internal Investigation
Results:
Year Resolved:
Compliance Monitor:
Ongoing: Yes
Details:
In July 2009, Talecris voluntarily contacted the DOJ to inform them of an internal investigation that Talecris was carrying out regarding possible breaches of the FCPA in sales to certain central and East European countries.
In its Form 6-K filed with the SEC on 6 May 2014, Grifols disclosed that the company continues to carry out an internal investigation, started prior to the acquisition of Talecris, through an external legal advisor. Grifols' internal investigation has been focused on sales to Belarus and Russia, and trading practices in Brazil, China, Georgia, Iran and Turkey are also being investigated.
Agencies: Italy: Unspecified
Results:
Year Resolved:
Compliance Monitor:
Ongoing: Yes
Details:
The company further announced that an investigation was opened in Italy, in relation with the bribery-related criminal prosecution in Naples against five Grifols employees, including the former General Manager.
Agencies: United States: Department of Justice
Results: No Action
Year Resolved: 2012
Compliance Monitor: N/A
Ongoing: No
Details:
In July 2009, the Talecris Group voluntarily contacted the DOJ to inform them of an internal investigation that Talecris was carrying out regarding possible violation of the FCPA in sales to central and East European countries. Actions at issue by Talecris took place while it was part of the Bayer Group, prior to the acquisition of Talecris by Grifols.
Since July 2011, Grifols has cooperated fully the DOJ's investigation, including reporting all internal findings in relation to the violation of the FCPA.
In their Form 6-K filed with the SEC on 30 November 2012, Grifols disclosed that the DOJ notified Grifols that the proceedings would be closed, without prejudice to the fact that they could be re-opened in the future should new information arise. In the declination, the DOJ noted that their decision was based on significant cooperation by Grifols, including taking immediate steps to secure valuable informaiton and early disclosure of information to the DOJ, thanks to Grifols' compliance Program, internal audit functions concerning bribery and related misconduct, and the continuing improvements in the global anti-corruption compliance procedures.
Agencies: United States: Department of Justice
Results: No Action
Year Resolved: 2016
Compliance Monitor: N/A
Ongoing: No
Details:
In its Form 6-K filed with the SEC on 6 May 2014, Grifols disclosed that FCPA investigation by the DOJ has been opened in Italy, in relation with the criminal prosecutions in Naples against five Grifols employees, including the former General Manager.
On 29 September 2016, the DOJ notified Grifols that the DOJ has closed its inquiry into the company concerning possible violations of the FCPA and noted Grifols' full cooperation with the DOJ's investigation.
Discovery Method: Voluntary Disclosure
Details:
In July 2009, the Talecris Group voluntarily contacted the DOJ to inform them of an internal investigation that the Group was carrying out regarding possible breaches of the FCPA prior to Grifols' acquisition of Talecris.
Country: