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Consumer Products / Retail
Richardson, Texas, United States
Nationality of Foreign Officials: Poland
Summary of Allegations:
The internal investigation into Lennox's Russian subsidiary expanded to Poland as the company's operations in both countries used the same third-party logistics provider.
Approximate Alleged Payments to Foreign Officials: Unspecified
Business Advantage Allegedly Obtained: Unspecified
Nationality of Foreign Officials: Russian Federation
Summary of Allegations:
The Russian subsidiary of Lennox International, Inc. ("Lennox") allegedly made payment in the amount of 30,000 rubles (approximately USD 475) to a Russian customs broker or official. The alleged payment was allegedly made to release a shipment of goods being held by Russian customs officials due to inaccurate paperwork. The value of the shipment was approximately €62,000 (approximately USD 68,500).
Approximate Alleged Payments to Foreign Officials: 30,000 rubles (approximately USD 475)
Business Advantage Allegedly Obtained: release of shipment of goods held by Russian customs
Agencies: Internal Investigation
Results:
Year Resolved:
Compliance Monitor:
Ongoing: Yes
Details:
In its Form 10-Q filed with the U.S. Securities and Exchange Commission ("SEC") on 17 October 2016, Lennox disclosed that the company, under the oversight of its Audit Committee, has initiated an investigation into the allegations in Russia with the assistance of external legal counsel and external forensic accountants.
As of the filing date, 17 October 2016, the internal investigation has not resulted in any evidence of other potentially improper payments. However, the investigation has raised questions regarding possible irregularities with respect to other Russian customs documents.
The investigation expanded to include Polish operations.
Agencies: United States: Department of Justice, United States: Securities and Exchange Commission
Results:
Year Resolved:
Compliance Monitor:
Ongoing: Yes
Details:
In October 2016, Lennox self-reported the Russian allegations to the SEC and the DOJ.
In its Form 10-K filed on 21 February 2017, Lennox disclosed that its investigation had expanded to its Polish operations.
Lennox noted its intention to provide full cooperation with the SEC and the DOJ.
In its form 10-Q filed on 23 April 2018, the company disclosed that the DOJ declined to prosecute the matter.
Discovery Method: Voluntary Disclosure
Details:
In October 2016, Lennox self-reported the allegations in Russia to the SEC and the DOJ.
Country: Russian Federation