What do you do when a lower-level employee breaks the law? Well, you could ignore them, reprimand them, or fire them. When it’s a higher-level executive, do the same rules apply? What do the answers say about the company’s commitment to compliance with all applicable laws?
“Rio Tinto Fires Two Amid Payment Probe,” The Wall Street Journal, November 17, 2016 B4. The chief executive of a large section of the company, together with the top legal officer of the company, were fired following discovery of emails tying a payment of $10.5 million to a consultant with the award of a large project.
As the Yates memo (and the Federal Sentencing Guidelines Manual) might have said, it’s a start. Firing the General Counsel (actually, the head of the company’s legal and regulatory affairs function) is a twist.