The controller for Asis Electronics, a subsidiary of a European-based corporation, was concerned that Asis might have overcharged the U.S. Ministry of Defense in a contract for transmitters. However, Asis’s chief financial officer did not address the matter when he learned of it. After being asked to sign an annual compliance document related to anti-corruption practices, the controller needed to decide whether or not to report the irregularities through established “protected communications channels” that ensured confidentiality.
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