Problem
Borges, Inc., a Delaware company, owns copper mines around the world. Between 2007 and 2019, the company engaged in systematic violations of the Foreign Corrupt Practices Act, the Sarbanes-Oxley Act, and numerous environmental and mine safety laws both in the United States and abroad. In June 2019, a whistleblower from the mining department contacted the New York Times, which published a story exposing the environmental and mine safety violations. The board of directors of Borges, Inc. has just hired you as an outside consultant to help them navigate through this mess. They admire the way that Siemens ultimately handled its compliance failures problems (see the readings for this Module). Answer the following questions, making reference, of course, to what you learned about Siemens:
• What should the Borges, Inc. do vis-à-vis the violations that have not yet come to light?
• What should it do to help preserve its reputation?
• What should it do in order to minimize its exposure to criminal and civil sanctions?