Employees of Chinese design institutes, which are typically state-owned.
Rockwell is a global company that designs and manufactures industrial automation products and services. From 2003-2006, high-ranking employees of Rockwell 's then-wholly-owned subsidiary, Rockwell Automation Power Systems (Shanghai) Ltd. ("RAPS-China"), allegedly paid over $1 million to obtain business from state-owned enterprises. RAPS-China produced industrial power transmission products, motors and drives. Its employees allegedly used third-party intermediaries to pay funds to largely state-owned design institutes, intending $615,000 to go directly to employees and $450,000 to fund sightseeing and other non-business trips. For example, RAPS-China allegedly arranged leisure travel unrelated to business and hosted design meetings in New York City simply because "everyone likes New York."
Rockwell self-reported the payments after discovering them in 2006 through its normal financial review process.
Books and records (Issuer), Internal controls (Issuer)
Cease and Desist, Civil penalty, Civil Settlement, Disgorgement
Disgorgement of $1,771,000, prejudgment interest of $590,091, plus a civil penalty of $400,000.