What are the conditions for leniency protection for the applicants directors, officers, and employees?
If a corporation qualifies for Type A leniency, all directors, officers, and employees of the corporation who admit their involvement in the criminal antitrust violation as part of the corporate confession will also receive leniency if they admit their wrongdoing with candor and completeness and continue to assist the Division throughout the investigation. In addition, the applicant’s directors, officers, and employees who did not participate in the conspiracy but who had knowledge of the conspiracy and cooperate with the Division are also covered by the conditional leniency letter, as detailed below. If their corporation qualifies for Type B leniency, the Corporate Leniency Policy states that individuals who come forward with the corporation will still be considered for immunity from criminal prosecution on the same basis as if they had approached the Division individually. In practice, however, the Division ordinarily provides leniency to all qualifying current employees of Type B ap
Related Questions
- Can an applicants former directors, officers, and employees be included in the scope of the conditional leniency letter?
- When can an applicant or its employees judicially challenge a Division decision to revoke conditional leniency?
- Has LightPaths Board of Directors adopted the required codes of conduct for employees, officers and directors?
