This week we are pleased to have a guest post from Edward Heath and Dan Brody. Attorneys Heath and Brody are members of Robinson+Cole’s Government Enforcement and White-Collar Defense Team.

McDonald’s Corporation, a Fortune 500 company and one of the world’s largest fast-food chains, was recently reminded of the value of two basic internal controls: maintaining an anonymous reporting system and conducting an internal investigation based upon information received through that system. Those two measures, which can be adopted by any manufacturing company of any size, may have saved the Golden Arches over $40 million.

Last November, McDonald’s terminated its CEO, Stephen Easterbrook, for having a consensual relationship with an employee, deeming it conduct that demonstrated poor judgment. During the termination process, Easterbrook informed the company’s Board that the relationship had been the only one of its kind. Based on that representation, McDonald’s agreed to pay Easterbrook a severance package valued at about $42 million.
Continue Reading Internal Investigation Leads to Potential $40 Million Clawback Effort

Thank you to my colleague Jim Ray for his contributions to this post. Jim is a partner in our Environmental & Energy Practice Group.

We have all been involved in investigating and remediating sites with soil and groundwater contamination. But another form of contamination has been recently gaining attention—vapor intrusion.

Vapor intrusion is the migration