J&F Investimentos: Brazilian Officials are Bribed for Business Gain (2005-2017)

1. Abstract

J&F Investimentos spent $148 million in payments to Brazilian Officials between 2005 and 2017. These payments were made in exchange for access to business funds to increase the market share of J&F. These actions are unethical according to the ethical theories. According to individualism the bribes that took place are unethical. Profits were not maximized, since large amounts of money were paid out to the Brazilian government officials. Under Utilitarianism these actions are unethical since the unhappiness of the Brazilian people, government and the United States government outweighs the happiness of the individual government officials that benefited and the happiness of J&F. These actions are also unethical under Kantianism. The Brazilian officials were treated as a means and not as an ends. Lastly, J&F’s actions showed that they lacked the four main virtues of virtue theory, which are courage, temperance, honesty and justice. In order to prevent these actions from occurring again J&F should establish an ethics program that every employee should have to complete. J&F should also establish an internal review board that reports to the investors to make sure employees are compliant with the ethical program. 

2. Ethics Case Controversy

Timeline of events outlining J&F Investimentos actions.

      J&F Investimentos is an investment company that invests in many industries. These investments are mainly the agriculture and meat industry (J&F Investimentos S.A. Pleads Guilty). They are currently the leading beef and pork processor in the United States. J&F has more than 300 production units and serve, through exports, over 150 countries. The company’s mission is ‘to be the best in all that we do, providing superior products and service to our customers and the opportunity of a better future to all of our team members” (JBS Making Your World Stronger). J&F is part of the Pilgrim’s Pride Corporation which owns many chicken production brands. 

      Between the years of 2005 and 2017, J&F’s employees “paid millions of dollars in bribes to, and for the benefit of, Brazilian government and officials in order to obtain financing from two Brazilian state-owned and state-controlled banks…” (J&F Investimentos SA Pleads Guilty). These actions directly violate the Foreign Corrupt Practices Act or FCPA, which makes it illegal to bribe government officials in order to further business practices. This law was amended to apply to any foreign body who conducts a corrupt payment within any United States territory (FOREIGN CORRUPT PRACTICES ACT). J&F used banks in the American banking system in order to carry out these payments. One specific example occurred between 2005 and 2014. J&F made $148 million in payments to Brazilian government officials. These officials included the highest-ranking member of the Banco Nacional de Desenvolvimento Econômico e Social, which is a bank controlled by the Brazilian government. In return for the money, J&F receives millions of dollars in financing. J&F also paid $25 million to a high-ranking official in the legislative body which allowed them to receive financing from Cixa Econômica Federal, which is a Brazilian government controlled bank (J&F Investimentos S.A. Pleads Guilty). These acts do not directly violate the Federal Corrupt Practices Act but the way J&F went about the bribery does. In order to facilitate some of these bribes, bank accounts opened at New York banks were used to make these payments to officials. Meetings also took place in New York and other locations in the United States. Lastly, an apartment in Manhattan, located in New York City, was purchased as a bribe (J&F Investimentos S.A. Pleads Guilty). 

Joesley Batista at a press conference prior to the J&F Investimentos bribery scandal going public.

3. Stakeholders

There are many stakeholders in this case. J&F itself is a stakeholder. Through their actions their revenues and eventually profits are being used to bribe officials. At the same time, their business is losing money through these actions. The J&F employees are also stakeholders. The company, depending on profits and losses, may decide to layoff individuals or not reward bonuses, which hurts the employee and their dependents. 

J&F is managed by the Batista family. The CEO is an appointed member of the family who inherits the responsibility for the company. The Batistas are stakeholders in this situation. They are ultimately held responsible for the actions the company takes. They are also one of the main profiteers from the company who pull large salaries. The Batista brothers, Joesley and Wesley, have been charged $550,000 each from the Securities and Exchange Commission in the United States for charges of bribery. They have also been arrested in Brazil and a trial or settlement is pending. In the meantime, Wesley Batista Jr. is the acting CEO. 

The United States government and the Brazilian government are both stakeholders in this situation. First, the United States is where most of the bribery was taking place. The bribery was facilitated by using United States banks with American dollars to pay the officials. The United States government’s law was violated. The Foreign Corrupt Practice Act outlaws these kinds of bribes. In this situation, the United States government’s relationship with other countries could be hindered. If a bribe did not succeed and the United States government looks like it has not done anything to stop it, political tensions could arise. This could lead to a conflict between the two governments and ultimately the countries. This is not ideal for anyone involved. With that said, the Brazilian government is also a stakeholder. Here, many officials have accepted bribes from J&F which decreases the integrity of the government. Brazilians cannot trust their government if they know that the officials are accepting bribes from companies. They cannot trust that the government officials are working for the people and not their own wallets. The government officials who were not accepting bribes are also affected. These people now have to spend time on training and developing new systems to combat bribery. These individuals have also not received the same benefits of the job as the people who accepted bribes. The people who have accepted bribes have received more funds and other benefits than that of the others in the same position.

      Within the Brazilian government specific organizations have been affected by this situation. The first is the Brazilian Development Bank or BNDES. BNDES is a public company that works with the Ministry of Development, Industry and Foreign Trade to finance development projects in Brazil (UNEP Finance Initiative). On their website, they state that “BNDES is an important partner for investors to be able to understand and access opportunities offered by the Brazilian economy” (BNDES: The Brazilian development bank). BNDES is the main organization, whose money and approval is needed in Brazil in order to gain access to funds and other necessary means in order for businesses to expand. This is why J&F bribed one of the high-ranking officials. BNDES has now been seen as less trustworthy to the public with the funds they have used. 

4. Individualism

Individualism is an ethical theory that was developed by Milton Friedman. Friedman essentially argues that actions are ethical as long as they maximize the profits for the business. A businessperson has no other responsibility but to maximize the profit for the stockholders as long as all laws are obeyed. According to Desjardins individualism focuses on only pursuing the highest profits as possible. “Pursuing any social objective other than the maximization of profit is spending someone else’s money for your own purposes… this is ethically equivalent to theft” (Desjardins 55). Tibor Machan added on to this ideology and stated that a business’ goal is to maximize profits while following all laws but other goals can be prioritized over maximizing profits. He goes on to state that the goal of profiting can be met through meeting other goals that do not maximize profits.

J&F’s actions are unethical according to the theory of individualism. The main argument here is that J&F Investimentos broke the law. Their actions violated the Foreign Corrupt Practices Act which made their bribery that occurred in the United States illegal. Their goal was to increase profits by expanding their business, which is why they used their funds to bribe high ranking officials at BNDES. Their bribes did not end up giving them this desired result. The bribes caused J&F to have to pay $256,497,026 to the United State government. This decreased their profits for the period. Ultimately J&F’s actions do not satisfy the condition of maximizing profits for the company and doing so within the law. 

5. Utilitarianism

The utilitarian theory of business ethics looks to maximize happiness. This theory was developed by John Stuart Mill who argued that the only thing with value in and of itself is happiness. He argued that happiness should be maximized for anything that can feel it. This is different from egoism or altruism because it requires happiness to be maximized in not just yourself but in others as well. 

      In the J&F ethical issue, J&F’s actions were not ethical because the happiness these bribes created did not outweigh the unhappiness. The only people whose happiness increased because of the bribes are the Brazilian government officials and J&F Investimentos. These officials received money and other incentives in order to act in accordance to how J&F pleased. This made the officials happy. J&F also increased their happiness through their actions. Through the bribes they received access to many different business resources, like money, to be able to expand their business and ultimately their profit. The stockholders were happy that their profits were increasing. On the other hand, more individuals suffered because of J&F’s actions. People who work for J&F were seeing funds be used to pay government officials instead of bonuses or raises. This made these people unhappy. The people of Brazil are also unhappy. They can no longer trust their government to act in a way that puts the people first. The Brazilian people know that their officials can be bought and sold for money or apartments in the United States. They are unhappy because their government does not act for them and instead acts for the officials themselves. The United States government is also unhappier due to J&F’s decision. The United States’ law was broken, and J&F got away with it for many years. The government also cannot trust businesses to follow the laws that they have put into place to protect their international relations. The actions taken by J&F can cause anti-American viewpoints to spring up in parts of Brazil, which increases tensions between the two countries. These tensions could potentially lead to conflict. As the unhappiness of the Brazilian people and the United States government outweighs the happiness of the J&F stockholders and the people that received the bribes. 

6. Kantianism

Kantianism was developed by Immanuel Kant who argued that one should act in a way that is right because it is right. The action must be rational and the reason for the action must be right. This is the principle behind Good Will. In order to decide if an action is ethical under Kant’s theory the Formula of Humanity is used. This formula states humanity must be treated “as an end and never as a means”. In this statement humanity is one’s rationality. In essence, your rationality and the rationality of other must be treated as if it has value in itself. The rationality is not just a way to get something else from others. 

Using Kantianism J&F’s actions are not ethical. In order to test this theory, a maxim must be formed. A maxim in this situation would be; I will bribe government officials in order to get them to give me funds and other resources that I want in order to expand my business”. This does not respect the rationality of another person. The government officials in this situation are being treated as an ends and not a means. J&F is using the position of power that the officials have in the Brazilian government to receive funding and other resources. J&F is using the Brazilian officials to get to the actual ends that they want which is the funding for their business. Therefore, the actions taken by J&F are unethical due to the lack of respect the bribes have for the rationality of the Brazilian officials. 

7. Virtue Theory

Virtue theory requires that actions are motivated by the right virtues. There are four cardinal virtues; courage, temperance, honesty and justice. Courage is the idea that one will take risks and stand up for the right actions and ideas. Honesty is the idea that one should give all the facts and be honest in all aspects of business. Temperance is self- control. In this regard, self- control refers to the ability to control desires and expectations. The last cardinal virtue is justice. Justice refers to fair business practices and making quality goods for the consumer.

J&F’s actions in the bribery scandal does not meet these virtues. First, their actions are not honest. J&F hid their actions from the public as well as the United States government for years until they were investigated, and their actions were brought to life. Second, they did not exhibit self-control. In this regard the company should have been able to control their desire for profits, and act in accordance with the law. Their actions did not do this, which makes them not virtuous. Third, J&F lacked courage. They did not stand up for what is right, and instead did the exact opposite by breaking a law. Lastly, they lacked Justice. The actions of J&F were not fair business practices. They received an advantage over other companies in the industry due to the bribes that they were giving to the Brazilian officials. Since J&F’s actions failed to meet the four cardinal virtues their actions are unethical.

8. Justicatied Ethics Evaluation

In my view the actions taken by J&F were impermissible. In this case, the bribes given by J&F were illegal in the United States. The United States would not have been involved, and the actions would not have been illegal if the company did not use American banks to make these transactions. The United States had seen bribes like this occur in the past, which is why the Foreign Corrupt Practices Act was passed into law. This act clearly states that any foreign entity that conducts a corrupt business act in the United States is conducting an illegal act. J&F did just that, which makes this impermissible. One could bring up the argument that the J&F was spending their own money in a way that the company saw fit, but this still makes their actions unethical. Yes, the funds that were used were funds that J&F Investimentos had made and retained in their business operations. Even though it was their funds, bribing officials for economic gain is unethical. In this situation deceit was involved. J&F Investimentos did not publicize the fact that they were conducting these fraudulent acts. If the company is not proud of their actions, then they should not be conducting them. Not only were the actions of J&F Investimentos employees who conducted these bribes unethical, but also the actions conducted by the Batista family were unethical. The brothers never completed any ethical training. They should have known that their actions were at the very least illegal. The brothers should have sought out ethical training when first put into the role of the CEO. In this training they probably would have realized that their company lacked an ethical code of conduct and would have worked to create one. If the employees and the brothers had strict guidelines to follow they most likely would not have found themselves in their current situation. 

9. Company Action Plan

J&F has multiple ways that they can change their inner workings in order to be compliant with ethical standards. First, J&F CEOs and employees should go through ethical training. This training should occur at every level of the business so that every employee knows what is ethically right and what is wrong. This way there is no excuse, and all employees understand the rules and regulations. The CEOs and managers should go through additional training. This way they can understand what regulations they must follow that is different than the rules of the general employees. The CEOs should also report compliance to ethical standards to the stockholders so that the company and its investors are aware of the actions the company is taking. 

Second, J&F should establish an internal investigation division. These employees would be separate from human resources and will be able to investigate all transactions or any internal complaints of compliance issues. These employees should have access to the accounting books and should be able to interview employees. Through this divisions J&F Investimentos should be able to internally control whether or not employees are following the ethics regulations. This division should also be able to report their finding to the investors. This way the information is not being blocked by an individual that is higher up in the business. The CEO would have to let the employees report their findings. This divsion should be headed by individuals that cannot be fired by the CEO, instead they can only be fired by a vote from the investors.

The last step J&F should take in order to move past the ethical issue is through public relations work. As a food exporter J&F could donate food to people in Brazil. By doing this J&F is changing the public perception of their business. People in Brazil have seen J&F Investimentos take steps that have undermined their government. Through donations and interacting with the people of Brazil, J&F will be able to change this perception.

Some of the meat J&F could donate to the people of Brazil to improve public opinion.

Through these two actions the company can still remain profitable. J&F will only be losing out on money spent to develop the ethics program, the money spent to establish an independent division within the business and any donations. This will not result in a huge hit to the profits of J&F. J&F can decide how much they would like to donate and how they would like to interact with the people of Brazil. With this amount of freedom their company can decide to limit how much they do donate so their profits are not hit too hard.

Works Cited

BNDES: The Brazilian development bank. https://www.bndes.gov.br/SiteBNDES/bndes/bndes_en/Institucional/The_BNDES/. Accessed 28 Nov. 2020

Desjardins, Joseph. An Introduction to Business Ethics, Fifth Edition. McGraw Hill- Companies, 2014. 

“BNamericas - Executives of Brazil's J&F Investimentos arrested” BNamericas.com, www.bnamericas.com/en/news/executives-of-brazils-j-f-investimentos-arrested. 

FOREIGN CORRUPT PRACTICES ACT. The United States Department of Justice, 3 Feb. 2017,                                      https://www.justice.gov/criminal-fraud/foreign-corrupt-practices-act. Accessed 13 Nov. 2020.

JBS Making Your World Stronger. JBS, 2020, https://jbssa.com/about/. Accessed 13 Nov. 2020.

J&F Investimentos S.A. Pleads Guilty and Agrees to Pay Over $256 Million to Resolve Criminal Foreign Bribery Case. The          United States Department of Justice, 14 Oct. 2020, https://www.justice.gov/opa/pr/jf-investimentos-sa-pleads-guilty-and-agreespay-over256- million-resolve-criminal-foreign. Accessed 13 Nov. 2020.

“J&F to nominate Wesley Batista Jr. as next JBS CEO”. Reuters, https://www.reuters.com/article/jbs-executive/jf-to-nominate-wesley-batista-jr-asnextjbs-ceo-newspaper-idUSL5N1LY0L4. Accessed 13 Nov. 2020. 

Sun, Mengqi. “J&F’s Bribery Settlements Highlight Compliance Breakdowns, Remediation Efforts”. The Wall Street Journal, https://www.wsj.com/articles/j-fsbribery-settlements-highlight-compliance-breakdowns-remediation-efforts11602840600. Accessed 13 Nov. 2020.

UNEP Finance Initiative. “Banco Nacional De Desenvolvimento Economico E Social” UNEP, United Nations Environment Programme – Finance Initiative, 2020, https://www.unepfi.org/member/banco-nacional-de-desenvolvimento-economico-e social-bndes/. Accessed 28 Nov. 2020.

Purdue Pharma Pleads Guilty to Federal Criminal Charges Regarding OxyContin (2020)

    For the past few decades, The United States of America has been plagued with an opioid epidemic. Purdue Pharma, the makers of OxyContin, have been known to be greatly contributing to this epidemic, if not causing it entirely. Recently, the company has been charged with several criminal charges, as well as made to pay billions of dollars in fines. As a part of the settlement that was reached, the Sackler family, who has owned the company since the 1950’s, will lose ownership of Purdue Pharma, as it is turned into a public benefit company. 

     All ethical theories would find several issues with the actions of Purdue Pharma. From an individualistic perspective, their actions were those of a typical business trying to maximize profit, however several violations of the law make their actions impermissible.  A utilitarian would also see several issues with this situation, as the biggest concern of utilitarianism is maximizing happiness for all. As will be outlined in this paper, not a single individual in this situation ended up with what one would consider to be happiness. From a Kantian perspective, several actions of Purdue Pharma are considered impermissible, particularly using people as a means to some end goal, as well as practicing manipulation of consumers. Finally, virtue theorist would find concern in the fact that almost all no virtuous traits were carried out by Purdue Pharma, but rather they practiced vices such as greed, dishonestly, and manipulation. 

    Although Purdue Pharma made several unethical mistakes in the marketing and distribution of OxyContin, there are things that can and should be done to fix this problem. By taking responsibility and showing that they have a desire to help those that they harmed, Purdue Pharma has the potential to improve their public image and regain the trust of Americans. 

Ethics Case Controversy 

 

Purdue Pharma's OxyContin, the meditation that has 
caused millions of deaths and led to the downfall
of the company. 

    Throughout the past couple of decades, the opioid crisis has become characteristic of the United States of America, and Purdue Pharma is being held responsible for creating it. The company has had to admit to “enabling the supply of drugs without legitimate medical purpose” (BBC), meaning that their only concern was selling their medication with no regard to whether it was done properly and safely or not. Recently, Purdue Pharma has been undergoing a federal investigation on the basis of lack of care involved in distributing OxyContin.  This has led to an $8.3 billion settlement to be reached. The settlement emphasizes that “for more than two decades, there has been a widespread problem of overprescribing, diverting, and abusing pain medication in America, while drug manufactures such as Purdue profited from this issue and failed to take responsibility or action” (Rowland). As part of this settlement, the Sackler Family, which has owned Purdue Pharma since the 1950’s, will not only lose ownership of their company, but will admit to “three felony counts for defrauding the federal government by misleading regulators about its efforts to restrict overprescribing of the drug and to violating anti-kickback laws by paying doctors to write more OxyContin prescriptions” (Williams).  A prime example of their wrongdoing was in 2012, when “members of the Sackler family demanded that company executives come up with a plan to generate greater revenue in response to slumping sales. A new marketing plan, called ‘Evolve to Excellence’ was created. This plan involved more intensified marketing of OxyContin to extreme, high-volume prescribers who were already writing ‘25 times as many OxyContin scripts’ as their peers.” (Rowland). While the company agreed to pay huge fines because of this as well as admit criminal liability, the family that owns the company, as well as executives within the company, claim that they "acted ethically and lawfully, and the upcoming release of company documents will prove that fact in detail” (Rowland). 

    This investigation has been ongoing for a substantial amount of time, however a settlement was just now reached due to the presidential election, but some are saying that it was far too rushed, and feel as if Purdue Pharma should have suffered more consequences for their actions. The Justice Department was pushed to settle a large number of outstanding cases involving major corporations, as “Administrations often seek to resolve significant cases as they near the possible end of their time in office, and with Election Day drawing near, the Trump administration has pushed to finalize a number of such matters this month” (Rowland). Massachusetts attorney Maura Healy stated that she believes that the Justice Department has failed, because “justice, in this case, requires exposing the truth and holding the perpetrators accountable, not rushing a settlement to beat an election” (Rowland). 

 

    The substantial amount of money that will be paid in this settlement will be used to redress past wrongdoings, as well as provide new resources for treatment and care of those impacted by OxyContin. Furthermore, Purdue Pharma will be turned into a Public Benefit Company, “meaning it will be governed by a trust that has to balance the trust’s interests against those of the American public and public health” (Balsamo). This comes as a relief to many, as the Sackler family has evidently caused an abundance of problems for the American public, and thus, they will no longer have control of their company. 

Timeline of Events 

 

Stakeholders

    There are countless stakeholders in this situation, including people who currently suffer or have previously suffered from addiction to OxyContin, the family and friends of people facing this addiction, the Sackler family, and the American population in general. People who have faced addiction to OxyContin largely have Purdue Pharma to blame, because if the medication was marketed and distributed properly, it’s likely that they would not have had a problem with it at all. Brooke Feldman, who is in recovery from opioid use disorder, stated that she “is glad to see Purdue admit wrongdoing. She said the company has acted for years as a ‘drug cartel’” (Balsamo). Many people who have faced addiction have lost a lot from this situation, including their jobs, relationships with family and friends, and some even losing their lives, which makes them one of the primary stakeholders in this situation. 

Protesters stage a "die-in" inside Harvard's
Arthur M. Sackler Museum to protest the Sackler's
involvement in the opioid crisis.

    Furthermore, families who are impacted by a member suffering abuse of the drug are also stakeholders, as many have lost someone they love due to the company’s wrongdoings. Ed Bisch, “who lost his 18-year-old son to an overdose nearly 20 years ago, said he wants to see people associated from Purdue prosecuted and was glad that the Sackler family wasn’t granted immunity” (Balsamo). Along with millions of others, Bisch blames the company and the family for the millions of deaths that have occurred, and has noted that “If it was sold for severe pain only from the beginning, none of this would have happened…but they got greedy” (Balsamo). 

    The Sackler family and other top executives are stakeholders because not only were they the decision makers in this case, but they also lost billions of dollars, as well as their company. Since they were the ones who chose to market their product aggressively, bribe medical professionals, and not take precautions to ensure the use of their product was safe and controlled, they ultimately made the decisions that made their company suffer. Because of that, and because they are also at a loss, they are considered stakeholders in this situation as well.

    Lastly, the American public are stakeholders in this situation as well. On top of having to be careful not to abuse OxyContin if they get prescribed it, Americans also have to watch people that they know and care about suffer from addiction. Many people, even if they are in severe pain, do not even want to get OxyContin prescribed to them because of how addictive it is. Since many have to live in fear, as well as watch many Americans suffer from OxyContin addiction, the general American public can be considered stakeholders in this situation as well. 

 

Individualism

    From an Individualistic perspective, there is wrongdoing involved with Purdue Pharma’s actions in the marketing and lack of responsibility in distributing OxyContin. Individualism, the theory created by Milton Friedman, emphasizes that “business actions should maximize profits for the owners of a business, but do so within the law” (Salazar 17). The aggressive marketing of OxyContin would not be seen as unethical from an Individualistic point of view, but rather beneficial to the company. The problem, however, is that Purdue Pharma used unlawful tactics in order to market their product. Purdue admitted to not only “violating federal anti-kickback laws by paying doctors to induce them to write more prescriptions, but also that it “impeded the Drug Enforcement Administration by falsely representing that it had maintained an effective program to avoid drug diversion and by reporting misleading information to the agency to boost the company’s manufacturing quotas” (Balsamo). Because they have violated several laws in order to make profit, this is not permissible under individualism. 

 

    Aside from the illegal aspect, the goal of their marketing was simply to maximize profit, which is the overall goal of Individualism. Since this theory is more so about the business and business owners rather than the consumers, there is nothing wrong with causing millions of addictions and deaths, according to Individualism. As long as the business is actively trying to maximize their profit, and doing so within the law, it is seen as permissible. 

 

    Although “Friedman held that it is the aim and the responsibility of businesses to maximize their

profits” (Salazar 18), Purdue Pharma was still in the wrong from an Individualistic point of view. Although consumers were undoubtedly harmed, that does not matter in and Individualistic sense, unless the law is broken. Since the marketing was not done within the law, however, this is not permissible under Individualism. 

Utilitarianism

    

    Utilitarianism emphasizes ‘maximizing the overall good’ or, in a slightly different version, of producing ‘the greatest good for the greatest number’. Acts that accomplish this aim are good; those that do not are bad” (Desjardins 29). This essentially means that the main goal is to maximize the happiness of everybody involved. 

    When Purdue Pharma was first beginning to sell OxyContin, their actions may have been seen as permissible under Utilitarianism. The Sackler family, as well as top executives in the company, were profiting off of selling this drug, which evidently causes happiness for them. Doctors were under the impression that the timed-release formula was meant to decrease the likelihood of addiction, so having a drug that reduced pain, while also having non-addictive properties, was seen as a great thing in the medical industry. Consumers, who had been dealing with severe pain before, were given a medication that worked well for reducing pain, which in turn made them happy. 

 

    Later on, however, almost everyone was hurt by this situation, meaning that it was shown to be unethical by Utilitarians. Consumers began facing addiction or even death due to OxyContin, meaning that family members were losing loved ones because of this drug. People who suffered from addiction were clearly not happy, and the risk of losing one’s life did not cause happiness either. Purdue Pharma was faced with incredibly large fines, as well as having to give up their business, meaning that he happiness from making profit did not last, and they ended up becoming unhappy as well. Since “business actions should aim to maximize the happiness in the long run for all conscious beings that are affected by the business action” (Salazar 17), and nobody remained happy in the long run, it becomes evident that the actions of Purdue Pharma were not permissible under Utilitarianism. Since almost everyone suffered in the long run and nobody came out of this situation with happiness, it can be seen that these actions are not beneficial to any of the stakeholders. This emphasizes that ultimately, the actions of Purdue Pharma were unethical by a Utilitarian point of view. 

 

Kantianism

    According the The Case Manual, the ethical rule of Kantianism is to “always act in ways that respect and honor individuals and their choices. Don’t lie, cheat, manipulate or harm others to get your way. Rather, use informed and rational consent from all parties” (Salazar 17). Furthermore, according to Kant, “…ethics requires us to treat all people as ends and never only as means.” (Desjardins 38).  Purdue Pharma undoubtedly violated this, as they were using consumers as a means to the end goal of profit. The company did not care that people were becoming addicted to this medication at astounding rates, leading to millions of deaths across America, but rather they used this to their advantage, enabling them to sell more drugs and in turn, make more profit. 

    Although this situation is seen as ethically wrong in both Utilitarianism and Kantianism, it is wrong for different reasons. One of the key differences in the ethical theories is that “Utilitarianism is concerned only with consequences of an action and Kantianism does not make decisions based on consequences, but rather on what Kant calls the ‘Good Will.’” (Salazar 21). This essentially means that just because an action can produce good results, the action cannot be done based on only the outcome. Having Good Will, in this case, means that “…people

have good intentions and use good reasoning to come to conclusions that will 

make their good intentions effective” (Salazar 21). In the case of Purdue Pharma, it becomes clear that their intentions were only good for themselves, and not the consumers. They knowingly harmed millions of people in order to increase revenue, which ultimately benefitted only the Sackler family and top executives at the company. 

 

    One of the most concerning violations of Kantianism is one of the most important aspects of the theory, which emphasizes that the “fundamental ethical duty is to treat people with respect, to treat them as equally capable of living an autonomous life” (Desjardins 38). By continuing to aggressively market a drug that was known to be extremely addictive, Purdue Pharma was taking away people’s autonomy. Causing people to become dependent on a drug is one of the most clear-cut ways to manipulate people, as well as take away their autonomy. Once consumers become addicted, they keep needing more, which means that Purdue Pharma was making more and more profit off of people’s suffering. Because of this, it is evident that this case is extremely impermissible under Kantianism. 

 

Virtue Theory

    Similarly to Individualism, Utilitarianism, and Kantianism, the actions of Purdue Pharma would be seen as unethical by a virtue theorist. Virtue Theory, rather than focusing on individual actions, focuses on the character of individuals. The main objective of this theory is to “act so as to embody a variety of virtuous or good character traits and so as to avoid vicious or bad character traits” (Salazar 17), and it is evident that Purdue Pharma did not do that. 

 

    According to The Case Manual, “A few vices that have been severely detrimental to otherwise savvy and innovative business people are greed, dishonesty, and selfishness” (Salazar 23), and Purdue Pharma has demonstrated all of these. The company showed greed when they went to extreme measures to have their product become more popular. By convincing doctors to prescribe OxyContin more frequently, as well as going so far as to violate the law in order to make more profit, they have shown that they care more about profit than the health and wellbeing of consumers. Furthermore, dishonestly in this situation is rampant. On top of “defrauding the federal government by misleading regulators about its efforts to restrict overprescribing of the drug” (Williams), they have also lied about the dangers of the drug and its addictive properties, putting millions of people at risk. In terms of selfishness, Purdue has put gaining profit above the health of their consumers. They have expressed a selfish need for even more revenue than they already have, and rather than attempting to resolve the problem that they caused, they contributed to it even more. 

 

    Virtue theory values “Character Traits that Promote Wellness or Flourishing of Individuals within a Society.” (Salazar 22), and it is clear that Purdue Pharma does not promote wellness, but rather neglects it in an attempt to maximize profit. Because they marketed their product so aggressively and promoted the over-prescription of the drug, they were not promoting the flourishing of individuals within society, but rather the downfall. Because of all of the vices they have shown, as well as lack of virtuous characteristics, it is evident that a virtue theorist would view the actions committed by Purdue Pharma to be completely unethical. 

Justified Ethics Evaluation 

            In my opinion, Purdue Pharma’s actions were completely unethical. Not only did they harm millions and millions of people for the sole purpose of making profit, but they also did nothing to stop the epidemic that they created, but rather contributed to it even more. They were well aware that people had become extremely addicted to OxyContin, however, they continued to aggressively market the product, as well as bribe doctors to prescribe it abundantly. By implementing things such as “intensified marketing of OxyContin to extreme, high-volume prescribers who were already writing ’25 times as many OxyContin scripts’ as their peers.” (Rowland), Purdue Pharma put the health and safety of consumers at risk for the sole purpose of increased profit. Furthermore, they broke the law to do these things, by “defrauding the federal government by misleading regulators about its efforts to restrict overprescribing of the drug and to violating anti-kickback laws by paying doctors to write more OxyContin prescriptions” (Williams). Because of this, it is clear that Purdue Pharma made several ethical mistakes, which shows an abundance of negligence within the company. Not putting consumers first, but rather putting their lives at risk, is not ethical, and therefore Purdue Pharma acted completely unethical in this situation. 

 

Company Action Plan 

    It is evident that Purdue Pharma’s actions harmed millions of Americans. Because of this, there are several steps that must be involved in order to correct their wrongdoing. 

    First and foremost, the family and executives within the company need to accept their wrongdoing and admit to creating and contributing to the opioid epidemic. The family claims that they “acted ethically and lawfully, and the upcoming release of company documents will prove that fact in detail” (Rowland). This is evidently not true, and one of the first priorities when it comes to getting forgiveness from the general public is to admit that they did something wrong. Acknowledging their mistakes is the least that they can begin with doing. By doing this, they will show the American public, as well as those who have faced consequences from OxyContin, that they acknowledge their mistake and know that it was wrong of them.  

     As of now, Purdue is set to transform into a Public Benefit Company. One of the main purposes of this is “to ensure funding is devoted to advanced treatment programs” (Rowland), but also to ensure that the Sackler family will lose control of their company. Because of this, it will be impossible for the Sackler family to change the way they market and distribute OxyContin, since they will no longer have any part in it.

    One of the most important and potentially helpful things that the Sackler family can do to is donate money to families and communities that have been heavily impacted by the opioid crisis.  This is already a part of the settlement, since members of the Sackler family have already expressed a desire to “direct substantial funding to communities in need, rather than to years of legal proceedings…members of the Sackler family have expressed ‘deep compassion for people who suffer from opioid addiction and abuse and hope the proposal will be implemented as swiftly as possible to help address their critical needs’”(Williams). Despite the fact that this is already outlined in the settlement, it could be very beneficial for the Sackler family to donate some of their own personal money. This would not only improve the company’s public image, but it would show Americans that the family truly does care about how many people they have harmed, and are willing to give up part of the profit that they fought so hard for in order to help. 

    If the company wants to be able to remain profitable or be able to increase their profits, they would need to improve their public image and make sure that they are staying within the law. The Sackler family, however, will no longer have the ability to profit from the sale of OxyContin, since they no longer own the company. The Public Benefit company, however, must ensure that they are doing better than the Sackler’s in terms of marketing, distribution, and not violating the trust of the federal government and the American people. 

     Some of the values that need to be prioritized are trust, compassion, customer well-being, and honesty. Trust needs to be prioritized because it is one of the most important aspects of running a business. After the controversy, many Americans do not trust Purdue Pharma, and therefore the new company that will remain manufacturing OxyContin will need to regain this trust. The new company, as well as the Sackler family, needs to show compassion.  It was one of the main things that has been lacking for decades, and ensuring that businesses care about the people that they are supplying to is important, and it helps build trust. After all of the company has done, they need to show compassion and prove to Americans that they have learned from their mistakes. Customer well-being is the most important of all of these values. Because they are pharmaceutical company, that should be their first priority, however it wasn’t while the Sackler family owned it. The new Public Benefit Company, as well as the Sackler family, even after losing their company, need to show that they do care about the well-being of their customers. If that does not happen, then the company will not be able to flourish, and the Sackler family will remain in bad view from the public. Lastly, honesty is important in any business, but pharmaceutical companies especially. Pharmaceuticals have the power to kill people, create addictions, and cause many adverse effects. Companies need to be honest with not only their customers, but the government as well. It needs to be apparent to customers that the company has the well-being of customers as the first priority, and will not practice dishonesty to deceive customers for the purpose of profit. 

 

     If the Sackler family follows these steps of publicly apologizing, donating money to families and communities that were impacted from OxyContin, and keeping their values aligned, the company has a chance of greatly improving their public image, and potentially gaining the trust of Americans back again. Although it will be hard for them to be completely forgiven, taking steps towards this goal is important. If the family and the company do nothing, then they will be seen as even worse than they already are. 

     It is apparent that Purdue Pharma has made mistakes in the marketing and distribution of their product, OxyContin, that are considered to be extremely unethical. Not only did the company break several laws and lie to the federal government, but they also knowingly contributed to the opioid epidemic that has been controlling America for decades. Many, if not all, of Purdue Pharma’s actions were done for the sole purpose of increasing profits to extremely high amounts, however, they prioritized this over the lives of consumers. When looking at the situation from an Individualistic approach, almost everything is permissible, except for the fact that they broke the law. The ethical theory essentially states that businesses can do whatever needs to be done in order to maximize profit, as long as it is within the law. Because of that, it is obvious that this is impermissible under Individualism. In the sense of Utilitarianism, it is obvious that not everybody is happy in this situation. Not only are there millions of Americans suffering from addiction to OxyContin, but also family members and members of the community are drastically affected from that as well. Furthermore, the Sackler family ended up losing their company and having to pay billions of fines, so they are evidently not happy either. When preparing an analysis from a Kantian perspective, it becomes apparent that this is also impermissible, Purdue Pharma used customers as a means for increasing profits, and harmed them in the process. Lastly, a virtue theorist would also disagree with these actions. They are not practicing virtues that make businesses and people flourish, but they are instead practicing vices such as greed and dishonestly that harm people. Despite the fact that Purdue Pharma made a huge mistake and harmed the American people, there are steps that they can take to make things right. By taking full responsibility for their actions, as well as showing that they regret what they did by making monetary donations to those who have been affected, Purdue Pharma and the Sackler family has the ability to repair their public image, as well as potentially gain the forgiveness and trust of the American people. 

 

                                                                                                           Julianne Hess

 

 

 

 

 

References

 

Balsamo, Michael, and Geoff Mulvihill. “OxyContin Maker Purdue Pharma to Plead to 3 Criminal Charges.” AP NEWS, Associated Press, 21 Oct. 2020, apnews.com/article/virus-outbreak-business-criminal-investigations-opioids-epidemics-5f0679ffee14577b1696a94b64abc9c2.

DesJardins, Joseph R. An Introduction to Business Ethics. McGraw-Hill/Irwin, 2014. 

Ofgang, Erik. “Purdue Pharma and OxyContin: A Timeline.” Connecticut Magazine, 24 Oct. 2019, www.connecticutmag.com/health-and-science/purdue-pharma-and-oxycontin-a-timeline/article_e140534a-f50f-11e9-96ab-8bb2725250e0.html.

“OxyContin Maker Purdue Pharma to Plead Guilty to 3 Criminal Charges.” CBS News, CBS Interactive, 21 Oct. 2020, www.cbsnews.com/news/oxycontin-maker-purdue-pharma-to-plead-guilty-3-criminal-charges-ap/.

Rowland, Christopher, and Meryl Kornfield. “Purdue Pharma Agrees to Plead Guilty to Federal Criminal Charges in Settlement over Opioid Crisis.” The Washington Post, WP Company, 22 Oct. 2020, www.washingtonpost.com/national-security/2020/10/21/purdue-pharma-charges/.

Salazar, Heather. The Case Manual . 

Sherman, Natalie. “Purdue Pharma to Plead Guilty in $8bn Opioid Settlement.” BBC News, BBC, 21 Oct. 2020, www.bbc.com/news/business-54636002. 

Williams, Pete. “OxyContin Maker Purdue Pharma Pleads Guilty to Federal Criminal Charges.” NBCNews.com, NBCUniversal News Group, 22 Oct. 2020, www.nbcnews.com/news/us-news/oxycontin-drugmaker-purdue-pharma-pleads-guilty-federal-criminal-charges-n1244155.

 

Orthofix: Bribery and Fraud Scandal (2003-2017) - An Analysis of Ethical Theories in Business

Bribery and cover up have been topics covered extensively throughout the hundreds of years competitive business has been around. Orthofix, an international medical-device producer and distributor, had key executives caught in a bribery cover up scandals in both Mexico and Brazil. Heavy penalties and fines were levied against the company (to the tune of over $19 million) and their public image including relationships with stakeholders, patients, and customers took massive hits. The company continues to try to rebuild their image and gain back the trust of the public from scandals ranging from the beginning of the 2000’s until the mid 2010’s.

Orthofix Background

Founded in Verona, Italy in 1980, Orthofix is a now Texas-based medical device company specializing in the development, manufacturing, and distribution of orthopedic and spine products. Orthofix became a public company in 1992 and moved headquarters to the United States in 1995 when the company acquired American Medical Electronics. The company now operates in two segments, Global Spine and Global Extremities, doing business in over 70 countries worldwide.

 The move to the U.S. coupled with their acquisition of AME helped boost the company’s total sales over $77 million by the end of 1996 (Reference for Business). Their new business line of bone growth simulators and bone substitutes were main contributors to their success. Also, the sale gave Orthofix an extensive distribution network in the United States allowing them to sell more products internationally. In the meantime, Orthofix has continued to acquire stakes in competing orthopedic companies allowing them to expand their product line and continuously innovate.

Orthofix markets and distributes its products through direct sales representatives and independent distributors to a variety of clients including physicians, hospitals, surgery centers and other purchasing organizations. A major portion of the company’s revenue comes from sales with large hospitals and surgery centers as the company has tried to acquire a multinational market share. The company’s mission is to offer highly valued minimally invasive medical devices for the orthopedic and trauma markets and to achieve market leadership by focusing on continuous innovation in the products they serve and offer (Zippia).

The Case

             As Orthofix moved into the 21^st century, international business, specifically in Mexico and the Southern Americas, was important for the growth of the company. Orthofix did a large portion of their revenue in selling medical devices to government-sponsored hospitals in these regions and management at the corporation took steps to ensure this market for their business. From the start of the 2000’s until early 2010, Orthofix had committed acts of bribery that found the company paying routine bribes referred to as “chocolates” to Mexican officials to obtain lucrative sales contracts with government hospitals (SEC 2012 PR). These “chocolates” came in forms of cash, computers, televisions, and appliances and were given directly to officials by means of back channels and front companies. To cover the bribes, executives initially recorded them as cash advances and falsified their invoices
to support the expenditures. But, as the bribes became larger, they were eventually recorded as promotional and training costs. Yet, upon review, when an Orthofix executive noticed these expenses being consistently and significantly over budget, the bribery scandal was immediately found out and self-reported to the SEC.

            The SEC found Orthofix guilty of committing bribery from 2003-2010, illicitly spending over $300,000 to secure nearly $5 million in illegal profits with Mexican officials. The company was reported to fully cooperate with the SEC and their demands and Orthofix was eventually found guilty of violating the Foreign Corrupt Practices Act and agreed to pay $5.2 million to settle the charges.

            Yet, “where there’s smoke there’s fire”, and in 2017, Orthofix was once again charged with improperly booking revenue and making improper payments to doctors at Brazilian government-owned hospitals. The company was found improperly recording revenue as soon as products were shipped despite procedures requiring certain events in the transaction process to take place prior to receiving payment. In other instances, Orthofix immediately recorded revenue when it had provided customers with significant extensions of time to make payments (SEC 2017 PR) causing the company to misstate certain financial statements between 2011 and 2013. A separate SEC case found the company’s subsidiary in Brazil used high discounts and improper payments to induce doctors to use Orthofix products and created fake invoices to cover these services. The SEC was made aware of these crimes when the whistleblower, a doctor in Brazil, provided information to the SEC about an alleged kickback scheme operated by Orthofix (WSJ). Orthofix eventually agreed to pay $8.25 million in fines to settle their “channel stuffing” and SEC accounting fraud charges, as well as an additional $6 million in FCPA penalties, for a total of over $14 million in damages. In all, these scandals cost Orthofix over $19 million in SEC charged fines for violations relating to bribery and accounting fraud.

Stakeholders

            Because Orthofix is a public company, the future of its business and their success relies on its relationship with its stakeholders and potential customers. Their both illegal and unethical actions over the last two decades have caused public distrust and put the stakeholders in positions of risk. From a financial perspective, their stock OFIX has seen serious losses (down 85% in 2007). With that said, their share price has continued to steadily rise because they have taken steps to right their wrongs. The firing of all employees involved in these scandals was a good first step in the reshaping of their public image, but the company must make sure they don’t fall into previous practices moving forward. Orthofix prides themselves in their innovation and the high quality of the devices they provide for patients. The company should focus on continuing to rely upon the success of their products and allow for public trust to build over the positive review from customers and patients.

Individualism

            Analyzing the actions of Orthofix through the lens of an Individualist shows that while the business was certainly trying to maximize their profit, they were doing so outside the context of the law and the normally agreed-upon standards of society. According to Milton Friedman’s view on Individualism, all companies must abide by the same set of rules for this economic model to successfully work and “these laws therefore restrict what a business is ethically allowed to do to profit” (Salazar 18). In thinking of both the bribery and accounting fraud violations committed by Orthofix, it is clear that the actions performed by executives at the company were outside the bounds of legality of the system and state the company operated in and were therefore unethical in the nature of Individualism.

As a business context theory, Orthofix was certainly trying to maximize their profits, but, in doing so, broke laws and suffered penalties and fines that eventually lead to a net loss of profit in these areas where the acts were committed. The company’s system of checks and balances in their management and accounting departments was not strong nor diligent enough to uncover these crimes over the majority of time they had taken place, inevitably leading to the barrage of fines levied against the company. While Orthofix may have secured a short-term window of increased profit and brand success in Mexico and Brazil by enticing customers into using their products, they failed to see the long-term damage these crimes would carry. The severity of fines for crimes like those done by high-ranking executives inside the company should have created cause for concern, but the short-sighted mindset exhibited by these same people was the catalyst towards the penalties faced. With that said, their brand image and public trust were also hurt through these actions. Customers would now be less inclined to work with a crime-rated organization and the public was going to be less likely to invest in a company that showed trends of operating outside the bounds of the law.  

Utilitarianism

             In looking at this case in a Utilitarian sense, the actions of those in Orthofix would be deemed unethical because of their absence of consideration towards the owners and stakeholder’s happiness and desires. Through a Utilitarian lens, “all beings who are capable of experiencing happiness should be considered when weighing the costs and benefits of actions” (Salazar 20). Actions should lay consideration for all beings the action will affect, and a decision should be made depending on the value of the total benefit of the action.

            Prior to any crimes being committed, executives involved should have considered the pros and cons of bribing officials and its lasting effects. If executives considered their actions first knowing bribery could only lead to financial fraud (more crime), they would have seen the short-term gains weren’t worth the long-term losses. Executives failed to think about the desires of the stakeholders, the image that the scandal would cast on the company and the adverse effect it would have on the business relationships moving forward.

            More foresight should have gone into consideration for the crimes and what would follow by these executives at Orthofix. Employees continued to bribe officials for personal gain in their region and used fraudulent accounting measures to cover their tracks. As the illegal payments and profit grew, their attention towards the risks attached to not only themselves, but also innocent stakeholders only decreased. Utilitarians are concerned about the long-term costs and benefits of actions (Salazar 20), while executives at Orthofix were more concerned with their short-term profits. OFIX executives acted selfish in the short-term and ruined their long-term chance of success. Not only were the acts committed by these members at Orthofix highly illegal, they were also extremely unethical from a competitive and sympathetic view point.

Kantianism

            A Kantian view of this case would be interested in the intent or will behind the motivations of the people involved to commit the action. Kantianism would examine the ethics involved in bribing state officials for personal/business gain and using fraudulent accounting measures to cover a crime. In a Kantian analysis, the concerns are “the moral permissibility of the action and the moral worth in the motivation of the action” (Salazar 21). It was bad will for executives at Orthofix to commit crimes of bribery and put the company at serious financial risk.

            Another important aspect of Kantianism relies on the fact that people should act only according to maxims that could be universalized and acted upon. With relation to the acts of bribery – Could it be made a universal law to always bribe customers to get what you want? This would be impossible, because if everyone bribed everyone in every business transaction, it would be impossible to bribe someone. Also, according to Kant, he claimed “it is wrong to lie, cheat, and steal, no matter the positive consequences that occur” (Salazar 21). In examining the moral permissibility of this action again, executives at Orthofix cheated the law by bribing official for profit gain and lied about it by manipulating their accounting records in order to not get caught. Every aspect of this action goes against the key ideas of rationality and morality in the act of practicing good will.

            With attention to the fraudulent accounting measures used to cover their bribery scheme, this would be deemed unethical as well. Universalizing this maxim would leave: Could everyone cheat on their accounting measures to hide things from the government? I don’t believe this is possible because if everyone was hiding things from the government by improperly reporting financial statements, the government would know and it wouldn’t be possible. Also, it would be impossible to universalize cheating, lying, or manipulation because “An action is rational and permissible if it meets certain standards that demonstrates respect for the autonomy and rationality of all people affected by the action” (Salazar 21). Lying and cheating demonstrate a severe lack of respect for the government, its laws, and all other people abiding by those laws.

Virtue Theory

            Someone following the Virtue Theory model would be most interested in examining someone’s character and assessing if they are “virtuous” or not. This theory differs from the previous three in that they “analyze individual actions whereas Virtue Theory analyzes a person’s character” (Salazar 23). Important characteristics to be considered when analyzing someone’s traits include their virtues (honesty, wisdom, insight) and vices (greed, selfishness). Executives involved in these scandals showed a number of vices that can be considered unethical.

            Executives at Orthofix displayed certain vices like greed and selfishness that showed a poor judgement of their true character. By only thinking of the profits of their short-term gain, they exhibited key traits and characteristics that directly oppose the key virtues that build a good character. Bribing officials for personal gain (regionally and business) was selfish and showed a lack of temperance and no respect for their stakeholders or innocent parties involved. Also, they showed fraudulent behavior traits in the covering up of their crimes financially. Key virtues like honesty and trust were clearly missing from the people who committed these actions. Honesty and trust between themselves, clients, and customers has become strained because of the way in which these people acted, and their relationships could be negatively affected as they try to grow.

Justified Ethics Evaluation

            In my opinion, the actions of key high-ranking executives at Orthofix were unethical and highly illegal. The actions committed, both bribery and the reporting of fraudulent accounting measures, go directly against the goals and expectations of the free market. Breaking the law to gain an advantage can always seem like a good idea in the short-term, but most people will eventually slip and get caught, realizing the consequences were never worth the risk. The bribery was the steppingstone to fraudulent accounting practices used to cover up the initial scandal, leading to an avalanche of crimes and problems too big to cover. Negligence regarding the consequences of their actions resulted in heavy penalties against the company and negatively impacted many people that were never involved.

            The risks and rewards of their actions should have been considered more heavily and with much more severity. Understanding how hard it is to break the law and get away with it in this modern age of technology should have been a caution to anyone interested in doing so for their own personal gain. With that said, systems like the SEC’s whistle-blowing reward provide a strong incentive for individuals who notice unethical and illegal acts happening in business to report them. Often times, people involved in these acts can be scared of reporting incidents for loss of their job or blackmail, but through their anonymous system and monetary reward, it provides a reason for people to act lawfully.

            These executives at Orthofix did not act in an ethical manner and failed to show rational and moral judgements in their actions. Not only did they cheat to gain an unfair advantage over their competition, they lied and covered their tracks with the hopes of continuing their ruse and never be caught. They inevitably put the company and its stakeholders at extreme risk and valued their own self-interests over that of the greater whole.

Action Plan

            The company has already taken important steps in fixing the public image fallout associated with their scandals. Orthofix fired employees directly involved and responsible for the makings behind the schemes and immediately worked with necessary parties to “implement significant remedial measures” (SEC 2012 PR). With that said, the company’s image continues to fluctuate as they’ve had multiple scandals and struggle to engrain a trustworthy relationship with the public.

The problem with Orthofix seems to be a lack of training with regards to ethical responsibility in the workplace and helping employees make rational and grounded decisions based on their experiences. I recommend an extensive overhaul of the current training and orientation-type processes in order to start from the ground-up. All existing and new employees should be required to take these training courses that thoroughly cover the expectations and ethical practices members of their organization should abide by. Provide case examples from your own company in order to show people how serious the consequences can be for acting in a way that could hurt the company. Team members will have a better understanding of what is required from them and will be able to make grounded and rational decisions to benefit the entire organization.

Benjamin Wosky - Western New England University senior

References

“Orthofix History.” Zippia, 27 Aug. 2020, www.zippia.com/orthofix-careers-33893/history/.

“Orthofix International NV.” Reference for Business, www.referenceforbusiness.com/history/Oe-Pa/Orthofix-International-NV.html.

“Press Release.” SEC Emblem, 10 July 2012, www.sec.gov/news/press-release/2012-2012-133htm.

“Press Release.” SEC Emblem, 18 Jan. 2017, www.sec.gov/news/pressrelease/2017-18.html.

Sun, Mengqi. “Whistleblower in Orthofix Bribery Case Awarded $1.8 Million.” The Wall Street Journal, Dow Jones & Company, 25 Sept. 2020, www.wsj.com/articles/whistleblower-in-orthofix-bribery-case-awarded-1-8-million-11601064562.