Let’s say you’re a publicly traded manufacturer of a popular medical device, which you sell commercially as well as to a number of VA hospitals. You receive an anonymous internal hotline complaint alleging that certain unauthorized, reverse-engineered components were used in the manufacturing process and that certain quality tests were skipped in the interest of “efficiency.” You triage the complaint, do your preliminary diligence, determine the complaint isn’t frivolous, and launch a privileged internal investigation.

You know you have a legal obligation to investigate (remember, our device manufacturer is a publicly traded federal contractor), but you’re obviously apprehensive about what you might find. You’re also apprehensive about where those findings may take you. You can see the dominoes falling one by one in your mind’s eye.

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