Investigative Report: Violation of Corporate Policy by Amtrak Employees, with W.W. Grainger Inc., October 11, 2016

Background

This report presents the results of our investigation into allegations that the following Amtrak (the company) employees violated company policy by accepting paid trips from W.W. Grainger Inc. (Grainger), an industrial supply distributor, to its annual trade show (Grainger Show) in Orlando, Florida while involved with procuring products from Grainger

Conclusions

Our investigation found that company employees improperly accepted gifts from Grainger, a contractor doing business with the company and, thus, violated or acted inconsistently with the Ethical Conduct and Conflict of Interest policy. Further, they failed to disclose these gifts on their respective Certificates of Compliance.

Mitigating these violations, however, is the role local management played in “approving” these trips. Notably, as discussed below they failed to recognize
Grainger’s offer directly implicated the company’s ethics policy. As a result, they did not aggressively develop the facts, circumstances, and implications of these trips, nor did they seek assistance from the Law department, which has staff cognizance over the company’s ethics policy.