Avery Dennison Corporation
Avery Dennison Corporation
United States
Securities and Exchange Commission
China and several (unnamed) countries
Legal Person
Consent to Cease-and-Desist Order
Disgorgement of Profits, Prejudgment Interest, Civil Penalty
Art.16, Art.26
Art. 1, Art. 2, Art. 8
Internal Controls Violations, Falsification of books and records
No admission or denial of allegations
According to US Department of Justice Report to Congress, "Appendix C: Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010," Avery Dennison Corporation, at 39-40: Misconduct in China took place 2002-2005; (1) the Reflective Division of Avery (China) Co. Ltd. (Avery China) paid or authorized the payments of approximately $300,000 in kickbacks, sightseeing trips, and gifts to Chinese government officials; In one transaction, Avery China secured a sale to a state-owned end user by agreeing to pay a Chinese official a kickback of nearly $25,000 through a distributor. Avery China realized $273,313 in profits from this transaction. (2) illegal payments of approximately $51,000 by an Avery-acquired company, after acquisition, of making illegal petty cash payments to customs or other officials in several countries. Civil disposition: In administrative proceeding, SEC ordered Avery to cease and desist from such violations and to disgorge $273,213, with $45,257 in prejudgment interest. In federal civil action, Avery agreed to the entry of a final judgment requiring it to pay a civil penalty in the amount of $200,000. Cases are: SEC v. Avery Dennison Corporation (C.D. Cal., July 28, 2009), In the Matter of Avery Dennison Corporation (July 28, 2009).