Actions by New Leadership and Board Driving Compliance-Focused Culture
BANNOCKBURN, Ill., April 20, 2022 — Stericycle, Inc. (Nasdaq: SRCL) has agreed to resolutions with the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC), as well as Brazilian authorities – both the Comptroller General’s Office (CGU) and the Attorney General’s Office (AGU) – to resolve anti-corruption investigations that began in 2017 into Stericycle’s historical operations in Latin America. Stericycle fully cooperated with the investigations, which focused on conduct prior to 2017 by employees in its Latin American businesses, including in Argentina, Brazil and Mexico. Stericycle has since sold its operations in Argentina and Mexico and currently operates within the Latin American region only in Brazil. Through these resolutions, Stericycle has agreed to pay a total of approximately $90 million, which the company primarily accrued in the third and fourth quarters of 2021.
As part of the resolutions, Stericycle entered into a Deferred Prosecution Agreement with the DOJ and agreed to an administrative order with the SEC. No further enforcement action will be taken against Stericycle by the DOJ and SEC if, for a period of three years, the company meets the obligations it assumed as part of the resolutions. Stericycle will also engage an independent compliance monitor for two years, after which the company will self-report to the U.S. agencies on its compliance with the agreements for an additional year.
“Resolving this legacy matter represents another important milestone in Stericycle’s business transformation journey,” said Cindy J. Miller, president and chief executive officer at Stericycle. “Over the past several years, we have focused on fully remediating the issues identified during the investigation. This includes instituting new policies, procedures and internal controls and building a culture of compliance, integrity and accountability that aligns with our core values across our entire global operation.”
Under the direction of the board’s audit committee, Stericycle conducted its own thorough internal investigation, cooperated fully with the DOJ, SEC and Brazilian authorities, and took extensive steps to establish a strong global anti-corruption compliance program by enhancing its compliance policies, procedures and internal controls in every country in which it operates. Stericycle’s remedial actions were acknowledged by the DOJ, the SEC and the Brazilian authorities in the settlements.
Since 2017, Stericycle has transformed its board of directors and leadership team. The company has named multiple new members to its board of directors and added new, experienced executives to its leadership team, including Cindy J. Miller, who was named president and chief operating officer in 2018 and chief executive officer in 2019. The company also created a new Operations, Safety and Environmental Committee to enhance board oversight and hired compliance personnel including an experienced chief ethics and compliance officer reporting directly to Miller and the chair of the audit committee.
Building a Culture of Compliance—Remedial Measures and Global Enhancements
U.S. authorities credited Stericycle for its cooperation in the investigation and for steps the company’s new leadership has taken to enhance and ensure compliance and internal controls. As detailed in Stericycle’s deferred prosecution agreement, these steps have included:
- strengthening its corporate governance by appointing new executive leadership and board members;
- strengthening its compliance function by hiring additional personnel, including an experienced chief ethics and compliance officer;
- updating its code of conduct and internal controls relating to anti-corruption, retention and management of commercial agents and other third parties, and gifts, travel and entertainment;
- enhancing its internal reporting, investigations and risk assessment processes;
- overhauling its compliance training and communications;
- terminating employees involved in the relevant conduct; and
- divesting its subsidiaries in Argentina and Mexico.
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Stericycle, Inc., is a U.S. based business-to-business services company and leading provider of compliance-based solutions that protects people and brands, promotes health and well-being, and safeguards the environment. Stericycle serves customers in the U.S. and 16 countries with solutions for regulated waste and compliance services, secure information destruction and patient engagement. For more information about Stericycle, please visit stericycle.com.