(See PDF here.)
I am the communications director for Redflex Traffic Systems.
I have been reviewing the stories you have posted about Redflex and the recent decision by Culver City to continue utilizing Redflex as the city’s photo enforcement vendor.
I wanted to reach out to you and introduce myself and ensure you had my contact information.
Additionally, I wanted to make sure you were aware of the findings we released over a year ago regarding our internal investigation into our City of Chicago contract.
I have attached those findings. In response to these findings, Redflex secured the resignation or termination of the executives who were involved — the Executive Vice President, CEO, CFO and General Counsel. In addition to ridding itself of the individuals involved, Redflex voluntarily reported the misconduct that it discovered to the appropriate law enforcement agencies, and it is cooperating fully with those agencies.
Further, I wanted to make sure you were aware of the corrective actions Redflex has implemented since we announced these findings:
1. Training: A Redflex Anti-Bribery and Anti-Corruption online training system has been created to train all employees, Board of Directors, and all contracted commercial intermediaries on Redflex Anti-Bribery and Anti-Corruption policies and procedures. All employees are required to complete Redflex Anti-Bribery and Anti-Corruption training acknowledgement on an annual basis. Additionally, there is expanded training for employees with high risk job classifications.
2. Assessment and Reporting Processes: Established specific policies and procedures to monitor compliance with state and municipal gift and hospitality policies, including appropriate reporting obligation to customers.
3. Hotline and Compliance Email: A whistleblower program, including a live 24-hour hotline and dedicated email address enables employees and Redflex customers, to report suspicious or illegal or unethical behavior on an anonymous basis and an assurance those reports will be reviewed, investigated and resolved. Reports flow directly to the Audit Committee Chairman, Director of Compliance and Redflex International Global Chief Financial Officer simultaneously.
4. Compliance Association Membership and Software Solutions: Membership in TRACE International, an association that provides compliance solutions and software to enable the company to track observance of Redflex policies and provide reports to customers.
5. Contract Provisions and Processes: The company has included language in its contracts with outside consultants stressing compliance with its policies and has changed its contract processes to ensure compliance.
a. Sales Consulting Agreements are being evaluated and now include, or will include, strong Anti-Bribery and Anti-Corruption compliance provisions.
b. Master Subcontractor Agreement and Professional Services agreements have been updated to include strong Anti-Bribery and Anti-Corruption compliance provisions.
c. All Sales Consulting Agreements and administration are now under the supervision of the General Counsel's office.
d. The company has clearly delineated the different roles of its sales consultants and lobbyists.
6. Enhanced Expense Report Processes: The company's expense reimbursement system has been fortified and is regularly monitored.
a. Expense reimbursement processes, controls, and training have been enhanced. The Director of Compliance reviews expense reports each pay period for all employees who interact with third parties.
b. Expense reimbursement form will be updated to require additional detail and a signature legend that requires the employee and approver to attest that the expenses are compliant with policy.
Ms. Ryan may be contacted at jryan@redflex.com
