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City of Philadelphia Signs Settlement Agreement with Aramark and Strother Enterprises

Philadelphia, Dec. 13, 2012 –The City of Philadelphia has signed a no-fault settlement agreement with Aramark Correctional Services (ACS) and Strother Enterprises, Inc. (Strother) to conclude a dispute over allegations that the companies circumvented the City’s minority-business requirements and anti-discrimination policies by submitting inaccurate invoices to the City for payment under ACS’ food-services contracts with the Philadelphia Prison System (PPS).  

According to the settlement, the companies will pay the City a total of $400,000 and incorporate new internal policies to ensure their compliance with anti-discrimination policies on future contracts with the City and/or City-related agencies.

The settlement was the result of a Philadelphia Office of the Inspector General investigation into allegations that ACS had inaccurately reported payments made to Strother in documentation submitted to the City. Although Strother, a City-certified minority-business entity, performed actual work in connection with PPS food-services contracts, the OIG found that the company had engaged in a circular billing arrangement with ACS, which made it appear that Strother had performed a larger percentage of the contracted work than it had actually performed.

“We take our anti-discrimination policies very seriously because it is our mission to ensure fairness and equality for all who do business with the City,” said Inspector General Amy Kurland. “Everyone deserves a fair shot to compete for contracts in Philadelphia, and ACS’ scheme denied opportunities to legitimate M/W/DBEs. We will continue to pursue companies that circumvent the City’s anti-discrimination policies.”

ACS was required by contract to meet a minority-, women- and disabled-owned business entity (M/W/DBE) participation range of 20 to 25 percent, established by the Office of Economic Opportunity pursuant to Executive Order 02-05, which has since been replaced by Executive Order 03-12. If ACS had made a good faith effort to fulfill the requirement but could not do so, the City could have granted a reduction in the participation range. However, ACS did not attempt to demonstrate a good faith showing, according to the OIG’s investigation, nor did the company apply for a participation reduction. Instead, the OIG found, ACS used a circular billing arrangement to create the appearance of compliance.

Evidence of the circular billing arrangement between ACS and Strother was first discovered by the City Controller’s Office, which prompted an investigation by the OIG. The OIG established that Strother, at ACS’ direction, invoiced ACS for food-service and food-product costs. However, ACS provided the food for the contract, and Strother received a net payment for only the food service portion of the contract.  

The billing arrangement did not increase the amount of money that the City paid to ACS because Strother’s purportedly larger participation did not affect how much ACS charged PPS for food. Instead of paying Strother at least 20 percent of the contract proceeds, ACS passed on only 4 percent of the total contract value to Strother, overstating Strother’s revenue by more than $2 million. 

ACS and Strother deny any wrongdoing. ACS maintains that Strother purchased food from the company. ACS also maintains that the method by which it calculated its payments to Strother was consistent with its legal and contractual obligations.

The OIG maintains that its evidence is well-founded.

“The Office of Economic Opportunity concurs with the findings of the Inspector General’s Office,” said OEO Executive Director Angela Dowd-Burton. “M/W/DSBEs should represent arms-length relations with prime contractors on City contracts. OEO will work with the Philadelphia Prison System and ACS to insure good faith efforts are used to meet their M/W/DBE goals.”

ACS has agreed to change its minority participation-reporting procedures to more clearly explain its financial relationship with Strother to the City. ACS has also implemented a comprehensive compliance program related to the identification, retention and payment of M/W/DBEs.

Among the key provisions is a requirement that ACS executives certify that all contractual documents and invoices submitted to the City or City-related agencies are true and accurate. Similarly, Strother executives must certify the truth and accuracy of all contractual documents and invoices submitted to prime contractors performing work for the City or City-related agencies. Both companies have pledged to provide compliance training to employees involved in bidding, contract negotiation and invoicing.

The compliance programs will remain in effect for as long as ACS and Strother perform work under City contracts that contain participation requirements for M/W/DBEs.

To view the settlement agreement and an executive summary of the case, visit www.phila.gov/oig and click on the “reports” link.

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CITY EMPLOYEE CHARGED IN MILLION DOLLAR SCAM

Philadelphia, November 28, 2012 – An indictment was unsealed today charging three people, including a city employee, in a scheme to defraud the City of Philadelphia of more than $1 million, announced United States Attorney Zane David Memeger, FBI Special Agent-in-Charge George C. Venizelos, and City of Philadelphia Inspector General Amy Kurland.  Calvin Duncan, 61, of Philadelphia, worked for the Philadelphia Water Department as a mailroom clerk.  As part of his responsibilities, Duncan was responsible for mail deliveries and purchasing supplies, including printer ink and toner cartridges, for the administrative offices of PWD.  Today, agents of the Federal Bureau of Investigation in Arkansas arrested Derek and Danita Willis.

According to the indictment, Duncan submitted requests for approval to purchase printer ink and toner cartridges, falsely claiming that the cartridges were for PWD employees. After receiving the printer ink and toner cartridges from the approved vendors at the City of Philadelphia’s expense, Duncan sold the printer ink and toner cartridges to Laser Cartridge Plus, Inc. (“LCP”), a business located in Russellville, Arkansas, owned by co-defendants Derek Willis, 48, and Danita Willis, 34, both of Russellville, Arkansas.  Derek and Danita Willis sought to obtain thousands of ink and toner cartridges at prices significantly below the prices usually charged by ink and toner cartridge vendors.

In order to accomplish this, the indictment alleges that they purchased cartridges from Duncan knowing that the cartridges had been stolen.  Derek Willis dealt directly with Duncan prior to 2005 when he tasked Danita Willis with arranging to buy the illegally obtained printer ink and toner cartridges from Duncan.  Duncan mailed the illegally obtained printer ink and toner cartridges to LCP using United Parcel Service (“UPS”).

The alleged scheme was carried out between January 1, 2006 and January 5, 2012 and caused the City of Philadelphia to pay approximately $1,368,091.19 on purchase orders and shipping costs for printer ink and toner cartridges never intended to be used by PWD employees.  Additionally, Derek and Danita Willis allegedly paid Duncan approximately $545,412.79, which was not due to him, for the printer ink and toner cartridges purchased with the City of Philadelphia funds and shipped to LCP using PWD’s UPS shipping account.

“The fraud alleged in this indictment cost the city crucial funds that might have benefitted the taxpayers in other ways,” said Memeger. “This office will work with our partners in federal, state and local government to pursue people who steal from their municipal employers.”

“The case against Duncan was initiated by the Philadelphia Office of the Inspector General in September 2011 after investigators received a tip from a city employee. The OIG then teamed up with the FBI to conduct a joint investigation,” said Inspector General Amy Kurland.  “Collaboration is the key to fighting public corruption in Philadelphia. Oftentimes, cases like this start with tips from City employees who have the courage to do the right thing. Together, we’re changing the culture of corruption that has damaged the reputation of too many good public servants.”

“The FBI, with the United States Attorney’s Office, and the Inspector General’s Office, is committed to pursuing individuals who blatantly steal from the City for personal gain,” said Venizelos. “Today’s indictment illustrates law enforcement partners working together to send a message that these types of actions will not be tolerated, but prosecuted to the fullest extent of the law.”

Duncan, Derek and Danita Willis are charged in five counts of mail fraud and aiding and abetting.  Derek and Danita Willis also are charged with obstruction of justice for the destruction of documents related to the fraud scheme. They also are charged with perjury for knowingly making false statements to the grand jury on May 8, 2012.

If convicted of all charges, Duncan faces a maximum possible sentence of 100 years imprisonment, a maximum fine of $1.25 million, a $500 special assessment, and supervised release; Derek Willis faces a maximum possible sentence of 120 years imprisonment, a maximum fine of $2.25 million, $900 special assessment, and supervised release; Danita Willis faces a maximum possible sentence of 110 years imprisonment, a maximum fine of $1.75 million, a $700 special assessment, and supervised release.

The case was investigated by the Federal Bureau of Investigation and the City of Philadelphia Office of the Inspector General. It is being prosecuted by Assistant United States Attorney Tomika N. Stevens.

CITY OF PHILADELPHIA REACHES NO-FAULT AGREEMENT WITH WILLIAM BETZ JR. INC.

Philadelphia, October 24, 2012–   The City of Philadelphia signed a no-fault settlement agreement with William Betz Jr. Inc., a local heating and plumbing supply company, for its involvement in circumventing minority-business requirements and anti-discrimination policies for at least 15 City contracts.  According to the settlement, William Betz Jr. Inc. will not participate in any contracting with the City for 24 months, will pay the City $128,000 and will comply with the provisions of an Equal Opportunity Procedures Policy.

“The agreement between the City and Betz achieves the objectives my office wanted from this case,” Kurland said. “Betz has voluntarily accepted the sanctions that would have been imposed on the company if it had not made a good faith effort to resolve this matter. We appreciate their cooperation.”

According to the agreement, Betz will pay the City $128,000, in full, within a 90-day period.  The agreement also stipulated the following:

  • Betz and all related entities will refrain from performing work for the City and bidding on City contracts for 24 months, effective October 23, 2012.
  • On storefront signage and on key sales-related documents distributed to its customers, Betz must disclose that it is prohibited from selling supplies to companies that plan to use those goods in work performed under contract with the City.
  • On October 23, 2014, Betz will again be eligible to participate in City contracts but must comply with the terms of an Equal Opportunity Procedures Policy (EOPP).

Under the EOPP, all of Betz’s sales transactions must be “arms length.” This provision prohibits Betz from negotiating arrangements between prime contractors and disadvantaged subcontractors that are certified by the Office of Economic Opportunity (OEO) as minority-, women- or disabled-owned business entities (M/W/DBEs). Betz may direct customers to the OEO Registry of M/W/DBEs if they are seeking a certified subcontractor to perform a Commercially Acceptable Function, as defined in the City’s anti-discrimination policies.

Additionally, the EOPP contains the following provisions:

  • Within 30 days of the EOPP’s adoption, Betz must provide at least one hour of training to all of its sales employees to ensure compliance with both the EOPP and the City’s antidiscrimination policies. Betz must review the program annually and update its training to reflect any changes in the City’s anti-discrimination policies.
  • Within 90 days of the EOPP’s adoption, Betz is required to issue a report to OEO summarizing the implementation process of the agreement.
  • A compliance manager at Betz will be responsible for communicating the terms of the EOPP to sales staff on a monthly basis. The manager will also be responsible for reporting noncompliance to the OIG, the Procurement Department and the OEO.

If Betz does not fulfill the terms of the agreement, the City reserves the right to pursue civil action to ensure compliance.

In a case summary released in January, the Office of the Inspector General established that William Betz Jr. Inc., JHS and Sons Supply Company and UGI HVAC Inc. colluded to make it appear that JHS, a City-certified minority vendor, had provided equipment and supplies for a government-funded weatherization project when JHS was paid only for the use of its name and minority certification.

As a result, the City entered into a $100,000 settlement agreement with UGI HVAC, Inc. and removed JHS and Sons from its list of certified minority businesses on January 12, 2012.  The City also began debarment proceedings against William Betz Jr. Inc. but has withdrawn the notice after further negotiations and agreeing to the earlier mentioned terms.

 

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OIG INVESTIGATION LEADS TO $1.85 MILLION SETTLEMENT WITH PRISON HEALTH SERVICES, INC.

Philadelphia, July 25, 2012 – Following a Philadelphia Office of the Inspector General investigation into a woman-owned subcontractor arrangement, the City of Philadelphia has entered into a $1.85 million settlement with a prime city contractor and will initiate debarment proceedings against the subcontractor.

Philadelphia Inspector General Amy Kurland today released a summary of the OIG’s investigation, which found that prime contractor Prison Health Services, Inc. (“PHS”), now known as Corizon Health, Inc., subcontracted with JHK Inc. to make it appear that JHK—a City-registered, woman-owned business — had provided pharmaceutical supplies to the Philadelphia Prison System. In fact, JHK was paid only for the use of its name and its woman owned business certification.

“For more than four years now, the Philadelphia Inspector General has been aggressively rooting out fraud and corruption in city government and among those who do business with the city,” said Mayor Michael A. Nutter. “I applaud Amy Kurland and her hard-working staff who have saved or recovered millions of dollars on behalf of taxpayers. Regarding this case, the City will not tolerate any business that fraudulently circumvents the our anti-discrimination policies.”

The Inspector General said, “Many disadvantaged yet qualified small businesses are still struggling to keep people on the payroll. We’re committed to leveling the playing field here in Philadelphia so all businesses can compete for City contracts and create jobs for talented minority-, women- and disabled-owned businesses.”

In documents provided to the City, PHS represented that it had entered into a subcontract with JHK worth 40 percent of its $196 million health-care contract with the Philadelphia Prison System.  Instead, from 2007 to 2011, Secure Pharmacy Plus LLC and Maxor National Pharmacy Services Corporation actually provided pharmaceuticals to the Philadelphia Prison System while PHS paid JHK more than $410,000, about 1 percent of the total contract value, to make it appear that JHK was supplying pharmaceuticals.

PHS took the position that it fully disclosed its subcontractor arrangement with JHK to the City.  However, while PHS did request and receive approval from an employee at the Philadelphia Prison System who oversaw the City’s contract with PHS, PHS never notified the Office of Economic Opportunity (“OEO”), which oversees compliance with the City’s anti-discrimination policies, or its predecessor, the Minority Business Enterprise Council (“MBEC”) of the arrangement, as it was required to do.

The City seeks qualified minority, woman and disabled-owned businesses to play a significant role in all of its contracts, but prime contractors can seek a reduced participation goal when they have made a good faith effort to find certified minority-, women- or disabled-owned vendors (M/W/DSBEs) but are not able to meet the participation goals. 

To comply with the City’s anti-discrimination policies, M/W/DSBEs must perform a commercially acceptable function under any subcontracting agreement.  OEO defines a commercially acceptable function as performing, managing or supervising meaningful work or supply efforts that are distinct from other parts of the contract and consistent with the anticipated cost of business.

JHK admittedly failed to provide any services to the Philadelphia Prison System other than placing its name on paperwork PHS submitted to the City.

In addition to the settlement with PHS, Kurland recommended that the City remove JHK from the OEO registry of certified M/W/DSBEs and initiate debarment of JHK and its owner from participation in any City contract for two years.  Acting on the IG’s recommendation, the City has removed JHK from its registry and begun the debarment process.

Upon learning of the OIG’s investigation, PHS worked cooperatively with the OIG and made good-faith efforts to comply with the City’s policies relating to M/W/DSBE participation, including promptly replacing JHK with another certified WBE engaged in the provision of pharmaceutical services.

As part of the settlement, PHS agreed to strengthen its corporate compliance program by reviewing all of its subcontracting agreements to ensure compliance with City anti-discrimination policies.  PHS has appointed an M/W/DSBE Compliance Team Member, who ensures that M/W/DSBE requirements are fully understood by PHS personnel and who, along with PHS’s in-house counsel, must approve the M/W/DSBE portion of any bid or contract submitted to the City or any City-related agency.  PHS will also provide training to its employees about these requirements. 

Additionally, PHS is developing a corporate-level vendor diversity program and will join the National Minority Supplier Development Council and the Women’s Business Enterprise National Council in order to continue to promote diversity among its vendors nationwide. 

Kurland noted that “the OIG is pleased with the way PHS responded to its investigation by taking responsibility for using a pass-through subcontractor arrangement and taking aggressive measures to ensure compliance with City policies going forward.”

The OIG will continue its ongoing probe into companies paying M/W/DSBEs to act as pass-throughs on City contracts and into companies that allow prime contractors to use their name and M/W/DSBE certification without performing any real work.

“We hope this investigation sends a message that compliance with the City’s anti-discrimination policies is essential,” Kurland said.

The settlement agreement and case executive summary are available at http://ph.ly/OIGReports.

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Philadelphia OIG uncovers sham minority contractor scheme

Philadelphia, January 12, 2012 – In the wake of a Philadelphia Office of the Inspector General investigation into a sham minority contracting scheme, the City of Philadelphia has begun debarment proceedings against one contractor, removed a second from its list of certified minority businesses and reached a no-fault settlement with a third contractor, which has agreed to pay the City $100,000.

In a case summary released today by Philadelphia Inspector General Amy Kurland, the OIG established that William Betz Jr. Inc., JHS and Sons Supply Company and UGI HVAC Inc. colluded to make it appear that JHS, a City-certified minority vendor, had provided equipment and supplies for a government-funded weatherization project when JHS was paid only for the use of its name and minority certification.

The vendors falsely represented their compliance with anti-discrimination and economic-opportunity policies designed to help disadvantaged businesses compete for City contracts, Kurland said.

When apprised of the OIG’s findings, the Office of Economic Opportunity removed JHS from its list of certified minority vendors and the Law and Procurement departments began debarment proceedings against Betz. The OIG and the Law Department finalized the settlement agreement with UGI earlier today.

“This city is committed to doing business fairly and transparently,” Kurland said. “Companies that flout the rules need not apply.”

Angela Dowd-Burton, executive director of the City’s Office of Economic Development, echoed Kurland’s sentiments and emphasized the important role that minority- and women-owned businesses play in creating jobs, spreading prosperity and spurring entrepreneurship in Philadelphia.

“The goal of this Administration is to have minority-owned businesses provide a commercially acceptable function and to be compensated accordingly,” said Dowd-Burton. “We cannot afford the displacement of legitimate minority contractors with business owners that are willing to sell their good name, nor can we tolerate contractors that create schemes to circumvent our inclusion strategy.”

In June 2010, UGI signed a $1 million contract with the Philadelphia Housing Development Corporation to make houses more energy-efficient for low-income residents of Philadelphia.

UGI pledged to hire a subcontractor certified by the City as a Minority, Women or Disadvantaged Business Entity and later informed the City that JHS would provide boilers, hot-air furnaces and chimney liners for the weatherization project. However, investigators discovered that UGI had purchased those products from Betz, who paid JHS 3 percent of the contract proceeds from UGI to pretend JHS was the supplier.

Rudy Betz, president of William Betz Jr., brokered the deal among the three companies, Kurland said.

Investigators also found that UGI and Betz had generated false invoices to cover their tracks, and discovered that Betz had used JHS as a sham minority contractor on at least 14 other city contracts.

If debarred, William Betz Jr. Inc. would be banned from conducting business with the city for up to three years, the maximum penalty.

The City has not initiated debarment proceedings against a company since 2007, but Kurland said the sanction was warranted in this case because Betz completely disregarded the interests of the City and of legitimate minority businesses.

“Debarment is rare for a reason,” Kurland said. “The city saves it for the most egregious breaches of contract.”

The Office of Economic Opportunity and the Office of Housing and Community Development provided invaluable assistance in the investigation, Kurland said.

In particular, Kurland and Dowd-Burton commended the efforts of the Office of Housing and Community Development’s compliance unit, which first identified evidence of the scheme and referred the matter to the OIG.

As part of its settlement agreement with the City, UGI has promised to raise minority-owned business participation to 50 percent on a future weatherization contract with PHDC.

UGI has also created new policies and procedures to ensure that its employees comply with the City’s anti-discrimination and economic-opportunity policies.

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Villanova man indicted for allegedly bribing a City of Philadelphia employee

Philadelphia, October 4, 2011 – A joint investigation conducted by the Philadelphia Office of the Inspector General (OIG) and the Federal Bureau of Investigation (FBI) has led to the indictment of a 61 year-old Villanova man on suspicion of bribing a City official.

In an attempt to expedite and guarantee the acquisition of a property on the 7100 block of James Street, in the Tacony section of Philadelphia, Daniel Apokorin and several co-conspirators allegedly presented $5,000 cash to a City official, according to the indictment. The City official immediately reported the alleged bribery attempt, spurring an OIG-FBI investigation.

Apokorin and his co-conspirators continued to pursue the property and allegedly gave an additional $5,000 to an undercover federal agent posing as a City official, the indictment said.

Cooperation among the OIG, the FBI and City officials made the case successful, said Inspector General Amy Kurland.

“City employees have provided crucial assistance in many of our cases,” Kurland said. “We should celebrate these honest public servants for standing up against corruption.”

Kurland said the case represented another important step on the road to good government.

“When City employees refuse to sell their integrity, they cast light on a dying stereotype,” Kurland said. “Most City employees are honest and hard-working. They want to earn only what they deserve.”

Division of Technology deputy fired for exploiting City’s Verizon contract

Philadelphia, July 20, 2011 – Managing Director Richard Negrin has accepted the findings of an Office of the Inspector General (OIG) investigation into City employees who exploited the City’s Verizon contract for personal gain, and has terminated one high-level Division of Technology employee and demoted another.

An OIG investigation found that Joseph James Sr., the Deputy Chief Information Officer for Communications and Operations, and Concetta D. Lilly-Pearson, an Information System Operations Manager, had accepted meals and gifts from vendors with City contracts, violating a mayoral executive order and provisions of the Philadelphia Home Rule Charter.

Today, James was terminated; Lilly-Pearson was demoted and given a 20-day suspension.

In addition, Francis G. Punzo, a former deputy commissioner of the Department of Public Property, was implicated in the actions conducted by James and others while he worked for the City of Philadelphia.

Verizon has taken “significant disciplinary measures” against those employees who provided meals and/or entertainment to City employees, according to Verizon’s corporate counsel. One employee was terminated and five received final written warnings, “which is the most serious form of discipline short of termination.”

James accepted 39 business-related meals — a personal benefit of $1,300 — from representatives of Verizon, Comcast, Shared Technologies, Motorola and RCC Consultants between January 2006 and December 2009.

Verizon representatives provided 18 of those meals — a $733 benefit to James — including a dinner at Morton’s steakhouse in December 2007 to thank James, Lilly-Pearson and Punzo for helping to renew the City’s Verizon contract for telephone and data services. Verizon representatives also provided a Philadelphia Flyers game ticket to James and sent him a $77 cheesesteak delivery.

Lilly-Pearson accepted two meals from Verizon for a personal benefit of $151. Punzo accepted 122 business-related meals from the five vendors — a personal benefit of $3,153 — for the years 2006 to 2009. Verizon representatives provided 80 of those meals — a personal benefit of $2,255 for Punzo — as well as four golf outings and tickets to six sporting events.

With few exceptions, Executive Order 002-04 prohibits employees in the executive branch of City government from soliciting or accepting, directly or indirectly, anything of value, including any gift, gratuity, favor, entertainment or loan, from vendors with City contracts. It also prohibits vendors from providing anything of value to City employees.

James and Punzo also used City resources to set up an unauthorized Verizon Business Link Rewards account, through which they improperly procured more than $48,000 worth of rewards — including iPods, gift cards, televisions and Tumi tote bags — from December 2005 to September 2009.

James and Punzo hid the rewards from the City’s property inventory and distributed items at their own discretion. James kept an iPod for his own personal use. Lilly-Pearson kept one iPod for her personal use and gave one to a family friend.

To date, most of the rewards items have not been located, including $2,300 worth of gift cards to Best Buy, Macy’s and Barnes & Noble. Kurland noted that this was not surprising given James and Punzo’s efforts to shield the rewards program from scrutiny.

“This case proves yet again that corruption spreads in the absence of oversight,” Kurland said. “We have to be vigilant. We have to hold our employees accountable at every level of government.”

Kurland said that the Managing Director’s Office (MDO) would redeem the remaining $107,600 worth of rewards points for Lowe’s and Best Buy gift cards, which the MDO’s PhillyRising program will use for community beautification projects throughout the fiscal year.

PhillyRising targets neighborhoods throughout Philadelphia that are plagued by chronic crime and quality of life concerns, and establishes partnerships with community members to address these issues. The PhillyRising Team coordinates the actions of City agencies to help neighbors realize their vision for their community through sustainable, responsive, and cost-effective solutions.

Before joining the City as Deputy Commissioner of the Department of Public Property’s Communications Division in February 1995, James was the Bell Atlantic account manager responsible for the City’s telephone and data services. In June 2000, Bell Atlantic merged with GTE to become Verizon.

Punzo was the Verizon account manager responsible for the City’s telephone and data services before he joined the Department of Public Property as a Communications Superintendent in January 2004. Punzo reported directly to James until February 2007, when James transferred to the Mayor’s Office of Information Services — now known as the Division of Technology — to become Deputy Chief Information Officer.

Punzo replaced James as Deputy Commissioner and held that position until he resigned in September 2009. Punzo then returned to Verizon, but did not work on the City’s account.

Public Property Commissioner Joan Schlotterbeck and Verizon’s legal compliance team have cooperated fully with the OIG’s investigation.

Verizon employees who received final warnings were taken off the City account and warned that any further misconduct would result in further discipline, including possible termination, according to Verizon’s corporate counsel. “All the employees who received a final written warning (except for one employee whose conduct was deemed less serious) were denied a 2011 salary increase and were personally counseled by Verizon Legal to reinforce their understanding of the rules.”

Representatives of Comcast, Shared Technologies, Motorola and RCC Consultants also cooperated with the OIG’s investigation.

The OIG has referred its ongoing investigation to the City Board of Ethics to determine if the parties involved have violated ethics rules. The OIG has also referred the matter to the U.S. Attorney’s Office to determine if there were any violations of federal law.

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