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agreements negotiated on behalf of the Plastics Division.  Cosgrove, who was in charge of C&A's Financial Planning and Analysis Group, instructed the Purchasing Department to obtain the side letters and provided detailed language for these letters.  Barnaba ensured that Purchasing Department employees obtained the side letters and that these letters provided an apparent justification for the improper accounting.    

31.Stockman played a hands-on role in C&A's day-to-day operations before he became CEO in August 2003.  From at least the second quarter of 2003, Stockman met with Purchasing Department employees at least quarterly and emphasized the importance of negotiating supplier rebates.  He routinely identified the suppliers to target, the size of the rebates to demand, and the incentives to offer.  Stockman directed that the rebates be used to boost income in the current quarter even though he knew, or was reckless in not knowing, that such recognition was improper because the rebate income was contingent on future purchases from the suppliers.  One such meeting took place on May 27, 2003, when Stockman spoke via conference call with purchasing officials from all three C&A divisions.  During that call, Stockman directed C&A's purchasing officials to increase income in the second quarter of 2003 by "pulling ahead" rebates that would otherwise be properly recognized in future quarters.

32.During the second quarter of 2003, C&A improperly recognized rebates from, among others, Brown Corporation ($500,000), Dow ($400,000), and Manufacturer's Products ($150,000).   C&A also recognized a $1.2 million rebate from DuPont Textiles & Interiors ("DuPont") in the second quarter of 2003, even though this was actually a short-term loan similar to the McCallum payments.  Both Stockman and Stepp were directly involved in C&A's fraudulent accounting for the DuPont transaction.

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