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Unfortunately, in retrospect two separate Continental
group organizations, not part of the Continental Can
Company or in the jurisdiction of the head of the
Continental Can Company, my predecessor, apparently
continued to do business with two former Boffa asso­
ciates not charged -- who were not charged with criminal
activities, but had been associates.
With the advantage of hindsight, I would say
that Continental should have disengaged more promptly
and completely following Mr. Boffa's conviction.
One result of the Commission's interest in
this matter has been to alert our company's management
to the lack of a formal written corporate policy in
this area. I'm certain that if it had not been for
the Commission's efforts, these issues might not have
been forced up to senior management levels in companies
like ours for appropriate action.
For example, in Continental, at my request,
our general counsel is drafting a specific company
policy to deal with this type of situation. I strongly
believe in the presence of due process, whether in our
legal system or in the corporate environment. I
believe that a criminal conviction is more than ample
evidence to cease doing business with such enterprises
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