🔥 Warm-Up (5 minutes)
- In your workplace, how are conflicts of interest typically identified and disclosed, and do you think the current process is effective?
- Should whistleblowers who report wrongdoing anonymously be entitled to the same legal protections as those who report openly? Why or why not?
📖 Key Vocabulary
| English | Type | Example Sentence |
|---|---|---|
| malfeasance | n. | The audit report cited several instances of financial malfeasance within the procurement department. |
| whistleblower | n. | The company's whistleblower policy guarantees anonymity to employees who report misconduct in good faith. |
| conflict of interest | n. | Board members are required to recuse themselves from any decision that presents a conflict of interest. |
| collusion | n. | Investigators found evidence of collusion between the purchasing manager and an external supplier. |
| due diligence | n. | The legal team conducted extensive due diligence before the merger was approved. |
| kickback | n. | The contractor was accused of paying kickbacks to secure government contracts. |
| indemnify | v. | The vendor agreed to indemnify the company against any losses arising from its own negligence. |
| reprisal | n. | Employees who file complaints are protected from reprisal under the new whistleblower statute. |
| circumvent | v. | Several managers attempted to circumvent the approval process by splitting invoices below the reporting threshold. |
| culpable | adj. | The internal review concluded that two senior executives were culpable for the reporting failures. |
🧠 Grammar / Strategy Focus
When a sentence begins with a negative or restrictive adverbial expression — such as Not only, Under no circumstances, Rarely, Seldom, On no account, or Not until — the subject and auxiliary verb must be inverted, just as in a question. This construction, common in formal business and legal writing, lends emphasis and a more authoritative tone, and it appears frequently in compliance policies and audit reports. For example: 'Under no circumstances should an employee accept payment from a vendor currently under contract negotiation.' Similarly: 'Not only did the compliance review expose gaps in the reporting system, but it also prompted a full audit of the procurement division.'
✏️ Part 5 Practice
Incomplete Sentences
📝 Part 6 Practice
Text Completion (Subject: Mandatory Ethics & Compliance Training – Q3 Deadline)
To: All Department Heads From: Office of Corporate Compliance Re: Mandatory Ethics & Compliance Training – Q3 Deadline
This memorandum serves as a reminder that, (1) the recent regulatory scrutiny faced by our industry, all employees are required to complete the revised Ethics and Compliance Training module no later than September 30.
It is imperative that every department head (2) attendance and submit a completion report to this office by the deadline stated above.
Employees (3) to complete the module by the deadline will have their system access (4) pending a follow-up review by Human Resources.
Any employee who suspects a violation of the Code of Conduct is strongly encouraged to report the matter through the confidential whistleblower hotline. Under no circumstances will retaliation against a good-faith reporter be tolerated.
📰 Part 7 Practice
Reading Comprehension
Following an internal investigation that uncovered irregularities in how certain regional offices engaged third-party agents, Meridian Industries has overhauled its anti-corruption policy to bring the company into closer alignment with international regulatory standards. The revised policy, which takes effect on October 1, mandates that any employee entering into an arrangement with a third-party intermediary first obtain clearance from the Office of Corporate Compliance. Notwithstanding the additional administrative burden this requirement imposes, senior management insists that the enhanced due-diligence procedures are indispensable if the company is to avoid the reputational and financial fallout experienced by competitors embroiled in bribery scandals.
The policy overhaul was prompted not by a regulator's inquiry but by an anonymous tip submitted through the company's whistleblower hotline, a channel that has seen a marked increase in usage since it was relaunched with guarantees of confidentiality and protection against reprisal. Employees found to have colluded with external parties to circumvent procurement controls will face disciplinary measures ranging from suspension to termination, and, where warranted, referral to law enforcement. Going forward, all staff, irrespective of seniority, will be required to complete refresher training on the Code of Conduct annually, with completion rates to be reported directly to the board's audit committee.
🎧 Listening Practice
Conversation (Part 3 style)
Teacher: read the script aloud twice (or record it) at natural speed, then ask students the questions below.
Woman: Do you have a minute? I wanted to run something by you before I take it to Compliance.
Man: Sure, what's going on?
Woman: It's about the vendor selection for the new packaging contract. Turns out one of the finalists is run by my cousin's husband, and I only just found out.
Man: Ah, that's not exactly a coincidence you can just brush aside, is it? Have you disclosed it yet?
Woman: Not formally. I figured I'd get your take first, since you sat on the ethics panel last year.
Man: Honestly, the sooner you file a disclosure form, the better. If it comes out later that you sat on this, it'll look a lot worse than the conflict itself.
Woman: That's fair. I'll draft the disclosure this afternoon and loop in the compliance officer before the vendor shortlist gets finalized on Friday.