This international business case involves an inappropriate partnership formed between a senior executive of a large wholesale company and a retailer in Oregon. The Defendant in this case is the former CEO of a large fabric wholesaler who discovered that another senior executive had entered into undisclosed partnerships with a retail distributor. These partnership discounts were not reported, and were designed in a manner that deferred payment, creating the potential for a budget shortfall and jeopardizing the company’s finances. The defendant learned of this after the executive had been terminated and his replacement discovered the deferred accommodations owed to the retailer and brought it to Defendant’s attention. The SEC alleged the defendant should have taken a more proactive approach upon learning of the executive’s actions in advising the board and the financial department. The Defendant maintained that his budget was set and his employees had a duty to adhere to the restrictions of the budget.