Executive Decision Lab™

The Consulting Fee

A bribery whistleblower just gave your leadership team 48 hours. A 90-minute facilitated session on who takes the wheel when the regulatory clock starts — and whether your controls and culture already failed before the call came in.

What This Lab Is Really About

Scenario Vehicle

Anti-Bribery / FCPA

Leadership Lesson

Crisis Command and the Self-Disclosure Decision

The real discussion is not about the bribery law. It is about who takes the wheel when a whistleblower’s clock is running, why Finance paid what Sales negotiated with no compliance check on the vendor, and whether anyone would have heard the warning before it became a 48-hour ultimatum.

The Scenario

An anonymous report is received by Marrenford Industrial’s compliance hotline. It alleges that the company’s top-performing regional sales director in the Republic of Veturia, Derek Mallory, has been routing “consulting fees” to a firm called Halvorne Advisory — quietly owned by the brother-in-law of the official who awarded Marrenford’s largest contract, roughly 12% of projected global revenue. Finance approved the payments; the invoices looked clean. The reporter says they raised this with a local manager months ago and were told to keep quiet. They are no longer waiting: the company has 48 hours before they take it to regulators and the press.

“Our people would never do this.”

It’s the first thing most leaders think when reading a scenario like this — and it’s usually true. In a calm, fully informed room, no one approves of the bribe or silences the reporter. But that’s not where these decisions get made. They get made under a revenue number that depends on the deal, in a relationship leadership spent years building, with a star performer no one wants to doubt. This Lab doesn’t test whether your team knows right from wrong. It surfaces whether the conditions that allow a payment like this to clear — and a warning like this to go unheard — are already present here.

How the Crisis Unfolds

Three injects, dropped into the room at 30-minute intervals. The pressure compounds each time.

Inject 1 · 0–30 min · The Internal Fire

The reporter is no longer only internal. They have copied a mid-level HR representative on a written message: act within 48 hours, or they will go to the SEC and the press. The room must decide: Do we suspend Mallory now? How do we protect a whistleblower when half the sales team can already guess who it is? And what is our protocol for preserving records in that regional office before anyone starts deleting?

Inject 2 · 30–60 min · The External Pressure

Finance confirms it: Halvorne Advisory is owned by the brother-in-law of the official who awarded the contract. In the same hour, a technology-sector journalist DMs the VP of Marketing to ask for comment on “alleged financial irregularities” in the region. The room must decide: How fast can we freeze pending payments to Halvorne? What is the holding statement? Do we stop work on the contract now, or wait for a formal internal investigation?

Inject 3 · 60–90 min · The Bind

The awarding official learns of the investigation and threatens to cancel the contract outright — and sue for breach — if Marrenford halts operations. Meanwhile, the board wants an update in two hours. The room must decide: Do we self-disclose to regulators today to get ahead of the reporter, or finish our internal investigation first? And what do we tell the board about the revenue forecast?

The Four Pressures in the Room

None of them is irrational. That is what makes the wrong call feel reasonable.

Revenue. One contract is 12% of global revenue. Halting it blows a hole in the forecast that the whole leadership team will have to answer for.

Authority. The accused is the region’s top performer. Acting against him feels like punishing the person who delivered the company’s biggest win.

Relationship. The contract — and the official behind it — represent a relationship leadership spent years building. Walking away has a cost no one wants to own.

Time. A 48-hour whistleblower ultimatum and a two-hour board deadline compress every decision — exactly when the team most needs to slow down.

What This Lab Surfaces

By the end, the team should not just be stressed. They should have named three gaps in the company’s playbook — the ones the crisis exposed.

Who is actually in charge?

During an active investigation, does the CEO lead — or does Legal and Compliance take the wheel? Most teams have never decided this in advance and discover the answer mid-crisis.

Where are the data silos?

Why did Finance approve a payment that Sales negotiated, with no one in Compliance ever checking the vendor? The bribe didn’t slip through a gap in the rules. It slipped through a gap between departments.

Is the culture safe?

Why did the reporter feel they had to threaten the press, instead of trusting the company’s own hotline and HR channels? A whistleblower who escalates externally is telling you something about the channel you built.

Who Should Be in the Room

The leaders who would actually be in the room during a real crisis — each with a pre-named role card, or playing themselves. Seven seats:

CEO — owns the board and investor fallout, and the question of who leads
Chief Compliance Officer — the regulatory exposure and the investigation (the anchor seat)
General Counsel — privilege, self-disclosure strategy, and litigation risk
CFO — the approved payments, the controls that missed them, the forecast
VP of Sales — the star performer, the contract, the revenue at stake
CHRO — the retaliation claim and protecting the reporter
VP of Marketing / Communications — the press inquiry and the holding statement

Plus an observer. One person stays out of the decision-making to watch how the room actually behaves — who defers, who dominates, where the silences fall — and feeds it back in the after-action.

How the Session Runs

0–10 min · Setup & Framing

Assign the seven seats, set the rules of engagement, and establish that there is no audience and no screens to hide behind.

10–35 min · Inject 1

The 48-hour ultimatum lands. The facilitator surfaces who reaches for control and who waits to be told.

35–60 min · Inject 2

The brother-in-law link and the press inquiry. Business instinct and legal instinct start pulling in opposite directions.

60–80 min · Inject 3 & The Self-Disclosure Call

The cancel-and-sue threat and the two-hour board clock. The room has to make the disclosure decision on the record.

80–90 min · After-Action & Commitments

Written commitments are captured before anyone leaves. Named owners on every gap. A summary was drafted for the board or audit committee.

+30 days · The Check-In

A mandatory follow-up to confirm the commitments became real changes — not notes that died in the room.

Every Kit Includes Seven Deliverables

Licensed to your organization. Run by your internal facilitator. Unlimited internal use.

Facilitator Guide

Full session script with phased narration, decision points, and the patterns experienced practitioners follow — including the module for the “it would never happen here” moment.

Premium Slide Deck

32 slides sequenced to match the guide. Executive-grade design.

Role Cards

Printable, one per leadership role, with the primary concerns and predictable blind spots for each of the seven seats.

Injection Cards

Time-stamped facts that land at scripted moments — including the 48-hour whistleblower ultimatum and the Halvorne brother-in-law reveal.

After-Action Review Template

Structured form for capturing commitments live in the room.

Executive Summary Template

One-page memo for the audit committee, board, or program leadership.

30-Day Check-In Template

Status tracking against each commitment to keep the work moving.

The Gaps the Room Will Own

Each leaves the session with a named owner, because an identified gap that no one owns just documents your own negligence.

Third-party due diligence and payment controls — how an intermediary gets vetted before money moves, and what stops a payment Sales negotiated from clearing Finance unchecked.

Escalation paths that bypass the local chain — so a concern can reach Compliance without going through the manager it implicates.

The self-disclosure protocol — who decides, on what trigger, and how fast, when getting ahead of a regulator is on the table.

Whistleblower protection and anti-retaliation — how a reporter is shielded when the team can guess who they are, so the next one trusts the channel.

Crisis command and board communication — who leads, who briefs the board, and what the company says while the facts are still moving.

Designed For

Public-company and pre-IPO leadership teams with overseas revenue, government or state-owned customers, or third-party intermediaries in the sales chain. Built for chief compliance officers, general counsel, CFOs, audit committees, and boards who would rather find the governance gap in a conference room than in a subpoena.

Companion Resources

The Clean-Looking Invoice →
The front-line scenario — the analyst’s decision that begins this whole story.

Anti-Corruption & FCPA Scenarios →
The full cluster of front-line scenarios behind this risk area.

Why Compliance Should Run Tabletops →
The case for practicing the decision before the incident forces it.

Custom-Built Around Your Risk Profile

Find out who takes the wheel — before the clock is real

Every Executive Decision Lab™ is tailored to your organization’s structure, industry, and highest-risk situations. Internally facilitated by design, with an experienced outside facilitator available as an option.

Pricing: Contact Xcelus for Pricing

Talk to Xcelus →