The filed complaint alleges that defendants made false statements and/or concealed that: (i) Andrew Hopkins, the Company's former Chief Executive Officer, had engaged in improper relationships with employees that were inconsistent with the Company’s standards and values; (ii) David Nicholson, former Chairman of the Company’s Board of Directors, had prior knowledge of Hopkins’s relationships and had improperly addressed Hopkins’s misconduct without consulting the Board of Directors; (iii) the Company’s maintenance and enforcement of its Code of Business Conduct and Ethics was inadequate to safeguard against the foregoing conduct; (iv) the foregoing failures subjected the Company to a heightened risk of disruptive leadership transitions and/or reputational harm; and (v) as a result, defendants’ public statements were materially false and/or misleading at all relevant times.