VIOLATION OF CORPORATE POLICIES FOR INDEPENDENT CONTRACTORS

Amtrak paid over $141,000 to a retired Amtrak claims representative to do work for the Claims Department. A manager in the Amtrak Claims and Tort Litigation group circumvented and violated Amtrak policy by directing persons to facilitate this work without a contract with Amtrak. The arrangement included the use of two Florida law firms to provide "pass-through" billing services for the former Amtrak employee.