This matter presents a verified documentation-integrity breach involving a manager-generated performance record authored on April 14, 2025—four days after the underlying April 10 meeting. A verbatim audio recording of that meeting confirms that several statements appearing in the April 14 document were never spoken, directly contradicting multiple assertions and creating direct discrepancies between the written narrative and the contemporaneous source record.


Although informally formatted, the April 14 entry functioned as a manually developed IPE (Information Produced by the Entity) under Boston Scientific's SOX-aligned 2024 training framework. The record existed solely within email accounts, was unilaterally created, and was subsequently referenced in later HR and managerial communications without correction or qualification despite evidence contradicting its accuracy.

Because the 2024 performance rating had already been communicated in March—before the April 14 document was authored—the April 14 narrative cannot be considered contemporaneous. It operated as a post-hoc justification, later incorporated into official documentation streams and relied upon as if it represented an accurate account of the April 10 meeting, despite contradicting the audio record. The subsequent use of this unverifiable, after-the-fact record in performance-management interactions is consistent with pretextual documentation.

The falsified document was subsequently relied upon in performance appraisal communications and downstream HR actions (including ongoing PIP trajectory and subsequent performance documentation) despite contradicting the audio record. While not formally categorized as a controlled document, its use as a managerial input influencing compensation and HR determinations places it squarely within internal-control expectations relating to accuracy, completeness, attribution, and traceability, including:

• ISO 13485 / ISO 9001 — obligations for authenticity, accuracy, and traceability of documented information supporting personnel competence and managerial oversight
• SOX 302 / 404 Principles — completeness and accuracy requirements for information produced by the entity (IPE) when used in processes influencing compensation, escalation, or decision-making
• Internal Code of Conduct Standards — accuracy and integrity in managerial reporting

These issues did not arise in isolation. The accompanying materials document a sustained pattern of mischaracterization over the preceding twelve months, during which the managerial narrative progressively diverged from contemporaneous facts. This pattern clarifies managerial motive and provides the factual context in which the April 14 record was created.

What began as a correctable managerial irregularity escalated into an integrity issue once the inaccurate April 14 narrative was circulated, relied upon, and later maintained after formal notice of its inaccuracy. At that point, the matter transitioned from individual misconduct into organizational ratification, implicating documentation integrity, internal controls, and fiduciary oversight obligations.

Why this is an executive-level issue
After the matter was escalated, corporate leadership elected not to initiate an investigation or amend the inaccurate record, despite being provided with audio-verified evidence directly contradicting the manager's written account. In a regulated environment, such inaction transforms a managerial falsification into a governance and internal-controls failure, with cascading implications:

1. Documentation Integrity Failure – A verified misrepresentation remained uncorrected in official HR records, implicating ISO 13485/9001 quality-system requirements for record accuracy, attribution, and traceability.
2. Internal Controls Exposure – Post-hoc documentation used to justify adverse actions constitutes a potential internal-control weakness under SOX 302/404, as the company's documentation workflows permitted a non-contemporaneous, inaccurate record to be adopted as authoritative.
3. Leadership Oversight Failure – The Company's inaction after receiving formal notice reflects a breakdown in director-level oversight obligations, raising potential exposure to reputational, regulatory, and shareholder risk arising from documented falsification and retaliatory escalation.

These variances constitute a substantiated misrepresentation in a certified HR record, confirmed through direct comparison with contemporaneous audio evidence. Once escalated to leadership and left uncorrected, the issue extended beyond HR procedures into enterprise-level integrity and governance, potentially compromising the reliability and accuracy of certifications and Executive attestations aligned with respective standards and governance frameworks.

What occurred
A Boston Scientific manager authored an official performance document containing statements demonstrably contradicted by a verbatim audio recording of the underlying meeting. The recording establishes direct contradiction on key points, confirming that the document does not reflect what was said or agreed. Because it was drafted after the rating cycle had closed, the April 14 document constitutes a retroactive justification later incorporated into decision-making workflows.

When the employee raised concerns about unequal treatment, non-competitive promotions, and advancement patterns inconsistent with those of similarly situated peers, his protected activity was followed by additional negative documentation—further intertwining the documentation failure with concerns of retaliatory escalation. Despite a detailed evidentiary submission and formal appeal delivered to executive leadership on May 7, 2025, no corrective action followed.

The absence of corrective action after verified notice eliminated the distinction between individual misconduct and organizational adoption of the inaccurate record.

Scope and Structure
Primary Focus: Documentation integrity, escalation chronology, and post-notice continuation of reliance on a disputed, inaccurate record.

Supporting Materials: Audio evidence, contemporaneous correspondence, and follow-on performance documentation demonstrating cumulative impact.

Additional Artifacts: A factual discrepancy matrix comparing the manager-authored IPE to the verbatim transcript; evidence of organizational notice and non-remediation; a compliance mapping to ISO 13485, SOX 302/404, and internal-control expectations; a witness matrix identifying individuals with direct knowledge, escalation receipt, or downstream reliance.

Interpretive Guidance
Readers should view this content as a structured evidentiary map documenting a clear pattern of misrepresentation regarding employee work contributions and performance (including the FDA Pre-Submission consultation, Coiling Plate design mischaracterization, and managerial abandonment at a critical design meeting), which culminated in the deliberate creation and corporate adoption of an inaccurate managerial record. The evidence reflects not only individual misconduct but also a failure of managerial candor, in which the Company's internal oversight failed to investigate and subsequently adopted as the official corporate position—matters that extend well beyond HR procedures into executive-level governance.

Any falsified management-generated record used in decision-making—whether within HR, Quality, or Operations—undermines the reliability of the Company's documentation environment and represents a system-level control failure.

Closing Statement
Throughout this process, every action has been taken with deliberate restraint and discretion. The objective has never been punitive or adversarial, but to ensure that the documented discrepancies are understood accurately and resolved appropriately. The evidence has been compiled methodically to preserve factual integrity and protect the Company's interests as much as my own.

The materials contained in this briefing provide a comprehensive record of events, supporting documentation, and corroborating evidence sufficient for executive review and ensure complete visibility into the factual record, the nature of the discrepancies, and the control-relevant implications of the ratification sequence. It offers no conjecture and makes no recommendations. It presents the evidence as it exists.