"Michelin (China) Investment Co., Ltd. was found to have violated Chinese law by implementing a rebate scheme under which third-party distributors were awarded points for facilitating sales of Michelin tires. Distributors could use these points to redeem merchandise, including Amazon gift cards, from the Michelin Distributor Club website. Michelin China recorded the gift cards as “sales expenses” and did not issue any related invoices. The distributors were not required to, and did not, record their receipt of the gift cards in their books and records. Since the third-party distributors typically sold several tire brands other than Michelin, the SAIC found that Michelin China’s scheme violated the Chinese Anti-Unfair Competition Law because it was improperly designed to increase sales revenue by squeezing out competitors. Additionally, the government found that the monetary value of the incentives was enough to adversely affect market order, thus constituting commercial bribery. Penalties included disgorgement of RMB 18,442,865.44 and a fine of RMB 160,000."