Business Ethics Now 3rd Edition by Andrew Ghillyer

Exercise 57

Galaxy Mining's Indaba copper mine recently experienced its third accident in the three years that the mine has been operating. Several miners were injured but, fortunately, none seriously. However, during the accident repair process (which was accelerated to get the mine up and running as quickly as possible), one of the retaining walls for the mining blade coolant runoff was damaged, allowing several thousand gallons of chemical sludge to seep into the local river.
To manage the media response to the accident, Galaxy contracted the services of John "Monty" Montgomery, a self-proclaimed "specialist in local public relations and consulting services." Monty billed Galaxy for $1 million in advance as his standard retainer fee, which was paid without question.
Montgomery took control of the Indaba situation quickly, issuing several authoritative press releases committing Galaxy Mining to prompt and full restitution for any damage done by the leak. Thirty days later a press conference was arranged to announce the construction of a new water treatment facility (funded by Galaxy) that, to quote Montgomery, "will guarantee fresh, clean water for local residents for generations to come." The Indaba leak was never mentioned in the local press again.
When Galaxy's auditors requested more detail on the services provided by Montgomery's organization during a routine audit several months later, he responded with an e-mail confirming that the $1 million was "for services rendered in the management of the Indaba mining incident." No further explanation or documentation was provided.

What kind of policies should Galaxy Mining put in place to make sure these kinds of "services" aren't utilized again