“We were only doing what was expected from us” might be the answer from those involved in the initial discussion. It’s a justification addressed at the bosses, it’s saying, ‘you didn’t spell out what’s not on’ or ‘you asked us to go along with dodgy payments and cover them up with legitimate names’.
The question to them might have been: “Why did you sign off on payments that meant that consumers bought products that new environmental legislation considered too dangerous?” And that’s the answer you are getting.
That answer doesn’t mean that those involved escape fines or prison. Then again, the outcome of the internal investigation could be embarrassing enough to those involved, if it finds that they weren’t great business people “optimising” products, they just dodged the system.