Just out of curiosity, what do the orgies have to do with prison time? Are orgies at work illegal?
Besides professionalism, it's just plain stupid. What happens if a participant claims they were pressured into it for the sake of a promotion, or for the sake of not being fired, or for the sake of not losing their visa? The result would be a disaster. This is also so predictable, that maybe an investor could claim legal negligence.