TheCorporateCounsel.net

February 2, 2015

Survey Results: Whistleblower Policies & Procedures

Here are the survey results from our recent poll about whistleblower policies & procedures:

1. Over the last year, when it comes to our whistleblower policy, our company:
– Has changed existing policies to address the latest whistleblower developments – 12%
– Hasn’t yet, but intends to change existing policies within the next year – 24%
– Not sure yet if will change existing policies – 24%
– Has decided not to change existing policies – 41%

2. The board committee charged with consideration of the SEC’s whistleblower rules is:
– Audit Committee – 94%
– Corporate Governance Committee – 6%
– Risk Committee – 0%
– Compliance Committee – 0%
– Compensation Committee – 0%
– Board as a whole – 0%

3. Our company:
– Has provided incentives for whistleblowers to report internally first – 0%
– Hasn’t yet, but intends to provide incentives for whistleblowers to report internally first – 6%
– Has decided to not provide incentives for whistleblowers to report internally first – 94%

4. Our company:
– Has created a system to alert employees of the benefits of reporting internally (eg. sign updated employee handbook, fill out compliance questionnaires) – 28%
– Hasn’t yet, but intends to create a system to alert employees of the benefits of reporting internally – 6%
– Has decided not to create a system to alert employees of the benefits of reporting internally – 67%

5. Since the SEC adopted its whistleblower rules, our company has had:
– More whistleblower claims reported internally – 0%
– Same number of whistleblower claims reported internally – 100%
– Fewer whistleblower claims reported internally – 0%

Take a moment to participate in our “Quick Survey on Shareholder Engagement” and our “Quick Survey on Conflict Minerals.” I also just posted this “Quick Survey on Currency Fluctuations for Incentive Compensation.”

Simplifying D&O Questionnaires: Going Electronic

In this podcast, Russell Maher of QDiligence explains how electronically organizing your D&O questionnaires provides benefits, including:

– What does QDiligence do?
– What is the process to move a company’s D&O questionnaires online?
– Companies often have questionnaires that are personalized and have attachments and appendices. How do those work online?
– Can companies pre-populate the responses? If they do pre-populate, how do they know what they changed?
– Can companies print the questionnaires that are electronic?

Our February Eminders is Posted!

We have posted the February issue of our complimentary monthly email newsletter. Sign up today to receive it by simply inputting your email address!

– Broc Romanek