TheCorporateCounsel.net

The announcement of a new DOJ pilot program for whistleblower awards, combined with the continued effectiveness of the SEC’s whistleblower program (a few weeks ago the SEC announced a $37 million award to a whistleblower) leads one to the inevitable question, what should companies do now in light of these developments?

I think it is a good time to take a close look at your company’s whistleblower program and processes to carefully assess whether it provides potential whistleblowers with a fair and effective process for receiving and acting on complaints, so that whistleblowers feel comfortable raising their issues internally rather than running straight to the government. While it should always be clear that an employee can go to the government with their concerns, one would hope that employees only see that option as a last resort. By having an effective internal process that ensures anonymity and prompt and appropriate follow-up (combined with an appropriate tone-at-the-top), a company can create a reporting culture that encourages an internal dialogue.

I encourage you to check out all of the great resources that we have posted in our “Whistleblowers” Practice Area. If you do not have access to all of the useful resources that we have in our Practice Areas, become a member of TheCorporateCounsel.net today by visiting our online store.

– Dave Lynn