Survey Results: Whistleblower Policies & Procedures


1. In the wake of the SEC's new whistleblower rules, our company:(Total responses: n=33)
(select only one)
n=3 (9.09%) Has changed existing policies to address the new rules
n=9 (27.27%) Hasn't yet, but intends to change existing policies to address the new rules
n=14 (42.42%) Not sure yet if will change existing policies
n=7 (21.21%) Has decided not to change existing policies because considerations under the new rules are adequately addressed by existing policies

2. The board committee charged with consideration of the SEC's new whistleblower rules is:(Total responses: n=32)
(select only one)
n=22 (68.75%) Audit Committee
n=6 (18.75%) Corporate Governance Committee
n=0 (0.00%) Risk Committee
n=3 (9.38%) Compliance Committee
n=0 (0.00%) Compensation Committee
n=1 (3.13%) Board as a whole

3. In the wake of the SEC's new whistleblower rules, our company:(Total responses: n=33)
(select only one)
n=0 (0.00%) Has provided incentives for whistleblowers to report internally first
n=1 (3.03%) Hasn't yet, but intends to provide incentives for whistleblowers to report internally first
n=20 (60.61%) Not sure yet if will provide incentives for whistleblowers to report internally first
n=12 (36.36%) Has decided to not provide incentives for whistleblowers to report internally first

4. In the wake of the SEC's new whistleblower rules, our company:(Total responses: n=33)
(select only one)
n=4 (12.12%) Has created a system to alert employees of the benefits of reporting internally (eg. sign updated employee handbook, fill out compliance questionnaires)
n=8 (24.24%) Hasn't yet, but intends to create a system to alert employees of the benefits of reporting internally
n=20 (60.61%) Not sure yet if will create a system to alert employees of the benefits of reporting internally
n=1 (3.03%) Has decided not to create a system to alert employees of the benefits of reporting internally

5. Since Dodd-Frank was enacted in mid-2010, our company has had:(Total responses: n=32)
(select only one)
n=1 (3.13%) More whistleblower claims reported internally
n=29 (90.63%) Same number of whistleblower claims reported internally
n=2 (6.25%) Fewer whistleblower claims reported internally

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