Helpline Usage (or Lack Thereof)
What's Going on With Whistleblower Lines
Whistleblowers: Don't Drink the Government's Kool-Aid
Andy Dunbar and Nick Morgan on What the SEC Expects from Your Internal Investigation
Compliance into the Weeds: Episode 118-Hotline Metrics
Compliance into the Weeds-Episode 40, COSO ERM Framework Update
Day 22 of One Month to Better Compliance Through HR-10 Questions to Better Operationalize Compliance
Day 15 of One Month to Better Compliance Through HR-Employment Separation Issues
The Department of Justice (DOJ) signaled it will soon join the list of government agencies to have implemented a whistleblower rewards program, putting further pressure on companies to have in place an effective compliance...more
If you find yourself thinking, “there are so many whistleblower stories in the news these days,” you’re not wrong. From historic awards being distributed from the U.S. Securities and Exchange Commission (SEC) to the EU...more
Recently the chief compliance officer of a global company asked me: does a company need a telephone-based whistleblower hotline anymore? In our all-technology, all-the-time world, could a company phase out telephone hotlines...more
Employment separation and layoffs can present some unique challenges for the compliance practitioner. Employees can use layoffs to claim that they were retaliated against for a wide variety of complaints, including those for...more
About two years ago, the Securities and Exchange Commission (SEC) made history when it brought the first “pretaliation” whistleblower enforcement action against KBR Inc., a technology and engineering firm in Houston. The...more
If compliance officers ever needed one more sign about the importance of anti-retaliation programs, it arrived on September 29, 2016. On that day, the Securities and Exchange Commission (SEC ) fined a company that makes...more
“A culture of ethics ties long-term performance to the interests of long-term stakeholders.” — Larry Fink, Chief Executive of Blackrock The quote above was mentioned by Timothy Erblich, CEO of Ethisphere, at the...more
The FCPA Guidance has about as clear, concise and short a statement about hotlines than any other Tenet of an Effective Compliance Program. It states, “An effective compliance program should include a mechanism for an...more
On August 4th, the SEC delivered new guidance designed to answer once and for all one of the most important concerns of a potential whistleblower: “Where must I report to obtain protection from retaliation?” When...more
FCPA settlements carry with them a basket of compliance and enforcement lessons. The recent Goodyear settlement with the SEC for $16 million carries some important compliance and strategic reminders for ethics and compliance...more