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SEC Whistleblower Program
Anonymous
Posted: Saturday, August 13, 2011

Posted: 10/29/2010 11:29:56 AM

By: George

Many people have been asking me if they should report fraud via internal channels. This can obviously lead to loss of employment for blowing the whistle. I tell them this...

(1) Are the internal corporate whistleblower policies formally memorialized in your employment manual and policies and does the corporation specifically state in writing that you cannot be harassed, demoted, mistreated or terminated if you report facts that may amount to corporate misconduct? No wiggle words. No legalizes.

(2) Does the human resources department run the internal corporate whistleblower program? If so, I would be concerned. With apologizes to the many great HR executives out there, HR reports to management and that management may have a vested interest in the misconduct. In a large corporation, the HR executive operating in a subsidiary or a remote location is often times hired by the manager running the subsidiary or off-site location. That HR executive reports to that manager. The solid corporate whistleblower programs that I have seen are independent of HR and report to either a specific executive tasked with investigating fraud or even a committee of the Board of Directors.

(3) Are there examples of fellow employees successfully using the corporate whistleblower program? If so then this may be a good indication of its value.

(4) How actively does the corporation promote its whistleblower policies to the employees? Active, open communication of the program may be a strong sign of that program’s effectiveness.



Internal Administrator
Posted: Saturday, August 13, 2011
Joined: 10/12/2010
Posts: 5780


Posted: 10/29/2010 11:27:09 AM

By: George



SEC Whistleblower Program


 

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