Daily news, documents and intelligence about Offshore Financial Centers and those who conduct business in them that you will not find anywhere else.
RSS Feed Print
SEC Whistleblower Program
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


Jump to different Forum... 

We hunt for red flags in high-value, cross-border finance by monitoring offshore and onshore courts, regulatory actions, offering documents, and other sources - and email you the results.

View Recent Digests

Cayman Court Secrecy: A Huge Red Flag for Foreign Investors & Clients
David Marchant
As any fule kno, the biggest enemy of fraud, corruption, money laundering, and other forms of financial crime is transparency, while their best friend is secrecy. That's why the unprecedented mass sealing of cases that's taking place at the Financial Services Division of the Grand Court of the Cayman Islands is repugnant to anyone with a genuine concern for financial crime.