Minimizing whistle-blower risks: 10 best practices
Reprints
Experts have several recommendations for firms to follow to avoid SEC scrutiny in light of the Dodd-Frank Act's whistle-blower provision:
• Examine hotline and reporting procedures to ensure the company is getting information about wrongdoing early enough.
• Encourage workers to use the internal procedures.
• Conduct internal investigations, perhaps by an independent third party.
• Consider improved promotion of the hotline program.
• Introduce more training and orientation to employees.
• Reassure workers they will not be retaliated against if they report wrongdoing.
• Reward whistle-blowers who report problems internally.
• Periodically survey compliance programs to monitor their effectiveness.
• Establish an ombudsman program.
• Exercise greater diligence in hiring practices to avoid potential whistle-blowers.
