Given the lottery-like nature of the $14 million dollar bounty, employers should expect more employees to disclose potential misconduct to the SEC rather than reporting internally. As the number and value of whistleblower awards increases, it further underscores the need for corporations to be as proactive as possible in ensuring that compliance programs and training are robust and up to date. Companies must also encourage employees to report misconduct internally by countering two of the forces likely to push employees towards external reporting — fear of retaliation if they report internally and a belief that internal reporting is ineffectual and unlikely to generate change. It is only through this type of robust compliance that companies can effectively ensure that would-be whistleblowers report internally rather than to the government.
via “Show Me the Money” or 14 Million Reasons to Upgrade Your Compliance Program — BakerHostetler
