The SEC rule requires no such thing: Dodd-Frank prohibits retaliation against whistleblowers, and the SEC rule says companies can’t “take any action to impede” whistleblowing by, for example, enforcing a confidentiality agreement against a whistleblower. But the rule doesn’t say that whenever you have a confidentiality agreement, you have to tell employees that federal law enforcers have open access to company secrets.
‘Enforcement 40’ for 2020
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