Five Important Steps in Putting Together a Whistleblower Compliance Program
The stakes are high. Everyone knows that. The FCPA paparazzi likes to write about the importance of creating compliance programs to address the real risk to companies of SEC whistleblowers. Everyone agrees on the basic list of compliance improvements: changing the corporate culture and seeking to persuade the whistleblower to believe in the corporation’s commitment to responding to the whistleblower’s specific complaint. All that is...