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B. Fleshing Out Potential Problems and WhistleblowersAs discussed above, the growing numbers of enforcement programs relying on andseeking to reward whistleblowers is making it ever more difficult to convince employeesto report problems internally. Without an advertised commitment to compliance asshown from the top company officials down, and a supporting environment that actuallyconvinces employees that the reporting of concerns is welcome and expected, there isnot a chance of success. Companies should consider facilitating the internal reportingof problems through means including the following:• Internal promotion of the compliance commitment and openness of thecompany to receiving reports of concerns at all levels.• Creation of incentives for the reporting of compliance related concerns orproblems, including the addition of compliance reporting to performanceand compensation review criteria for managers.• Internal messaging, from the top of the company, emphasizing thecommitment to ensuring that reported concerns will be addressed properlyand reporters will be protected from retaliation of any kind from any levelof the company.• Tracking and documentation of hotline and other reporting by employeesand monitoring of internal reporting mechanisms to ensure reporting isactually working at levels in line with the company size and risk profile.16