1E9Ct5D

company’s commitment to compliance or has not previously been brought to theattention of management. The form also provides for other options in cases where anindividual has concerns or information that has not been reported internally, andrequires the disclosure of any such matters.These additional compliance checks and certifications have been found to be veryeffective in ferreting out additional unreported concerns that could develop intowhistleblower claims or problems.All of these types of efforts have been proven to help reduce instances whereemployees resort to the external reporting of matters that may be ultimately successfullyresolved, but only after prolonged and costly enforcement review.C. Evaluating the Whistleblower and Enforcement RiskEnvironmentIn many ways, the risk of enforcement is growing for all businesses as whistleblowersand the government pursue cases in a wider variety of fields, under laws including theFCA but extending to anti-corruption laws, tax laws, securities laws, and consumerfraud and environmental laws. Determining the effective compliance measures that willtruly reduce exposure to whistleblowers and related investigation and enforcementaction is another daunting task. And not all risks warrant the same level of concern orattention. The current enforcement climate, however, offers little comfort from the factthat one is a smaller company, operating only domestically, and with fewer resourcesthan the companies in the headlines. Today, we see companies expending more timeand attention to the evaluation of risk associated with their business and practices, with18