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too many management teams considered compliance a non-revenue generating and, atbest, tolerated function. The role that compliance plays in assisting management insourcing and resolving potential whistleblower claims is changing rapidly. Companieslooking to reduce risk of exposure to risks in this arena must ensure that they havequalified compliance personnel on board and give them the resources and authorityneeded to do their job. Understand that compliance is viewed by employees as atrusted and unbiased resource where concerns can be aired. In addition, topexecutives and board members need to do more to assist compliance in promoting thecommitment to doing what is right and correcting issues of concern. Top levelassistance to compliance is particularly valuable in connection with communications thatallow employees to better understand they are encouraged, if not expected, to reportconcerns and can do so without fear of repercussions.E. Adopting the Lessons of Whistleblower and Other RelevantEnforcementsReported cases and settlements offer valuable information that assist managers inunderstanding the reasons whistleblower claims arise in similar settings and how thoseproblems could have been averted. These materials also help management to betterunderstand the compliance expectations of enforcement authorities involved in thereview of problems brought forward by whistleblowers. Understanding what cases arebeing pursued, how they are resolved, and what sanctions follow when compliancemechanisms are deficient, in particular the mishandling of internal compliance reporting,help similar companies take steps to avoid similar fates. Settlements often address thecompliance program elements found lacking, such as deficiencies in or the absence of20

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