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their responsibility to report immediately any allegation of unlawful activityto someone in human resources or compliance.7. Act on a complaint and provide feedback to the tipster who often worriesabout what is going to happen as a result of their bringing information tothe company’s attention.8. Create a culture of integrity.9. Consider self reporting when dealing with a whistleblower. Even insituations where the company believes the complaint is untrue, orimmaterial, a company’s reporting of the allegations to the SEC first andexplaining why the allegations are unfounded may avoid or shorten whatotherwise could be a protracted investigation.10. Evaluate how to deal with the individual who made the complaint. Takesteps to ensure the whistleblower is treated the same as all others underthe company’s policies.11. Review and evaluate company contracts. Some companies require theiremployees to execute employment agreements or non-competitionagreements which contain as a condition of employment a requirementthat employees make an internal complaint of wrongdoing prior to going toan outside agency.While there may be situations where suchagreements would be considered enforceable, the SEC and othergovernment agencies have taken the stance that such an agreement is an

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