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1 2 3 4 5 6 7 8 9 * 0 # Now dialing: Whistleblower line 1. Establish tone at the top. Establish and communicate the organization’s support for ethical behavior and internal disclosures. 2. Put clear procedures in place. The process of reporting, and the way the company investigates such reports, should be set out clearly. 3. Ensure timely response. Set out and adhere to a clear, efficient timeframe in the investigation. 4. Implement internal controls. Internal controls are key in detecting fraud: failure to follow such controls is a red flag that something or someone has gone astray. 5. Establish an anti-retaliation policy. Many people do not report wrongdoing because they fear retaliation. Encourage employees to speak up via clear, protective anti-retaliation policies. Did you know that only 8 percent of employees report wrongdoing externally without first reporting it internally? Yet, when a frustrated whistleblower does turn to government regulators, the outcome can be harsh. Government enforcement actions that rely on whistleblowers can result in penalties as much as $92 million greater and prison sentences up to 27 months longer than if no whistleblower was involved. To avoid these harsh consequences, the wise organization encourages a culture in which internal whistleblowing is accepted. Here are five steps to consider. www.dlapiper.com Published by DLA Piper LLP (US) Copyright © 2014 DLA Piper LLP (US) All Rights Reserved. This bulletin is intended as a general overview and discussion of the subjects dealt with. It is not intended, and should not be used, as a substitute for taking legal advice in any specific situation. DLA Piper will accept no responsibility for any actions taken or not taken on the basis of this publication. Pursuant to applicable Rules of Professional Conduct, it may constitute advertising. Circular 230 Notice: In compliance with US Treasury Regulations, please be advised that any tax advice given herein (or in any attachment) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding tax penalties or (ii) promoting, marketing or recommending to another person any transaction or matter addressed herein. You are receiving this communication because you are a valued client or friend of DLA Piper. DLA Piper LLP (US) is part of DLA Piper, a global law firm, operating through various separate and distinct legal entities. Further details of these entities can be found at www.dlapiper.com. All rights reserved. To unsubscribe from this mailing list, reply to this message with REMOVE in the subject line. DLA Piper LLP (US) | MRS000024390 5 STEPS TO ENCOURAGE INTERNAL WHISTLEBLOWING For more information, please contact Savaria B. Harris. Learn more about encouraging internal whistleblowing
