A company can go to extraordinary lengths to create and manage a first-in-class antibribery compliance program. It can work to send the right internal messages, nurture open communications, and be vigilant in upholding its clearly stated standards. And still, the compliance team might first read about an internal problem in The New York Times or in a letter from the U.S. Department of Justice. This is more likely than ever now that the Dodd-Frank whistleblower provisions offer a bounty of 10 to 30 percent of the ultimate fine to those providing the Securities and Exchange Commission with original information about corporate corruption.
As a practical matter, how can a company encourage employees and others with sensitive information to first report internallyquickly and fullyinstead of broadcasting the details to the world? Below are eight ways to support in-house whistleblowers at your organization:
1. Have a Clear Reporting Chain
The person reporting the information needs to be confident that the right person at the company will get the word. Companies can take steps to improve the chances that information will flow from the person reporting it, all the way to the person best able to act on it. Common missteps interrupt this chain and lead to frustration, cynicism, and worse.
