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The Sarbanes-Oxley Act of 2002, enacted in the wake of major corporate accounting scandals at companies such as Enron, WorldCom and, yes, Tyco International, established a multiprong approach to protect shareholders of publicly held companies from corporate greed. Congress included in the act a whistleblower protection provision, Section 806, that made it illegal for a publicly traded company to take an adverse personnel action against an employee because that employee engaged in "protected activity," such as reporting fraud against shareholders. Congress correctly recognized that individuals with the most information about company fraud are often current employees who require robust legal protections to be able to report fraud without fear of reprisal.

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