I ran across a few examples of whistleblower policies and whistleblower protection policies and some material on developing a whistleblower policy. Developing a Policy Developing a Whistleblower Policy (.pdf) by the Delaware Valley Grantmakers. Whistleblower Policies: Lessons For Associations by Julia E. Judish of Pillsbury Winthrop Shaw Pittman LLP National Whistleblowers Center Whistleblower Policy Safeguards
Grant Thornton put together a comprehensive report: Hear that whistle blowing! Establishing an effective complaint-handling process. (August 2006, .pdf) They have developed the MACH process which consists of six basic steps: Receive the complaint; Analyze the complaint; Investigate the complaint; Resolve the complaint; Report the resolution of the complaint; and Retain the necessary documentation.
A corporate code of ethics is the flip side of the coin of a whistleblower policy: The code of ethics is the principal means of communicating to all staff a strong culture of legal compliance and ethical integrity, while the whistleblower policy is a way to implement such values.
LRN published the transcript of a presentation by Dov Seidman at the Center for Business Ethics at Bentley University: The Power of How: Achieving Enduring Success Through Ethics. Basically, in a world in which nothing stays hidden, you have to act as if you have nothing to hide. But before you can act as though
Back in 2004, The Nature Conservancy created the job of Chief Compliance Officer and formalized is compliance and governance policies. There is an interview with Karen Berky, Chief Compliance Officer in The Nature Conservancy’s 2004 Annual Report: Conservation That Works. Ms. Berky talks about the Conflict of Interest Policy and the Conflict of Interest Standard
Rule 204A-1 under the Advisers Act requires investment advisers to adopt a code of ethics. Adoption means establish, maintian and enforcing a written code. At a minimum, the code must include: (1) A standard (or standards) of business conduct that you require of your supervised persons, which standard must reflect your fiduciary obligations and those
The Staff of the Securities and Exchange Commission’s Division of Investment Management and Office of Compliance Inspections and Examinations put together an information overview for Newly-Registered Investment Advisers. It is intended to assist newly-registered investment advisers in understanding their compliance obligations with respect to these provisions. This information sheet also provides information about the resources
Republican fundraiser Harry Sargent III is subject to a suit from Supreme Fuels that Sargent’s company International Oil Trading Company made illegal payments to Jordanian officials. IOTC has an exclusinve license to move military fuel through Jordan. IOTC’s response, according to the NBC News Investigates story: . . .in an email to NBC News, a
In a news release, the Financial Crimes Enforcement Network (FinCEN) announced the publication of a proposal to simplify its rules and regulations by centralizing them in its own new chapter of the Code of Federal Regulations. The current organizational structure of FinCEN regulations developed over many years, during which Congress expanded FinCEN’s authority . As
The Commerce Department’s International Trade Administration (ITA) has developed a certification mark for the U.S.-European Union Safe Harbor Framework. The mark may be used by companies on their websites to signify that they have self-certified compliance with the provisions of the Safe Harbor Framework. To display the certification mark, you must follow the Safe Harbor