Compliance requires lots of mid-course corrections. Those corrections are based on constant feedback that’s honest and accurate. That’s why attempts to impede feedback and complaints are always bad for compliance. And yet, confidentiality agreements (in their many different forms) are everywhere.… Continue Reading
Posts Tagged: Retaliation
The perception within many organizations is that a limited number of complaints being reported equals fewer problems. So it often becomes a conversation about the numbers. But do many complaints mean many problems, and do fewer complaints mean fewer problems?… Continue Reading
Since 2001, private Italian companies have been encouraged — through legislative initiatives — to adopt and implement robust compliance programs. Legislative Decree No. 231 of June 8, 2001 (commonly referred to as “Law 231”) allows private companies that chose to adopt specific compliance programs and mechanisms to avoid corporate liability where certain offenses are committed in the interest of the corporation by its directors or employees. … Continue Reading
On November 28, 2017, the Supreme Court will hear arguments in Digital Realty Trust v. Paul Somers on the question of whether the whistleblower protections of the Dodd-Frank Act extend to internal whistleblowers, or only to those who report to the SEC.… Continue Reading
A federal jury in San Francisco took just three hours Monday to decide that Bio-Rad Laboratories Inc. retaliated against former general counsel Sanford “Sandy” Wadler for reporting FCPA violations.
The jury awarded Wadler $2.9 million in back pay and stock compensation and $5 million for punitive damages.… Continue Reading
HomeStreet Inc. settled SEC allegations Thursday that it conducted improper hedge accounting and later took illegal steps to impede employees from talking to the SEC about it.
The bank agreed to pay a $500,000 penalty without admitting or denying wrongdoing.… Continue Reading
After a lengthy legislative process between the National Assembly and the Senate, Sapin II, the French anti-corruption law focused on transparency and modernization of economic activity, was passed, in its final form, by the National Assembly on November 8, with a majority vote of 308 to 171.… Continue Reading
The U.S. Securities and Exchange Commission has warned investment advisers and broker-dealers to comply with the Dodd-Frank whistleblower-protection rule.
The SEC’s office of compliance inspections and examinations said in a risk alert (pdf) it will look for illegal restrictions on individuals communicating with the SEC about potential securities law offenses.… Continue Reading
Spain is in the grip of a massive corruption scandal. A trial began this month in which some of the highest-ranking former lawmakers and officials of the ruling Popular Party (PP) are facing .… Continue Reading
The SEC last week brought its first enforcement action based solely on retaliation against a whistleblower. Casino-gaming company International Gaming Technology (IGT) agreed to pay a $500,000 penalty to settle the SEC’s enforcement action.… Continue Reading