Adopt an Internal Whistleblower Policy


It is highly recommended for companies and organizations to implement a strong internal whistleblower policy. The primary reasons for a corporate whistleblower system are to protect the company and its chief executive officer and chief financial officer from criminal indictment and the ensuing penalties and to protect the shareholders from losses of their equity interests. 

To enhance our understanding of how internal whistleblower programs operate, we will examine three corporate whistleblower policies.

Daimler’s Business Practices Office Whistleblower System

In 2006, Daimler established a whistleblower system for employees to report incidents of breaches of laws or internal regulations to the Business Practices Office (BPO).  The BPO is the company's place for receiving reports of severe breaches which can damage the business such as bribery, accounting violations and breaches of antitrust law. Daimler ensures confidentiality while preserving fairness to the whistleblowers and those impacted by the accusations.

ArcelorMittal's whistleblower procedure

Pursuant to the Sarbanes Oxley Act of 2002, ArcelorMittal developed its whistleblower procedure to identify any major issues concerning improprieties in accounting, auditing or banking — the whistleblower process does not handle general business complaints or employment grievances. Reports are immediately channeled to the Chairman of the Board’s Audit Committee, the Secretary of the Board’s Audit Committee and the Company Secretary. The Director of Internal Assurance will conduct an investigation and issue a report to the Audit Committee. ArcelorMittal's whistleblower policy will maintain confidentiality throughout the process. In addition, the company is dedicated to protecting any employees who have, in good faith, reported through the process, from retaliation.

TD Bank Group Whistleblower Hotline

Committed to achieving success through conducting its affairs to the highest standards of ethics, fairness and law, TD Bank Group (TD) created an independent, confidential reporting center for financial and ethical complaints. The TD Whistleblower Hotline is for any employee complaints of breaches of the company code or concerns of TD accounting and auditing matters. Where local laws permit, complaints may be made anonymously. 

Even when a company has an internal whistleblower procedure, state and federal whistleblower laws apply to protect employees or citizens from retaliation.  If you have risked your position to report violations of laws, regulations or company policy, it is recommended that you consult with a Dallas whistleblower attorney.

Topics:  CEOs, CFOs, Corporate Counsel, Retaliation, Whistleblower Protection Policies, Whistleblowers

Published In: Business Organization Updates, Labor & Employment Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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