In the most recent issue of the SCCE, Compliance and Ethics Professional Magazine, Issue 08/2011, is an article entitled “Foxes and henhouses: The importance of independent counsel”, in which author Dan Dunne discussed what he termed a “critical element” in any whistleblower response, which is a “fair and objective evaluation.” Dunne wrote that a key component of this fair and objective evaluation is the WHO question; that is, who should supervise the investigation and who should handle the investigation? Dunne’s clear conclusion is that independent counsel should handle any serious investigation.