Whistleblowers Gone Global – International Implications of the Dodd-Frank Whistleblower Programmes

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Organisations in the U.K. breathed a collective sigh of relief this summer when the commission formed by the Bank of England and the U.K. Financial Conduct Authority (FCA) recommended against the implementation of U.S.-style whistleblower bounties in the U.K. However, the latest annual report from the U.S. Securities and Exchange Commission (SEC) has put the spotlight back on international whistleblowers.

The SEC reported that in 2014:

  • Tips were received from individuals in 60 countries outside the U.S.
  • Non-U.S. reports accounted for an astounding 11.5% of total tips received
  • The U.K. leads in international reports at 70 reports with India and Canada close behind with 69 and 58 respectively
  • This year also saw the SEC award the highest-ever bounty, $30M USD, to a whistleblower located outside the U.S.

These statistics not only illustrate the strong global reach of the SEC, but also underscore the importance for global organisations to have strong whistleblower compliance programmes.

There is even more at stake than the risk employees reporting to the U.S. government. The U.K. government is expected to initiate regulatory changes that require organisations to have effective mechanisms for employees to raise concerns and be protected from retaliation. Further, Transparency International has been continuously lobbying for greater whistleblower and retaliation protections in the E.U., helping to pass legislation like Ireland’s Protected Disclosures Act 2014.

In today’s global regulatory landscape, organisations must foster a strong culture that encourages employees to raise concerns internally without fear of retaliation and vigorously investigate and take action against substantiated reports. Coupling whistleblower hotlines and report forms with a robust incident management platform helps to ensure that all reports are consistently captured and offers a consistent workflow for incident resolution.  As importantly, organisations must communicate its values to empower employees to report incidents through periodic training and distribution of whistleblowing policies.

Image Courtesy of Dreamstime

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