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Best practices when handling whistleblower complaints
Journal of Financial Compliance,
7
(1),
46-52
(2023)
Abstract
This paper is intended to serve as an initial guide for members of public companies on creating company whistleblower policies and procedures for the investigation of employee whistleblower complaints. Companies should establish clear internal policies for how employees can make whistleblower complaints, who should receive those complaints, how to investigate those complaints (whether internally or externally) and how the results of the investigation should be reported or shared with others.
Keywords: whistleblower; whistleblower complaint; regulatory; regulatory investigation; internal investigation; internal complaint; compliance
The full article is available to subscribers to the journal.
Author's Biography
Tracey Salmon-Smith a trial attorney, is a trusted adviser and pragmatic problem solver who assists clients with commercial and business disputes, employment litigation, securities law and internal investigations. As a former assistant United States attorney who also spent several years as in-house counsel for a global financial services firm, Tracey knows firsthand the pressures and challenges her clients face. Tracey is known for her composure under pressure and her commitment to achieving results. In 2022, she was inducted as a Fellow of the American College of Trial Laywers, an honour bestowed on less than 1 per cent of attorneys in the United States and Canada.
Sandra D. Grannum is a trial attorney and co-chair of both the firm's nationwide financial services litigation practice group and a member of the financial services industry team. She is a former in-house Wall Street counsel who ensures that her analysis of her clients' cases includes careful evaluation of their litigation exposure, reputational risk and budgetary concerns. Sandy concentrates on the securities industry representing broker-dealer arbitration, litigation, mediation and regulatory defence. She also concentrates more broadly on securities law, and clients turn to Sandy for complex securities litigation, including securities class actions, shareholder clawback adversarial proceedings and takeover, business judgment rule litigations. She defends employment cases and conducts whistleblower and discrimination claim internal investigations. Sandy is also a fellow of the American College of Trial Lawyers.
Jesse Linebaugh is a trial attorney and co-chair of both the firm's nationwide financial services industry team and the firm's securities and financial services litigation practice group. He handles matters throughout the US. Jesse concentrates on the securities industry representing broker-dealer arbitration, litigation, mediation and regulatory defence. He also concentrates more broadly on securities law representing clients in single plaintiff and class action cases for complex securities litigation, including securities class actions. He also handles noncompete litigation and internal investigations, and he represents insurance and annuity companies, banks and broker-dealers.
Vijayasri G. Aryama assists clients with various aspects of legal proceedings and trial preparation, including legal research and the drafting of motions and other legal memoranda and second chairing trials and arbitrations. While attending Rutgers Law School, Sri interned at the Department of Homeland Security in the Immigration and Customs Enforcement division and served as a research and technology editor for the Women's Rights Law Reporter.
