Fcpa Compliance Report

Today I want to consider some factors which can lead to employees’ distrust of an internal reporting system. Ryan Hubbs wrote an excellent article entitled “10 Factors Leading to Reporting Mechanism Distrust”.  The guidance and mandates for companies on reporting mechanism reporting are numerous, overlapping and sometimes very broad. There are the US Sentencing Guidelines; regulations under Sarbanes-Oxley (SOX), the Dodd-Frank Act and the 2012 FCPA Guidance. There are international guidelines from the EU, US and London based stock exchanges and even the United Nations deems reporting mechanism reporting a necessary good business practice. Dodd-Frank attempted to strengthen accountability by specifically providing protections for those who come forward as whistle blowers but also allows regulators to respond to misconduct through finding some legal action. While the goal of whistleblowers and reporting mechanisms might be to identify and correct wrongdoing, they do not guarantee success and they do not even gu