Michael E. Clark, Laurence S. Lese and F. Reid Avett
Recently, the US Securities and Exchange Commission (SEC) adopted final rules for the expanded whistleblower program established by the Dodd‐Frank Wall Street Reform and Consumer…
Abstract
Purpose
Recently, the US Securities and Exchange Commission (SEC) adopted final rules for the expanded whistleblower program established by the Dodd‐Frank Wall Street Reform and Consumer Protection Act. The rules raise challenging issues, perhaps the most significant being their impact on existing compliance and corporate governance procedures. This paper seeks to examine this issue.
Design/methodology/approach
The paper analyzes the final rules and their impact on public companies.
Findings
Publicly listed entities have cause for concern that their existing compliance programs may be bypassed by whistleblowers who now have strong incentives to place personal interests ahead of loyalties to employers.
Practical implications
Companies need to improve their compliance programs to limit the potential hazards.
Originality/value
The proffered “steps to potentially minimize Dodd‐Frank whistleblowers” can help publicly traded companies – and particularly multinational enterprises subject to the Foreign Corrupt Practices Act – to avoid the significant risks that Dodd‐Frank presents to them.