So there we were, about 70 of us, sitting in rows last week in a conference room at the Cosmopolitan Hotel in Las Vegas. We had come to attend the Society of Corporate Compliance & Ethics’ annual conference, and at that exact moment were listening to a superb analysis of whistleblower hotlines by Stephen Epstein, the chief ethics counsel at Microsoft.
Epstein was exploring how corporate compliance hotlines can remain a viable tool for compliance officers, when employees could just as easily ignore the hotline in favor of running straight to regulators with their tips so they can collect whistleblower rewards. He had projected a PowerPoint slide onto the screen listing the most common reasons why an employee chooses not to report misconduct:
