In last week’s column I posed the question of whether a company can require employees to report misconduct when they see it. My contention was—and still is—that compliance officers are in a predicament: impose a duty to report misconduct, and you could expose your company to retaliation complaints if someone ignores you; don’t impose one, and you could expose yourself to more scrutiny from regulators who claim your company has an insufficiently rigorous culture of compliance.
That debate stirred a fair bit of attention, and I have fresh insight to report. Last week Compliance Week hosted another of our editorial roundtables, this time in Houston and on the subject of conducting internal investigations. So I posed the question to the 12 compliance officers there: Does your company impose a duty to report misconduct?
