The Society of Corporate Compliance & Ethics’ annual conference in Las Vegas last week generated lots of fresh thinking about whistleblower hotlines and the new whistleblower reward program at the Securities and Exchange Commission—including a speech from Stephen Cohen, associate director of enforcement at the SEC. Cohen made a few interesting remarks, and since the SEC has yet to post his speech online, let me recap what he said here.
The point of the SEC’s whistleblower program, he said, is not to hi-jack compliance officers’ own investigations into corporate misconduct. Rather, the reward policy is meant to propel internal investigations—to give compliance officers and senior corporate executives more incentive to take allegations of misconduct seriously—because if you don’t, you have the threat that an employee might also raise his concerns with the SEC. Cohen’s message could all be boiled down to one sentence, really: “Companies now have to compete for the trust of their employees.”
