How to Handle Internal Whistleblower Claims Without Making Things Worse An Employee Lawyer s Perspective

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1 How to Handle Internal Whistleblower Claims Without Making Things Worse An Employee Lawyer s Perspective R. Scott Oswald The Employment Law Group Phone: Fax: Webinar Agenda Establishing a Compliance Program Why? How? What to do once an employee discloses a potential violation Dealing with a disclosing employee Acting on what is discovered Top 5 Compliance Mistakes 1

2 Why Establish a Compliance Program Legal Section 301 of SOX requires publicly traded companies to set up audit committees. 15 U.S.C. 78j 1(m)(4) (4) Complaints Each audit committee shall establish procedures for (A) the receipt, retention, and treatment of complaints received by the issuer regarding accounting, internal accounting controls, or auditing matters; and (B) the confidential, anonymous submission by employees of the issuer of concerns regarding questionable accounting or auditing matters. Why Establish a Compliance Program Legal Kolstad v. American Dental Association, 527 U.S. 526, 540 (1999) The Court held that punitive damages do not attach when a Title VII discrimination claim is based on vicarious liability and the employer has engaged in good faith efforts to comply with Title VII. A policy and compliance program can protect an employer in these circumstances. 2

3 Why Establish a Compliance Program Legal Employers can avoid vicarious liability for a hostile work environment [claim] by showing that (1) the employer exercised reasonable care to prevent and correct promptly any harassing behavior, and (2) the harassed employee unreasonably failed to take advantage of any preventive opportunities provided by the employer. Burlington Industries, Inc. v. Ellerth, 524 U.S. 742, 765 (1998). This latter requirement can provide the basis for an affirmative defense to hostile work environment claims. That is, where an employer makes preventive opportunities available to employees, they can defend against these claims. Antiharassment policy with a complaint procedure is not necessary as a matter of law under Fargher/Ellerth. But both prongs meet in a compliance program because of the passive and active elements discussed infra. In Williams v. Administrative Review Board, 376 F.3d 471, 478 (5th Cir. 2004), the court held that the Ellerth/Faragher standard is applicable to certain whistleblower hostile work environment cases. Why Establish a Compliance Program As part of the rulemaking process following the passage of the Dodd Frank Wall Street Reform and Consumer Protections Act, the Chamber of Commerce submitted multiple comments to the SEC. It cited many reasons supporting instituting internal compliance programs /s pdf Effective compliance programs rely heavily on internal reporting of potential violations of law and corporate policy to identify instances of noncompliance. [C]orporate employees should not be rewarded if they engage in, perpetuate, or fail to take action to stop internal wrongdoing. [I]t should be the policy of the Commission, reflected in the rules implementing the whistleblower program, to ensure that corporations are informed of potential wrongdoing involving their employees or others acting on their behalf. Many corporate compliance programs and/or employee codes of conduct impose an obligation on all employees to report conduct that violates law or corporate policy, including violations of the securities laws, via internal channels. 3

4 Why Establish a Compliance Program /s pdf (Second Submission by the Chamber of Commerce) [L]arge numbers of companies have implemented strong internal reporting systems to obtain information about potential wrongdoing. Recent regulatory developments, including adoption of Section 301 of the Sarbanes Oxley Act of 2002 ("SOX"), Pub. L. No , and revisions to the federal Sentencing Guidelines, have accelerated this trend. The experience of the many companies with robust internal reporting programs, as well as the empirical evidence, demonstrate that all stakeholders benefit when those with knowledge of potential securities law violations report internally, thus enabling management to promptly investigate and take remedial action. With timely access to information about potential problems, companies can address and punish wrongdoing, avoid lawsuits, improve efficiency, and reduce costs. Moreover, internal reporting works. The Chamber of Commerce reports that a group of the leading researchers on this question recently have reported, "empirical studies have shown few substantial differences in antecedents or outcomes of whistle blowing as a function of type of channel [i.e., external or internal] used." Why Establish a Compliance Program On February 20, 2014, the SEC submitted an Amicus Curiae brief in support of whistleblower Liu Meng Lin in his case against Siemens AG (http://www.sec.gov/litigation/briefs/2014/liu siemens 0214.pdf). The SEC summarized many of the benefits of an internal compliance program and internal reporting: Companies processes for the internal reporting of violations of law and other misconduct play an important role in facilitating compliance with the securities laws. [I]nternal reporting processes can help companies to promptly identify, correct, and self report unlawful conduct by officers, employees, or others connected to the company. The Commission s interpretation is also reasonable because, by ensuring that individuals who report internally first will not be potentially disadvantaged by losing employment anti retaliation protection under Section 21F, it better supports a core overall objective of the whistleblower rulemaking avoiding disincentivizing individuals from reporting internally first in appropriate circumstances. [I]f internal compliance and reporting procedures are not utilized or working, our system of securities regulation will be less effective. 4

5 How to Establish a Compliance Program A healthy compliance program needs passive and active components Passive Establish a complaint protocol for receiving complaints If a protocol is not established, courts may determine that complaints made to any management qualify. That is, such complaints put the company on constructive notice. Disseminate the protocol This provides notice to employees so they know what they must follow Require employees to follow it Establish protocol for investigating complaints (will return to this) How to Establish a Compliance Program A healthy compliance program needs passive and active components Active Require an annual certification from employees that they are unaware of any regulatory or legal violations in the workplace. In the event an employee knows of any violations, the company can hope to have such a certification bring them to light. The company can use such certifications as a defense. Investigate complaints Perform audits Risk assessments 5

6 Example Certification Example Compliance Program Scope and Roles Coverage Level of responsibility for each employee 6

7 Example Compliance Program How Complaint conduits Confidentiality Methods of reporting Example Compliance Program What Defining scope of reportable conduct 7

8 Example Compliance Program Defining scope of fiduciary duties What to do once an employee discloses a potential violation The most important quality applicable throughout an investigation: Speed First step: Interview the individual that has come forward who knows about the alleged violation who has information about it who has witnessed the violation Interview witnesses Gather documentation If necessary, engage a subject matter expert Report back to compliance department l 8

9 Hallmarks of a good investigation 1. Organization Take stock once a complaint is received Review the complaint and supporting documentation Interview witnesses in a logical order, starting with the complainant Interview the respondent and give him a chance to add witnesses to the list Hallmarks of a good investigation 2. Well Documented Common mistake is to take poor interview notes One paragraph for a two hour interview is not enough Documenting interviews needs to detailed what was said and what was asked and denied 9

10 Hallmarks of a good investigation 3. Neutral There is a natural inclination to advocate one side Investigator s role is to feel out potential theories for what happened Interview every person making a complaint regardless of whether you think it is meritorious at first blush Hallmarks of a good investigation 4. Discretion Careful with the information you are gathering Recognize when transparency is important E.g., explain the purpose of interviews Safeguard sensitive information Limit those aware of the complaint If a whistleblower has reported anonymously, do not attempt to identify the whistleblower s identity 10

11 Hallmarks of a good investigation 5. Heuristic Similar concept to thoroughness An investigation has been thorough when the investigator has Interviewed the complainant Reviewed relevant documents Interviewed witnesses with direct knowledge of the facts alleged in the complaint Interviewed the respondent Dealing with a disclosing employee Inform the whistleblower that there will be no retaliation based on reporting because what has been said is protected under relevant statutes. SOX, FCA, NDAA Wrongful discharge Industry specific statutes Inform others interviewed of coverage and no retaliation Crawford v. Metropolitan Government of Nashville, 555 U.S. 271 (2009) "Thus, a person can 'oppose' by responding to someone else s questions just as surely as by provoking the discussion," further "we would call it 'opposition' if an employee took a stand against an employer s discriminatory practices not by 'instigating' action, but by standing pat, say, by refusing to follow a supervisor s order to fire a junior worker for discriminatory reasons. Ellerth and Faragher imbues employers with a strong inducement to ferret out discriminatory activity because they can be held vicariously liable if they faile to investigate. 11

12 Dealing with a disclosing employee To the extent that compliance believes something untoward has happened (a legitimate violation), they should use the defined mechanism for notifying management of the violation Provide follow up Number one mistake is not keeping disclosing employee updated or no follow up Don t have to identify the results but to ensure the individual knows the company cares and is responsive; Responsible HR representative should schedule follow ups with disclosing employee at the 3 and 6 month marks, at least Acting on what is discovered Self disclosure to enforcement authorities False Claims Act: Reduction from treble to double damages 31 U.S.C. 3729(a) (2) Reduced damages. If the court finds that (A) the person committing the violation of this subsection furnished officials of the United States responsible for investigating false claims violations with all information known to such person about the violation within 30 days after the date on which the defendant first obtained the information; (B) such person fully cooperated with any Government investigation of such violation; and (C) at the time such person furnished the United States with the information about the violation, no criminal prosecution, civil action, or administrative action had commenced under this title with respect to such violation, and the person did not have actual knowledge of the existence of an investigation into such violation, the court may assess not less than 2 times the amount of damages which the Government sustains because of the act of that person. Risk of opening company to suit s 12

13 Acting on what is discovered DOD Voluntary Self Disclosure Program (1) the disclosure must not be triggered when the matter is about to be discovered by the government; (2) the disclosure must be on behalf of the business entity; (3) prompt and complete corrective action must be taken by the contractor; and (4) the contractor must cooperate fully in any ensuing investigation. The Department of Defense Voluntary Disclosure Program, Tab. A, pp Acting on what is discovered DOJ s seven criteria to be considered in determining whether to prosecute a volunteer: (1) completeness and candor of the disclosure; (2) preventive measures and strength of compliance program; (3) extent of the fraud; (4) pervasiveness of the fraud; (5) level of the corporate employee responsible for the conduct; (6) cooperation by the corporation; and (7) remedial action (Le., disciplinary action and restitution). U.S. Attorneys, Criminal Resource Manual, tit 9, ch. 931 (2010), available at sam/title9/crmoo93j.htm 13

14 Acting on what is discovered Government contractors covered by the Federal Acquisition Regulation ("FAR") are required to make a timely disclosure to the government whenever the contractor has "credible evidence" of: (1) a violation of the federal criminal law involving fraud, conflict of interest, bribery, or gratuity violations; (2) a violation of the FCA in a covered federal contract; or (3) a "significant overpayment" as defined in the FAR. 73 Fed. Reg (Nov. 12,2008). Potential suspension and debarment from federal contracts if disclosure is not made. Acting on what is discovered In Foreign Corrupt Practices Act enforcement actions, the Department of Justice takes into account a defendant s timely voluntary disclosure, and thorough and wide reaching self investigation for decreasing criminal penalties. crm 446.html The method for learning about violations of laws administered and enforced by DOJ is a compliance program. Department of Justice McNulty Memo, Dec. 12, 2006, at 14, available at The DOJ will ask two questions in criminal prosecutions: Is the corporation s compliance program well designed? and Does the corporation s compliance program work? Federal Sentencing Guidelines, 1.htm Whether a company has an effective compliance program is a significant factor in sentencing when a corporation is convicted of criminal conduct. 14

15 Acting on what is discovered SEC factors in self disclosure to assessing penalties. Importantly, satisfying the whistleblower with action (stymieing the action and discipline for violator) means it is less likely for the whistleblower to disclose externally. There is disagreement on whether to disclose the concern to the chain of command for the whistleblower that there has been a disclosure. Traditional approach: Do not inform chain of command because doing so would give them knowledge and lead to retaliation. Other approach: Getting things out in the open promoting an environment of compliance. Top 5 Compliance Mistakes 1. Failure to establish a compliance protocol 2. Failure to investigate immediately Whistleblowers feel they are not being heard and seek external remedies 3. Failure to interview witnesses identified by whistleblower Points to a predetermined outcome 4. Failure to take remedial action, including against those identified as engaging in wrongdoing where appropriate Opens the company to prospect of litigation for whistleblower retaliation 5. Failure of follow up with whistleblower to prevent retaliation Whistleblowers become disillusioned and seek external remedies 15

16 How to Handle Internal Whistleblower Claims Without Making Things Worse An Employee Lawyer s Perspective R. Scott Oswald The Employment Law Group Phone: Fax:

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