From law firm BuckleySandler, seven steps for integrating three key provisions of the SEC’s whistleblower program into a corporate compliance program to encourage internal reporting. Here are two:
"1. Create an ‘Internal Report Certificate Program’ to memorialize the date on which the internal report occurred so that whistleblowers can be confident that the SEC will recognize their place in line.
2. Provide whistleblowers with periodic updates throughout the 120-day period on the status of ensuing internal investigations so the whistleblower is aware of progress and can remain confident that his/her concerns are being addressed and that time still remains to report if needed.”
Read all seven: