As mentioned in a prior post, ex post protective measures for whistleblowers are insufficient on their own. Considering the economic benefits brought by effective reporting mechanisms, private firms need to adopt proactive measures that will avoid whistleblower victimization and lead to meaningful organizational change.
Entries in Adequate Procedures (5)
On December 18, 2014 the UK Government issued its long awaited “UK Anti-Corruption Plan.” The plan sets out over sixty action points for the Government and its partners, organized around four key themes of “Pursue,” “Prevent,” “Protect” and “Prepare."
Two years after the Bribery Act 2010 came into force, the hysteria surrounding the Act has abated. There are fewer media pundits pronouncing the end of UK plc as we know it and there are fewer newly invented “legal experts” opining on an area they knew little or nothing about but which they saw as a potential earner to fill the gaping hole left by declining litigation and commercial transactions.
The Government has proceeded to cut the budget of the Serious Fraud Office (SFO), the main enforcement agency, from £50 million in 2008/9 to below £30 million for 2013/14.
Jon Jordan propose his own version of an adequate procedures defense to the FCPA.