Troutman Pepper’s “Companies Should Exercise Caution When Addressing Anonymous Whistleblower Complaints” generally describes a recent spate of insider trading, bribery, and accounting fraud-related anonymous whistleblower complaints widely believed to be fabricated based on the significant numbers of public companies (including Society members) that have received the same or similar anonymous complaints. The firm advises companies that receive these or other anonymous whistleblower complaints to consider whether they may be cyber incident-related, and to evaluate, investigate, and document the investigation of any such complaints in a thorough manner in accordance with the company’s processes for managing whistleblower complaints generally. In the event the company determines a complaint to related to a cybersecurity attack or breach, the firm also suggests companies consider self-reporting to the SEC or other regulators.
In June, we informed members via the Society huddles about what appeared to be a whistleblower reporting scam concerning anonymous allegations of insider trading.
Access additional resources on our Whistleblowers page.
This post first appeared in the weekly Society Alert!