Updating Your Whistleblower Procedures: How to Apply Six Sigma and Lean Methodologies

Whistleblower litigation has continued to proliferate under federal and state statutes, and the SEC's rules implementing Dodd-Frank's whistleblower provisions just raised the stakes. One method of paring the risks is to develop processes and procedures in accordance with Six Sigma and Lean principles. In particular, companies have begun developing process maps that define and set guidelines for handling each stage of a whistleblower complaint from its inception through the investigation and resolution. This includes control mechanisms designed to monitor the compliance of the defined policies and procedures to minimize the risk. Join these experts:

• Steve Pearlman, Partner, Seyfarth Shaw LLP
• Donna Boehme, Principal, Compliance Strategists, LLC

Among this program's topics are:

• Identifying sources of whistleblower complaints, ranging from employees to vendors
• Instituting a sound complaint intake process; filtering complaints and escalating and transferring them to appropriate channels
• Defining each stage in the whistleblower process and developing policies and guidelines
• Charting out your investigation with defined protocols and timelines
• Defining appropriate roles and responsibilities amongst those involved in the process
• Crafting an appropriate whistleblower protection policy
• Managing employees after they blow the whistle
• Instituting appropriate controls
• Communication techniques
• Continuous feedback and improvement

 

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