The Corporate Whistleblower's Survival Guide

TOOL H Model Whistleblower Hotline Policy

Since the 2002 passage of the Sarbanes-Oxley Act for corporate accountability, all corporations that are publicly traded in the United States must have whistleblower “hotlines” to the audit committee for each board of directors. This requirement has institutionalized a common practice for decades at government agencies and companies. It has also created a dynamic, growing cottage industry in the United States for what traditionally was a scattered phenomenon with widely varying standards of quality.

Historically, there has been little credible evidence that hotlines are an effective vehicle through which whistleblowers could challenge corruption or other abuses of power sustained by secrecy. This model ...