Incentives Rise In The OSC Whistleblower Program

Increasingly, companies are expected to develop, implement and properly administer complaint handling and "whistleblowing" programs, especially in regulated industries and public companies. As we have written in previous publications, these programs, which should include protection for employees and third parties from retribution for bringing possible wrongdoing to the attention of responsible persons, play a crucial role in maintaining a "culture of compliance" within a business. Recently, capital markets and other financial conduct regulators have established rules and requirements for firms under their supervision, and some have set up their own regimes to help them uncover potential wrongdoing that can negatively impact markets and investors.