OSC Whistleblower Roundtable Provides Food For Thought

As we have written previously, we recognize the increasing reliance and institutionalizations of whistleblower programs as one of the most significant developments in the realm of regulatory enforcement in recent years. Notwithstanding the identified benefits of providing regulators and law enforcement personnel with unprecedented access to information and evidence to assist them in their pursuit of white collar transgressors, they have the potential of imposing real impediments to compliance officers, and corporate officers and directors in their ability to manage a meaningful internal compliance regime. On June 9, 2015 the OSC hosted a roundtable discussion (the "Roundtable") on its proposed whistleblower program framework, OSC Staff Consultation Paper 15-401 – Proposed Framework for an OSC Whistleblower Program (the "Whistleblower Program").