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ARTICLE · 15 MAY 2015

Osler Comments On OSC's Proposed Whistleblower Program

Osler has submitted a comment letter to the OSC setting out certain concerns with regards to the proposed Whistleblower Program as set out in the OSC Staff Consultation Paper 15-401.

CanadaEmployment and HR

In response to the OSC's call for comments, Osler has submitted a comment letter to the OSC setting out certain concerns with regards to the proposed Whistleblower Program as set out in the OSC Staff Consultation Paper 15-401 : Proposed Framework for an OSC Whistleblower Program.

As set out the comment letter, Osler has some significant concerns that a program of this nature will have negative consequences on the ability of a market participant to establish and enhance a meaningful 'culture of compliance'. While Osler agrees with the desirability of certain initiatives that encourage persons with relevant information about possible wrong-doing to come forward to regulators in certain unique circumstances without fear of retribution, there are some substantive issues with the proposed program, as noted below.

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