Whistleblowing

Tesco's £250 million profits overstatement bombshell was brought to the attention of the GC and new Chief Executive by an internal whistleblower.  Adequate bribery procedures include 'speaking up' or whistleblowing reporting lines as key features of any organisation's bribery prevention policy.  And more than 70% of cartel investigations are triggered by whistleblowers seeking leniency.

In the UK, the Competition and Markets Authority has continued the OFT's policy of offering a cash reward of £100,000 for cartel whistleblowers (although those directly responsible responsible for cartel activity will not be able to benefit).  For companies, confessing can deliver reductions or even immunity from fines.  Examples of recent leniency discounts granted by the OFT are set out below: