Internal Disclosures From Compliance Audits –What Could Go Wrong?

Compliance or internal audit departments frequently carry out audits intended to assure that business partners in an organization, such as human resources or legal departments, have in place policies and procedures that are effective for maintaining corporate compliance and consistent with the myriad laws with which the organization must comply, including employment, whistleblower, and anti-bribery and corruption. These reviews are often not confined to policies but may also seek review of actual compliance events and sensitive contemporaneous records. For example, in the case of an internal anti-discrimination and harassment policy, or a public and employee-facing whistleblower policy, the compliance department ("Compliance") may wish to review logs of previous complaints and investigation files. These records may contain the names of whistleblowers, allegations of unethical or illegal conduct, and legal conclusions.