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Policy Issues for the Audit Committee on Whistle blowers
The Audit Committee should be involved in setting policies and overseeing the ongoing implementation of the Whistle Blower policies. It cannot be farmed out to a third party or delegated to the company. Periodic reports from management of the third party institutions are inadequate.
the following questions on WB policies is the responsibility of The Audit Committee:
- Are there procedures and controls in place to ensure and maintain that the complaints as confidential and anonymous?
- How and when should the complaint system be communicated and reinforced to the company's employees and relevant third parties?
- Who should and should NOT have access to the complaints.
- Who gets copies of the complaints?
- When should the day to day management be actively involved based on the type of complaint?
- What type of complaints or summary should the audit committee receive?
- What is the components and processes that determines the level of effort given to each complaint?
- What documentation should be maintained regarding the resolution of each complaint?
- When a pattern of potential misconduct exists, what level of overall review is obligatory to ensure that complaints are not dismissed individually?
- When and what level of voluntary reporting or public disclosure is required (does not address SOX Section 301 compliance)
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