10 Tips for Whistleblower-Compliant Agreements
Troutman Pepper Partners Sheri Adler and Mary Weeks recently joined Meredith Irvine on TheCorporateCounsel.net's Timely Takes Podcast to discuss whistleblower-compliant documents and related SEC enforcement. The podcast can be accessed here. The discussion covers:
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The history of the SEC's Rule 21F-17 enforcement against companies whose documents were viewed as impeding whistleblowers from communicating with the SEC.
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Provisions in employment and severance agreements the SEC has found problematic under Rule 21F-17.
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The necessity for companies to take a broad, holistic, and consistent approach to compliance with Rule 21F-17.
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Additional takeaways from the SEC's Rule 21F-17 enforcement actions.