Bribery rewards are available to human resources personnel and recruiters – both internal and external – who report corporate bribery confidentially to the U.S. Securities and Exchange Commission (SEC). The Dodd-Frank reward program covers corporate violations of the U.S. Foreign Corrupt Practices Act (FCPA) by many international public companies. International whistleblowers who provide information about corporate bribery of foreign government officials by SEC-regulated companies can receive large rewards.
The SEC already has made more than $150 million in payments to whistleblowers. This post will discuss how current or former human resources personnel and recruiters working in countries outside the U.S. may have reward eligible information relating to FCPA violations.
Recruiters Often Have Reward Eligible Information
International recruiters who work in-house at a company or as search consultants (or work for headhunting or contracting agencies) often have reward eligible information because they are dealing with transitioning corporate employees. International recruiters are not required to have first-hand information about bribery but can report tips learned from candidates who they are placing at other companies. One recruiter reported that a person she was placing at a new company had left his prior position because he had reported bribery and corruption issues and had been retaliated against. Even though the recruiter did not have first-hand knowledge of the bribery, this information was still reward eligible. Any recruiter who has a corporate bribery tip should feel free to email me at firstname.lastname@example.org.
HR Personnel: “Watercooler Talk,” Employee Surveys, Exit Interviews, and Disciplinary Issues
HR personnel often have their fingers on the pulse of the day-to-day operations of the company and learn about the vast majority of issues that their companies are facing. HR personnel often learn about bribery and corruption issues raised by employees when they leave the company or when such issues are noted during employees’ evaluations or in their personnel files. If current or former HR personnel learn about corporate bribery from “watercooler talk,” employee surveys, exit interviews, or from employees being involved in disciplinary issues, they should feel free to email me at email@example.com, as this could be valuable information.
HR – Bribing Immigration Officials: Visas, Work Permits, and Residence Permits
Local HR personnel also often become aware of payments being made to immigration officials – either directly by company personnel or indirectly via a third party – to obtain visas, work permits, and residence permits for the company’s expatriates. If current or former HR personnel are aware of these type of payments, then they should feel free to contact me, as this could be valuable information.
HR – Engaging Government Consultants and Hiring Relatives of Government Officials
Through the recruiting and onboarding process, HR personnel will sometimes learn about their companies engaging government consultants and hiring relatives of government officials. Sometimes government officials will attempt to direct companies to their “favored” employment firms to obtain local part-time and temporary workers. If any current or former HR personnel is aware of a company engaging government consultants, engaging a business affiliated with a government official, or hiring a government official’s relative, then they should feel free to contact me. And for more details about how the reward program applies to FCPA whistleblowers, please click here.