This is part IV of my international reward whistleblower series where I address frequently asked questions posed by people who are interested in filing a reward submission to the SEC. Part IV will focus on questions relating to whether certain corporate employees and suppliers are eligible for rewards. As background, international and FCPA whistleblowers who report SEC-regulated companies may be eligible for a reward under the Dodd-Frank program. Part I of this series can be viewed here, part II can be viewed here, and part III can be viewed here.
Are Health/Safety/Environmental Personnel Eligible for Rewards?
Yes, HSE personnel often have reward eligible information given their unique positions and responsibilities at their companies. HSE employees will frequently encounter local regulatory officials during audits and inspections. In many instances, the local HSE personnel will be responsible for obtaining safety and environmental permits and licenses and addressing issues identified during inspections. Sometimes companies will make payments to regulatory officials to obtain permits, licenses, and avoid inspection violations.
Are Government Relations & Affairs Personnel Eligible for Rewards?
Yes, government relations and government affairs personnel are eligible for rewards under the Dodd-Frank program. Government relations and affairs personnel often meet with government officials to discuss obtaining permits and licenses. They also work with various government agencies to obtain any special approvals or projects that their companies need. Through this process, government affairs and relations personnel often will become aware of their companies engaging and paying vendors, suppliers, contractors, consultants, agents, and intermediaries who are affiliated with government officials.
Are Temporary Workers, Consultants, and Suppliers Eligible for Rewards?
Yes, current or former part-time and temporary workers, consultants, suppliers, vendors, and contractors working in foreign countries may have reward eligible information relating to bribery. These workers and suppliers assist in all areas and throughout all corporate departments, and many learn about bribery-related issues during their work for these companies.
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If anyone has information about an SEC-regulated company engaging in corrupt conduct outside of the U.S., please feel free to contact me for a free confidential consultation.