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CANADIANLAWYERMAG.COM/INHOUSE MAY 2015
whistleblower
codex
policy
compliance
procedure
culpability
I n d u s t r y S p o t l i g h t
THE ONTARIO SECURITIES COMMISSION
has fi nally started the ball rolling on an initiative
it fi rst suggested back in 2011: a whistleblower
program to provide fi nancial rewards to people
who report securities law breaches. In February,
the OSC published a consultation paper on a
proposed program framework, to stir up discussion
and get feedback.
Judging by the comments from a handful of legal
experts who follow these developments, the regu-
lator certainly has stirred things up — and it can
expect to receive plenty of input from lawyers con-
cerned that the proposed whistleblower program
will shatter companies' carefully crafted internal
compliance systems.
BY STEFAN DUBOWSKI
Will Ontario's
whistleblower
program blow holes
in internal compliance
systems?
Now's the time for
in-house teams to ask
hard questions about
their own compliance
programs.
