Professional Documents
Culture Documents
Contra-indications
Contra-indications
Contra-indications
Lawyers as gatekeepers
a paradigm shift
Officers
Board of Directors
Employees
Shareholders
The organization itself
What is the duty owed if something
occurs or is about to occur that
breaks the law?
Ch. 6 - Confidentiality - SOX reporting up and out
Shareholders
[QLCC - Qualified Legal Compliance
Committee - 17 CFR 205.2 (k)]
Board of Directors (audit committeecompensation committee-finance
committee)
CEO
CFO
Other officers
lower level employees
Ch. 6 - Confidentiality - SOX reporting up and out
10
11
12
13
14
15
16
17
19
20
21
22
23
24
25
Appropriate response
26
Appropriate response
27
28
29
30
Reporting Out
Reporting to the SEC
31
17 CFR 205.3
32
17 CFR 205.3
33
17 CFR 205.3
34
A threat to federalism?
Sarbanes Oxley preemption
35
36
37
38
39
40
41
42
43