An Empirical Study of Whistleblower Policies in United States Corporate Codes of Ethics

Companies have issued Codes of Ethics (also called Codes of Conduct) for decades, and these Codes increasingly have contained provisions related to whistleblowing. For example, Codes often encourage or even require corporate employees to report incidents of misconduct they witness. Code provisions describe the types of misconduct employees should report and provide numerous ways for employees to make reports. Moreover, companies use Codes to promise employees that they will not retaliate against whistleblowers. Indeed, because these whistleblowing provisions have become an important part of a corporation’s internal control and risk management systems, they merit closer examination to determine exactly what they require and promise. Accordingly, this chapter describes the results of the first comprehensive empirical study of whistleblower provisions contained in United States corporate Codes of Ethics