How to Handle Whistleblower Complaints: Best Practices Amid a Spike in FCPA-Related Complaints
Olivia Radin
Partner
King & Spalding LLP
Rina Vazirani
Associate General Counsel & Senior Director
Gilead Sciences
- Trends and specific challenges related to FCPA-related whistleblower complaints
- Step-by- action plan for handling the complaint, interviews and litigation risk
- Whistleblowers that continue to bring False Claims Act actions against life sciences companies, particularly those that lack the fundamental controls necessary to comprise adequate healthcare fraud and abuse compliance programs
- Asia Pacific-related whistleblower report trends: Meeting confidentiality obligations and local law requirements
- Whistleblower risks when implementing reductions in the workforce
- EU Whistleblower Protection Directive: Key Considerations for the Life Sciences Sector
- fostering internal, rather than external, reporting
- encouraging individuals to report centrally, while ensuring that the worker also has the option to report locally
- Retaliation:
- retaliations including “psychiatric or medical referrals”
- continuing to monitor its relationship with a whistleblower and to keep records of management decisions