Davies has submitted a letter to the Ontario Securities Commission (OSC) commenting on Staff’s framework for a proposed Whistleblower Program. The Whistleblower Program would be the first of its kind for Canadian securities regulators and only the second whistleblower program in Canada to offer a financial incentive.
As noted in our comment letter, we appreciate that the Whistleblower Program involves a careful exercise in line drawing between the goals of enforcement, on the one hand, and government intrusion into the affairs of reporting issuers, on the other hand. However, we are concerned that the proposed Whistleblower Program draws the line in the wrong place. In our comment letter, we raised the following concerns.
Financial Awards Create Perverse Incentives
Offering any form of financial award for information from whistleblowers could create perverse incentives that may ultimately have negative consequences for enforcement and investor protection, such as…
DAVIES – MAY 2015.
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