This paper discusses key considerations in a corporate whistleblower program once a complaint is received. It focuses in particular on the role of the audit committee, which under the Sarbanes-Oxley Act of 2002 is charged with establishing and overseeing these programs. This paper outlines the Model Accounting Complaint-Handling (MACH) Process, a step-by-step approach to establishing a corporate whistleblower program. Among the issues examined are:
(This is an updated version of Volume 2, Issue 2, originally released August 2006.)