Whistleblower Policy review

Whistleblower policy under SOX § 806 + Dodd-Frank § 922 + SEC Rule 21F-17.

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+ 104 general checks
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What it checks

Reporting channels — internal + external

Policy must establish internal reporting channels and acknowledge external (SEC / CFTC / DOL) options.

Critical · POL-023

Non-retaliation prohibition + SOX / Dodd-Frank protections

Policy must prohibit retaliation and reference SOX § 806 + Dodd-Frank § 922 protections.

Critical · POL-024

SEC Rule 21F-17 — no impeding whistleblower communications

Policy must comply with SEC Rule 21F-17 (17 C.F.R. § 240.21F-17) — no provision shall impede whistleblower communications.

Critical · POL-025

Confidentiality + anonymous reporting

Policy must offer confidentiality and an anonymous reporting option.

Critical · POL-026

Investigation procedure + corrective action

Policy must describe investigation procedure and corrective action.

Warning · POL-027

Every run also applies 104 general checks that belong to any agreement: structure, parties and signatures, defined terms, cross-references, dates, amounts, and one-sided terms.

Often reviewed with

Code of Conduct / Ethics

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