The Landscape of Whistleblowing: A Personal and Professional Perspective. Timothy Hediger
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1 The Landscape of Whistleblowing: A Personal and Professional Perspective Timothy Hediger CFE, CIA, CCSA, ACDA, DoD IASO Owner and Consultant Polaris Risk Services, LLC
2 Disclaimer Polaris Risk Services is not, by means of this presentation, rendering business, accounting, legal advice, or other professional advice or services to any individual, business, government, or enterprise. This presentation is not a substitute for such professional advice or services, nor should it be used as a basis for any decision or action that might affect your business. Before making any decision or taking any action that might affect your business, you should consult a qualified professional. Polaris Risk Services shall not be responsible for any loss sustained by any person or entity that relies on this publication. All materials including but not limited to graphics, photographs, and text appearing in this presentation are protected. Reproduction or redistribution in any form is prohibited.
3 The Landscape of Whistleblowing Overview Our conversations today: 1. My Whistleblower Story 2. Your Environment 3. Whistleblower Program Problems 4. Solving Those Problems 5. Concluding Thoughts 6. Questions
4 I work for: Poll State, Provincial, or Local Government Federal Government Non-Profit Organization Large Enterprise Accounting/Consulting Firm Other
5 Poll I am a chief audit executive or the lead investigator in my department: Yes No
6 My Whistleblower Story An Introduction Director of Internal Audit U.S. Dept. of Defense Contractor Helping wounded warriors and disabled populations Locations throughout United States Fifteen years of COSO, CoBIT, and ACFE experience Deloitte and Touche alum
7 My Whistleblower Story An Introduction
8 My Whistleblower Story It all started with an audit... Auditing a mission-critical ratio: The 75 percent disabled direct labor ratio is a statutory requirement of the Javits Wagner O Day (JWOD) Act. A minimum of 75 percent of the agency-wide direct labor hours must be performed by people with severe disabilities. The agency-wide disabled direct labor ratio is measured in labor hours. This ratio must be maintained for the entire time an NPA participates in the AbilityOne Program. Source:
9 My Whistleblower Story It all started with an audit... Auditing a mission-critical ratio: Employees must have a bona-fide severe disability Severe disability must be validated and documented every year Source:
10 My Whistleblower Story It all started with an audit percent, not 75 percent Something s not right!
11 My Whistleblower Story Reporting to Management 2 Compliance False Claims NISH Ratios Truth in Negotiations Act (TINA) 3 Financial False Claims Kickbacks False labor record-keeping False billing 5 Total False Claims
12 My Whistleblower Story Reporting to Management Seventeen written observations to #4: Denied #9: Fired internal #12: Forced to cancel all #13: #17: Reported issues to external auditor (SAS 99) and corporate counsel Three weeks later, position was eliminated
13 My Whistleblower Story Federal Government Investigation After observation #4, reported findings to Congressman Silvestre Reyes (TX-16) Investigated by FBI, Army CID, and DCIS Wore a recording device (wire) Interviewed informants and employees Discovered additional false claims
14 My Whistleblower Story Settlement and Quotes Providing jobs for disabled workers is a critical purpose of the AbilityOne Program, said Tony West, Assistant Attorney General for the Civil Division. This resolution demonstrates that the Department will vigorously pursue government contractors who overcharge on their contracts, as well as misstate the number of non-disabled workers they actually employ. (1) Ensuring the integrity of federal contracting programs is one of the objectives of the Affirmative Civil Enforcement Unit in the U.S. Attorney s Office, said Benjamin B. Wagner, U.S. Attorney for the Eastern District of California. Results like these help accomplish that objective. (1) Today s announcement is a testament to our solid and continued partnership with the Department of Justice and other law enforcement agencies in the fight against fraud, said James Podolak, Director of the Army Criminal Investigation Command s Major Procurement Fraud Unit. This clearly demonstrates our continued commitment to rooting out fraud... in the Department of the Army and that our commitment is stronger than ever. (1) (1)
15 My Whistleblower Story Family Struggles percent unemployment(1) Both breadwinners out of work Start new businesses Foreclosure Asset sale Depleted savings Moving to North Carolina Second car sold (1)
16 Your Environment Would you be a whistleblower? 78 percent of respondents would report wrongdoing in the workplace if it could: Be done anonymously Be done without retaliation Result in a monetary award That s a lot of ifs!
17 Your Environment What does it take to be a whistleblower? 5 variables to a person blowing the whistle Severity of harm Certainty of the harm Degree of involvement Cost of acting Certainty of the situation
18 Your Environment Is your enterprise friendly to tips? REALLY? We know that: Tips are the number one means by which fraud is detected.(1) Whistleblowing is an inherently risky endeavor. Whistleblowers put forethought into their actions. Investigators must vet whistleblowers thoroughly. (1)
19 Your Environment What federal laws protect whistleblowers? SUMMARY OF LAWS Occupational Safety and Health Act (OSHA) Surface Transportation Assistance Act (STAA) Asbestos Hazard Emergency Response Act International Safe Container Act Safe Drinking Water Act Federal Water Pollution Control Act Toxic Substances Control Act Solid Waste Disposal Act Clean Air Act Comprehensive Environmental Response, Compensation, and Liability Act (SUPERFUND) Energy Reorganization Act AIR21 Act Sarbanes Oxley Act Pipeline Safety Improvement Act Federal Railroad Safety Act National Transit Systems Security Act Consumer Product Safety Improvement Act Dodd-Frank Act Seaman s Protection Act Affordable Care Act FDA Food Safety Modernization Act Source: SUMMARY OF REGULATIONS 29 CFR Part CFR Part CFR Part CFR Part CFR Part CFR Part CFR Part CFR Part 24
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21 QUESTIONS? Timothy Hediger CFE, CIA, CCSA, ACDA, DoD IASO Telephone:
22 The Landscape of Whistleblowing A Personal and Professional Perspective January 26, 2012 Thank you Timothy Hediger The Landscape of Whistleblowing A Personal and Professional Perspective Organization trhediger@polaris-risk.com
23 The contents of this presentation may not be transmitted, re-published, modified, reproduced, distributed, copied, or sold without the prior consent of the author. Association of Certified Fraud Examiners, Certified Fraud Examiner, CFE, ACFE, and the ACFE Logo are trademarks owned by the Association of Certified Fraud Examiners, Inc.
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