These two recent cases are such great examples of the value of a whistleblower hotline. While the Ralph Lauren Corporation did not previously have an FCPA compliance program in place, the violations were discovered when one was introduced. By self-discovering and self-reporting, RLC dodged a bullet. There is no doubt that if these violations were reported to an outside entity prior to self-reporting, that the fines would have been significant. The associated reputational damage would have to be mitigated, and internal controls would have been subject to costly auditing. Needless to say, the timing of the compliance program was fortuitous.
As any employee knows, the work environment is subject to many of the same ethical challenges that we face in society. With different types of people, and many different cultures and personalities, unethical behaviour can, and does arise from time to time.