In an article written for The Conference Board entitled From Enron to Lehman Brothers: Lessons for Boards From Recent Corporate Governance Failures, author Frederick Lipman, who is a partner at the Blank Rome LLP law firm, discusses common pitfalls in many current whistleblower programs, and offers recommendations on how audit committees can work to strengthen internal whistleblower programs.
While the article is not written from the fund director point of view, many of its observations are transferable to the fund context. For example, the report notes that for a compliance program to be effective, it must be independently administered. In the area of whistleblower complaints, the report advocates that the identity of whistleblowers should be protected in order to encourage executives to use the internal whistleblower system. The report also suggests that whistleblower complaints regarding potential accounting, auditing and enterprise risk matters should be investigated by an independent entity that reports to the independent directors.
A copy of the report can be found here: http://www.aacmi.org/TCB%20DN%20V4N6_3rd%20proof.pdf