Whistleblower tips are streaming into the SEC, so it’s critically important for companies to develop effective parallel internal reporting systems. Jane Norberg, a partner at Arnold & Porter who previously served as the Chief of the SEC’s Whistleblower Office, chats with Chris and Kurt about the state of the SEC’s whistleblower program and how companies should encourage, triage and investigate whistleblower tips.
Featured in this Episode
Jane Norberg
Jane Norberg is a Partner in the Securities Enforcement & Litigation Practice at Arnold & Porter. Jane brings to her practice extensive experience as Chief of the Office of the Whistleblower of the Securities and Exchange Commission, having helped build and develop the SEC’s whistleblower program since near its inception. Under Jane’s leadership, the SEC received record numbers of whistleblower tips and paid out record-breaking awards.
Jane’s practice at Arnold & Porter focuses on advising clients on all aspects of whistleblower matters. This includes helping companies navigate complexities related to whistleblower reports and issues of all kinds; counseling companies on best practices for handling internal whistleblower reports; proactively assessing and mitigating risk; conferring with respect to emerging whistleblower issues; internal and external investigations; advising on best practices related to retaliation and impeding reporting to regulators; assisting the company in its response and defense to specific whistleblower allegations; and providing crisis management to mitigate reputational risk.
During her tenure at the SEC, Jane advised the SEC Chairman and the Director of the Division of Enforcement on emerging whistleblower issues and the development of rulemaking and policies, as well as reported to Congress regarding the program’s activities and advised them on whistleblower matters. She joined the Securities and Exchange Commission in 2012 as Deputy Chief of the Office and was appointed to Chief in 2016.
Under her leadership, Jane managed an expansion of the Office’s staff and oversaw a record-breaking growth in the number of whistleblower tips received and awards issued to whistleblowers under the program. Jane has extensive experience and knowledge regarding whistleblower retaliation and agreements that impede reporting in violation of Exchange Act Rule 21F-17, having directly advised on all whistleblower protection cases brought by the SEC during her tenure. Jane had a substantial advisory role related to the amendments to the SEC’s whistleblower rules, and has conferred with and advised other domestic and international regulators related to the development of new whistleblower programs.
Jane is a sought-after speaker and subject matter expert with respect to whistleblower-related issues and speaks regularly on the topic.