Whistleblower program compliance

Whistleblower program compliance in the Technology, AI and Competition sector is under active scrutiny from multiple directions, with the U.S. Securities and Exchange Commission's whistleblower program imposing specific requirements on how firms handle internal reporting channels, and the U.S. Department of Justice's Corporate Enforcement Policy creating direct incentives for companies to self-disclose before a whistleblower beats them to it. The European Commission's Whistleblower Protection Directive, now transposed across EU member states, extends mandatory internal reporting obligations to technology firms operating in Europe, including those handling AI systems flagged as high-risk under the EU AI Act. Compliance teams at technology companies are currently auditing their internal reporting procedures against these overlapping regimes, particularly where antitrust conduct, algorithmic decision-making, and data handling create novel disclosure questions.