An oil-and-gas company agreed to pay a $1.4 million penalty to settle SEC charges alleging that the company had employed illegal separation agreements and that it had retaliated against a whistleblower who expressed concerns about the company's process for calculating publicly reported oil-and-gas reserves.
According to the SEC Order, the separation agreements included the following problematic language: (i) a bar on disclosing information to any person, "including a governmental agency," and (ii) a requirement that employees not make any remarks "to any governmental or regulatory agency or to the press or media" that could embarrass or harm the company's reputation.
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