It is Santa's most important month of the year as he and his elves work around the clock in preparation for Christmas. With his naughty and nice lists just about finalised, Santa is dismayed to have received a whistleblower allegation that Snowy, an elf inside his Australian subsidiary ('Elfco'), has been taking bribes to move children off the naughty list.
Recent amendments to the Corporations Act 2001 mean that, with effect from 1 January 2020, Santa, through Elfco, has expanded responsibilities and obligations in relation to whistleblowers. This includes additional protections and legal rights for whistleblowers, and all public companies and large proprietary companies (who could doubt Elfco's status a large proprietary company?) will be required to have a whistleblower policy, with mandatory content. Santa operates under best practice and has implemented his whistleblower policy ahead of the 1 January 2020 deadline.
After ensuring the whistleblower was protected and providing them with appropriate support options, Santa took swift action. Integrity is one of Santa's key values, therefore he launched a full investigation into the allegations to ensure his operation was not compromised.
With Santa's elves communicating with billions of children around the world, the volume of email, messaging and social media collected is enormous. Christmas is fast approaching, so he needed help to progress the investigation quickly and efficiently.
Santa arranged for KordaMentha's forensic technology experts to launch a secret capture of Snowy's email account, computer and mobile phone. Forensic investigators then quickly and surreptitiously reviewed the large volume of data in RelativityOne, enabling them to use search terms, review conversation histories, identify personal email addresses and use Technology Assisted Review to identify suspicious correspondence.
The investigators quickly identified Snowy sending his Apple Pay details to naughty children who then use their parents' iTunes accounts to send bribes. The investigators prepared an interview brief and Snowy was brought in for questioning. During the interview, he provided the names of more elves in the USA and France with similar arrangements and alleged they had put him in touch with their naughty children's Australian cousins!
Santa's investigation was expanded to cover these new leads before finalising his lists for the Christmas Day run.
Following the investigation, the complicit naughty children were given a two-year ban and a sack of coal each. The naughty elves were reassigned to the Reindeer Farm. With the amendments to the responsibilities and obligations regarding whistleblowing policies becoming mandatory in the near future, corporations will also need to ensure their whistleblowing policies are up to date. Luckily for Santa, being an early adopter, he had an effective whistleblowing policy in place and integrity has been restored to his naughty and nice lists.
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