Devoted to Corporate Attorneys, Corporate Lawyers, and Corporate Counsel

The following is not meant to be legal advice.

On March 30, 2007, Nossaman Guthner Knox & Elliott LLP presented to in house attorneys in Burlingame, CA on the subject of Sarbanes-Oxley and ethical dilemmas.

The in house attorneys were advised of their up the ladder duty to report ethical issues.  The training went over the SEC rules on professional conduct, in particular 17 CFR Part 205.  “Reasonably likely” was explained to mean requiring evidence more than a mere possibility, but not more likely than not.  A case for illustration of points presented were a case involving David Drummond, General Counsel at Google, Inc.

The speakers discussed whistleblower measures such as prohibitions against retaliation when an employee provides information about fraud.  Cardinal Bankshares was a case on this issue.  Employee disciplines and terminations should be properly documented.