CRISIS TABLETOP ORIGINAL · GOVERNANCE & CONDUCT
A whistleblower alleges that a senior commercial executive manipulated contract timing and retaliated against employees who objected. Conflicts emerge, evidence may be disappearing, the complainant contacts regulators, and leaked allegations force decisions before the investigation is complete.
EXERCISE PURPOSE
A senior-executive misconduct allegation develops into retaliation concerns, financial-reporting risk, regulator contact, and public scrutiny
DECISION PRESSURE
The facilitator releases facts in stages. Participants should identify the decision owner, the authority being used, the information still needed, the immediate action, and the next escalation point.
Who receives the allegation if the general counsel or senior executives may have conflicts?
What preservation steps can occur without exposing the reporter?
Which interim measures protect people and evidence without prejudging facts?
When must audit committee, board, auditors, insurers, or regulators be informed?
How should the company respond when incomplete allegations become public?
INSIDE THE EXERCISE
The template is already populated with public injects, facilitator-only context, discussion prompts, private role messages, and a final hotwash.
The ethics hotline receives a detailed report alleging that the Chief Commercial Officer pressured staff to backdate acceptance records so revenue could be recognized before quarter close. The reporter also alleges retaliation against an employee who objected.
The General Counsel previously advised the commercial team on the contract structure now at issue. The Chief Human Resources Officer approved a performance warning for the employee alleged to have suffered retaliation.
IT confirms that chat messages are retained for only 30 days and that the executive uses a personal phone for some business communications. A key salesperson resigned last week and their cloud account is scheduled for deletion tonight.
The suspected reporter is removed from a customer meeting, receives a negative interim review, and is told that advancement opportunities are on hold while leadership evaluates loyalty and fit.
A preliminary data review identifies similar quarter-end changes in six transactions over eighteen months. Internal Audit had previously noted approval-control exceptions but closed them after management promised training.
The accused executive denies wrongdoing, demands to know who made the allegations, and asks the CEO to terminate the suspected reporter for disloyalty and poor performance.
The whistleblower tells the hotline vendor that documents were provided to the SEC and that counsel may contact the media if the company retaliates or delays corrective action.
PARTICIPANTS
Assign people to functions, not titles alone. If one person owns several functions, keep the roles distinct during discussion so conflicts and handoffs remain visible.
REAL-WORLD INCIDENTS
Use these cases during planning or the prebrief. They are factual anchors, not scripts. Adapt the scenario to the organization’s technology, industry, geography, contracts, regulators, and risk profile.
The SEC found disclosure-control failures relating to workplace complaints and a violation of the whistleblower protection rule. The company agreed to a $35 million penalty without admitting or denying the findings.
Uber breach-concealment prosecution↗The prosecution illustrates the personal and organizational risk created when leaders obscure a reportable event instead of escalating and documenting it accurately.
LEGAL, REGULATORY & STANDARDS LENS
Applicability depends on the organization and facts. Use counsel and subject-matter owners to tailor deadlines, thresholds, privileges, preservation, reporting, and communications.
Exercise direct-to-regulator rights, anti-retaliation safeguards, and agreement language that must not impede protected reporting.
OSHA whistleblower rights↗Use the exercise to test intake, confidentiality, interim protection, documentation, and retaliation monitoring.
SEC Rule 21F-17 order↗The order provides concrete facts for testing separation-agreement language and regulator communications.
PRACTITIONER PERSPECTIVES
External perspectives help the design team challenge internal assumptions. They do not replace organization-specific legal or technical advice.
A major-law-firm perspective on disclosure controls and Rule 21F-17 risk.
White & Case guidance on SEC whistleblower agreements↗Practical context for drafting, investigations, settlement agreements, and protected regulator communications.
EXPECTED OUTPUT