March 5, 2011
I have experienced for the last eight years all of the downside of being an honest person calling upon a public company to be in compliance, and when senior members of management rejected those calls, pointing out the facts to members of the Enforcement Division and others on the Staff and other law enforcement authorities. That led to a group of since initiated administrative actions and criminal cases relating to DHB Industries, Inc., now known as Point Blank Solutions, Inc.
From that experience, I implore the Commission to adopt rules which assure responsiveness by the Staff to all serious reporting persons, and continuing contact. The worst part of my reporting to the Agency was getting no response, and having no substantive contact with a responsible source ever.
The rules should also not be wedded to the reporting person following specific precise pre-set requirements, but should be flexible enough to allow the Staff to reognize the person or persons who actually provided the earliest substantive evidene of the crimes or violations. Your best sources are, in my opinion, likely to be people who did not even think of themselves as whistleblowers, or start out on that course of action for financial reward. The rules for recognizing people for awards should allow for nominatons by Staff personnel involved in the administrative or judicial action.