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Letter Summary:
We agree with Staff’s recommendation that the anti-retaliation provisions should apply to persons who report directly to the OSC and through their own internal reporting mechanisms. Without the latter protection, potential whistleblowers who report internally but who choose not to report further to the OSC would be disadvantaged, thus discouraging the internal reporting to compliance which is a core function of our markets.
Overview of the Council’s Comments:
We support the principles behind the proposed whistleblower program which is intended to encourage persons to report knowledge of possible serious breaches of securities law to the OSC.