The section from the pre-AOC One World Trust report on "Independent Review of ICANN’s Accountability and Transparency – Structures and Practices" https://www.icann.org/en/about/transparency/owt-report-final-2007-en.pdf Recommendation 4.1: ICANN should clearly describe the integrated nature of the Ombudsman, Reconsideration Committee and Independent Review Panel of Board actions. The links between the three functions and their integrated nature need to be properly communicated. 100. While ICANN has three mechanisms for investigating complaints from members of the ICANN community, the organisation does not have a policy or system in place that provides staff with channels through which they can raise complaints in confidentiality and without fear of retaliation. Having such a policy (often referred to as a whistleblower policy) is good practice among global organisations. A whistleblower policy that provides such protections serves as an important means of ensuring accountability to staff as well as preventing fraudulent behaviour, misconduct and corruption within an organisation. 101. The United Nation’s whistleblower policy is an example of good practice. It includes a definition of whistleblowing consistent with good practice and provides multiple channels for reporting violations thus offering safeguards against institutionalized conflict of interest, protection for outside parties, and mandatory discipline for those who retaliated against complainants. To embed the whistleblower policy in the organisation’s culture, the UN also trains staff and senior management on the implementation of the policy. 102. While whistleblower protections already exist under both Californian state law through the California Labour Code and Federal law through the Sarbanes-Oxley Act, ICANN should comply with good practice and develop an organisation-wide whistleblower policy. This would clearly state the protections afforded to staff, provide multiple channels through which a complaint can be made and clearly identify the steps of the complaints process. ---- The idea of Independent Expert might involve OWT to follow up on this recommendation for their evaluation of the program that ICANN instituted in response. Apologies for not having provided all this information by the deadline. avri