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Coming Clean and Cleaning Up: Is Voluntary Self-Reporting a Signal of Effective Self-Policing?

Michael W. Toffel
Harvard Business School (HBS) - Technology & Operations Management Unit

Jodi L. Short
Georgetown University Law Center


July 29, 2009

Harvard Business School Technology & Operations Mgt. Unit Research Paper No. 08-098

Abstract:     
Administrative agencies are increasingly establishing voluntary self-reporting programs, both as an investigative tool and as a way of encouraging regulated firms to police themselves. Effective self-policing is critical to contemporary regulatory designs, which rely heavily on regulated entities to monitor and assure their own regulatory compliance. We investigate whether self-reporting, or the voluntary disclosure of legal violations, can serve as a reliable signal of the discloser’s effective self-policing efforts, which might warrant a reduction in regulatory scrutiny. We find that voluntary disclosures are associated with improvements in regulatory compliance and environmental performance, indicating that self-reporting is associated with effective self-policing. In addition, we find evidence that regulators subsequently reduced their scrutiny over voluntary disclosers, which suggests that self-reporting can help regulators economize government enforcement resources and develop cooperative relationships with firms that are committed to self-policing.

Keywords: Self-reporting, Self-policing, Self-regulation, Voluntary Programs, Environmental Regulation, Environmental Performance, Pollution, Audits, Signaling

Working Paper Series

Date posted: July 29, 2009 ; Last revised: July 29, 2009

Suggested Citation

Toffel, Michael W. and Short, Jodi L., Coming Clean and Cleaning Up: Is Voluntary Self-Reporting a Signal of Effective Self-Policing? (July 29, 2009). Harvard Business School Technology & Operations Mgt. Unit Research Paper No. 08-098. Available at SSRN: http://ssrn.com/abstract=1440760


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J. L. Short (Contact Author)
Georgetown University Law Center ( email )
Michael W. Toffel
Harvard Business School (HBS) - Technology & Operations Management Unit ( email )
Boston, MA 02163
United States
617.384.8043 (Phone)
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