At the time Cynthia Cooper discovered the accounting fraud, WorldCom did not have a whistleblower hotline process in place. Instead, Cynthia took on significant risks when she stepped over Scott Sullivan's head and notified the audit committee chairman of her findings. Discuss the key criteria for the operation of an effective corporate whistleblower hotline. Be sure to highlight potential pitfalls that should be avoided and reference professional codes, legislation and academic literature as appropriate.