From Retaliation to Reinvention
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When Noelle Webb first blew the whistle on her employer, pharmaceutical company Depomed, for illegally marketing opioid pain medications, the U.S. was deep into a yearslong epidemic of opioid use. Hundreds of thousands of people were addicted to drugs that, in many cases, had been prescribed to them by their doctor. Webb knew that what her company was asking her to do was wrong, and she decided to speak up. What followed was severe retaliation from her employer and a decade of litigation. But through her journey as a whistleblower, Webb found courage and healing through her work training service dogs.
Webb, accompanied by Tully, the first dog she trained, recounted her experience to thousands of attendees at the 37th Annual ACFE Global Fraud Conference. Andi McNeal, CFE, CPA, chief operating officer of the Association of Certified Fraud Examiners (ACFE), interviewed Webb about the emotional and psychological effects of being a whistleblower and the powerful, healing connection between humans and canines.
Standing With the Truth
Webb’s story illustrates how speaking truth to power can have devastating consequences. As she described in her book, “Leash of Courage,” her decision to become a whistleblower “was a manifestation of my lifelong personality traits coming together in one perfect storm.” She told conference attendees her moral integrity drove her to speak up. “That overrode every rational thing that I could possibly think of or every excuse that I could come up with — a deep sense of knowing right from wrong.”
Webb said that having an “inherent sense of perseverance,” helped get her through more than a decade of litigation against her former employer. Another personality trait she described as something particularly unique to whistleblowers (and anti-fraud professionals) is the ability to recognize patterns. “You understand when something is just not right and something doesn't fit,” said Webb. “I think a lot of people in my situation and many whistleblowers struggle with, ‘Am I seeing this correctly? Are these really the facts?’ And you sit with those for months, sometimes years, before you ever speak up.” When whistleblowers finally speak up, they realize that what they’re seeing is a fraught pattern. The next step is having courage to “stand with the truth no matter how long it takes.”
Having courage is a prominent theme in Webb’s whistleblower story. During the session, McNeal asked Webb about the role that it plays for whistleblowers in coming forward.
“I would say moral courage, the ability to withstand personal loss in defense of your own ethical values, is probably the number one driving factor of anyone who blows the whistle,” Webb said. “But just because I had moral courage didn't mean that I was fearless. I was deeply fearful. I was fearful of the unknown. I knew what a whistleblower was, but I didn't know exactly what happened to them or how it happened or how long it took. I just had no idea. But when you're in the middle of it, when you're in the middle of a fire, all you want to do is get through to the other side. And that's what it felt like. It felt like I was in a fire, and I just had to keep moving forward to get out of it.”
Understanding the Mind of a Whistleblower
Webb’s journey from whistleblower to service dog trainer included learning about neuroscience. It might seem unusual, but the innerworkings of the brain are key to understanding the bond that develops between humans and canines. It’s also important in understanding the mind of a whistleblower. Webb described a part of the brain called the anterior cingulate gyrus (ACG). “It is a brain structure that sits in the midbrain, and it connects our primitive brain to our thinking brain. Basically, it is a conflict detector.” Webb explained that everybody has an ACG — even dogs. “Dogs proportionately have a much larger anterior cingulate gyrus than humans do,” Webb said. “That kind of accounts for why they are so emotionally attached to us.”
For Webb, her ACG acted like a flashing red light, alerting her to blow the whistle. “This anterior cingulate gyrus is flashing at me saying, ‘You need to do something’,” she said. “Because whistleblowers also have a profound sense of responsibility, especially to preventing harm to others. That anterior cingulate gyrus was saying, ‘Girl, you better take some action,’ and that's exactly what happened … I was compelled to speak up.”
By 2011, Webb had spent nearly three decades as a pharmaceutical sales representative. She was knowledgeable about the medications she sold and the legal restrictions of the job. She received accolades and awards for her service. As an astute sales rep, she read the weekly Morbidity and Mortality Report, which reports on disease occurrences. “I was tracking the disease incidence with what the company was claiming to be our prospective audience. And the sales goals were so elevated in comparison to the disease incidents.” She recalled how the data didn’t match up to the claims that her employer was making about the pain medications it was selling and what they could be used for. She decided to ask a simple question at work: How are the sales goals calculated? “That seems like a nonconfrontational question for a salesperson, but the answer I received was so vague and evasive that I knew it was a problem.”
Webb told conference attendees that the retaliation at work began almost immediately after asking that basic question. “I felt like the retaliation made me more resolute in wanting to speak the truth because they were trying to silence me, and instead of listening to the message, they were attacking the messenger,” she said. “Now I was being attacked personally. And once I was attacked personally, the issue had escalated into something far greater than I had ever anticipated.”
According to Webb, “telling the truth doesn’t always set you free, at least initially.” Telling the truth to her bosses made her a target, but it also kept her going.
Facing Retaliation
Webb filed two separate False Claims Act lawsuits in 2014. Because they’re filed under seal, Webb couldn’t talk about what happened to her until suits were resolved in 2025. But she received a minimal settlement despite the mounds of evidence she’d collected. “Once I realized what the company was doing, which didn't really take me that long, and the retaliation started shortly after I was hired, I knew that my job was to gather evidence,” she said. “It was very disheartening to know that in the end the evidence didn't make a lot of difference.”
And even though it’s against the law in the U.S. to retaliate against whistleblowers, her legal team failed to win her retaliation case. “We lost the retaliation claim on a technicality after 11 years,” she said.
Webb described the disappointment she felt after the resolution of her claims. She said that she felt disappointed in herself. “I think that standing up and having the courage to stand up is really what sustained me. I know that I did this and I should be proud of that. But in the background was all the hurt and all the years that seemed lost. But it was all in standing up for the truth. And I will never regret standing up for my principles.” Webb says the hardest part was seeing how her family struggled along with her. “There were so many areas of my life that were affected by the retaliation. When you see your family or your children suffering, that's a whole different level of suffering.”
During the interview, Webb recounted what she’d learned through her work with dogs about whistleblowers, courage and the human experience. Tully had been a birthday gift as Webb’s lawsuits wended their way through the circuitous U.S. federal court system. She was isolated and unable to speak about her case. “Tully came into my life at the most vulnerable time for me. And when I say she saved my life that’s not hyperbole, because I was literally drowning not only in retaliation, but I had some personal loss in my life. And the sorrow of that compounded on top of the additional length of the litigation was very difficult to manage.”
Finding Another Purpose
Tully inspired Webb to understand the bond between humans and dogs, so she pursued a master’s degree in human-canine life sciences and started training service dogs for people with disabilities and military veterans with PTSD. “I could recognize their grief and their sorrow, and the calming effect that a dog had on these people and how the dogs could bring them and me out of isolation and back to a purposeful, meaningful life.”
“I trained Tully as my own service dog while also working with others with PTSD and training their service dogs,” said Webb. “Her job description is lifesaver.”
Tully, who’d been sleeping on stage during the session, woke up for the applause she received from conference attendees.
To conclude the session, Webb returned to the personality traits that drive whistleblowers to come forward. “Whistleblowers are a very strange bunch. We're hard to silence. We're very stubborn. And most whistleblowers would say, despite the profound loss and the retaliation, they would do it again,” she said. “How could I not report fraud if I saw it? That's inherent in me. And it would go against everything that I had stood for and all my ethical values if I did not report it.”
She said that she’d blow the whistle again. “I would be better prepared. There are resources that are now available that weren't available when I first started, places like Whistleblowers of America, who can lead you to a legal team that would probably have better results than mine did.” She said that knowing what to expect and being prepared “for the battle” would’ve helped her endure the retaliation just a little bit more.
