A common misuse of whom that bears explaining. My general rule of course is if the relative pronoun / w-word (because it applies to interrogatives as well) is followed by a noun, it should be whom; if it is followed by a main verb, it should be who. And in this example the former applies: the relative pronoun / w-word is followed by a noun, so whom should be correct, yes? Unfortunately, no.
The noun that follows the relative pronoun in this instance is a noun in a separate clause (the company has determined); it is essentially an aside, a parenthetical, that could be easily rewritten ‘someone whom – the company has determined – did not use…’ With the dashes inserted, the incorrectness of whom becomes more apparent.
Additionally, from a meaning standpoint, the company did not determine someone; rather, the company determined that someone did not use that information…. So with the aside removed, it becomes clearer that that whom must be who: ‘refuses to scapegoat someone who the company has determined did not use that information to his advantage.