Katherine D. Ashley, Gary DiBianco, Dana H. Freyer, Matthias Horbach, Pierre Servan-Schreiber of Skadden, Arps, Slate, Meagher & Flom LLP put together a nice article addressing the challenges of exporting the whistleblower requirements under Section 301 of Sarbanes-Oxley to operations in the European Union: Whistleblower Programs: Challenges for Multinational Companies.
Section 301 of the Sarbanes-Oxley Act of 2002 created a requirement that public company audit committees establish procedures for the “confidential, anonymous submission by employees of the company of concerns regarding questionable accounting or auditing matters.” Most companies have expanded the use of this hotline to include any violation of law or violation of company policy.
On the other side of the Atlantic, European labor and data protection laws offer more protection and rights to the whistleblower’s target. It is struggle to get a whistleblower hotline that works around the world. The folks at Skadden offer some suggestions in their article.