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Structuring Global Whistleblower Hotlines Under the Sarbanes-Oxley Whistleblower Hotline Mandate


Product Code - INAU01
Speaker(s): Donald C. Dowling, Jr., Partner, White & Case
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Sarbanes-Oxley not only prohibits retaliating against whistleblowers (SOX section 806), it also affirmatively requires companies to set up hotlines or other "procedures" for the "confidential, anonymous submission of employee complaints and concerns" about audit/accounting fraud (SOX section 301). The SOX "hotline" provision applies to a multinational's operations worldwide. These days even many non-SOX-regulated companies launch global whistleblower hotlines. Indeed, a mini-industry of hotline-answering outsourcers has sprung up.

But any multinational's whistleblower hotline that accepts calls from employees (or customers) in Europe opens a Pandora's box of potential labor law and data-privacy law issues. A complex web of literally dozens of sets of regulations and court and agency cases at the EU level, and in many member states, sets out often-conflicting rules for how a multinational can--and cannot--offer a whistleblower hotline to European employees. This discrete area of law has grown more complex than would seem possible.

Join Donald C. Dowling Jr., International Employment Counsel in the New York legal offices of White & Case LLP, as he discusses Sarbanes-Oxley and its interplay with global whistleblower hotlines. This Webinar will explain how to launch and operate a whistleblower hotline in Europe in compliance with SOX and with these inconsistent laws. Topics covered include:

  • The gulf in social perception between a benign U.S. whistleblower hotline and a nefarious European "denunciation system"
  • What SOX does -- and does not -- require when launching a whistleblower hotline in Europe
  • Hotline compliance and labor laws in Europe
  • Hotline compliance and data privacy laws in Europe
  • Practical strategies for compliance

Donald C. Dowling, Jr., Partner, White & Case

 Dowling
Donald C. Dowling, Jr.,
 a White & Case partner and the Firm's International Employment Counsel, concentrates his practice on cross-border human resources law issues for multinational employers. Don is one of two lawyers in the US ranked in the top tier ("Leading") in the only competitive ranking of international labor/employment lawyers, London-based PLC Which Lawyer?, and he is ranked by Chambers as one of the top 34 Labor & Employment lawyers in New York. Multinationals globalizing their business operations increasingly need to align certain aspects of employment law compliance across borders and Don has over 15 years of experience managing multiple-jurisdiction employment law compliance initiatives.