by Sharon Oded and Jessie Steinebach
Sharon Oded and Jessie Steinebach (Photos courtesy of Norton Rose Fulbright LLP)
Organizations operating multinationally often tend to establish a central whistleblowing system at headquarters level, allowing employees and third parties to raise their concerns regardless of their physical location around the world. Once a report is made, the whistleblowing team would normally triage the report, assess its nature, severity, urgency, and possible adverse impact and determine next steps in handling the report. Directive (EU) 2019/1937 (“Directive”), adopted on 23 October 2019, obliges organizations operating in the EU to change this approach.
In an article we published recently in the Compliance, Ethics and Sustainability Journal,[1] we discuss a key aspect of the implementation of the Directive which many multinational organizations appear to grapple with – should multinational organizations establish local whistleblowing channels for each separate subsidiary or can they rely on a central whistleblowing channel operated at headquarters level. In our article, we present a practical design of a hybrid whistleblowing system, compromised of a central and multiple local whistleblowing channels, which may be the most optimal way forward for multinationals wanting to comply with the Directive.