I recently came across not only a must read article for the compliance practitioner but also a must save article. In the International Lawyer, Winter 2011*Volume 45*Number 4, I came across an excellent article, entitled “How to Launch and Operate a Legally-Compliant International Workplace Report Channel” or in Foreign Corrupt Practices Act (FCPA) parlance, a hotline. It was authored by Donald Dowling of the law firm of White and Case. Dowling provides a very useful guide to help navigate the challenges of setting up a multi-national whistleblower’s hotline, such as is required under the FCPA and UK Bribery Act. The majority of his article “analyzes the six categories of laws that can restrict whistleblower hotlines abroad, focusing on compliance.” You should obtain a copy of this article and keep it for reference in regards to your company’s hotlines. It is available on the White and Case website, by clicking here.
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