Global Whistleblower Hotline Toolkit: How to Launch and Operate a Legally-Compliant International Workplace Report Channel

White & Case LLP

As corporate social responsibility and business ethics continue to grab our attention, ever-more-sophisticated “best practices” and compliance strategies emerge. A key practice that anchors many corporate social responsibility programs and compliance initiatives is launching and publicizing an internal whistleblower procedure, report channel, or “hotline” that entices insiders to denounce colleagues’ misdeeds so management can root out corporate crimes, corruption and cover-ups.

Domestically within the US, workplace whistleblower hotlines are a largely uncontroversial “best practice” to which few ever object. But tensions rise when a multinational extends report channels abroad. Overseas, whistleblower hotlines can spark blowback from staff, employee representatives and government enforcers and can trigger confounding legal issues without US counterpart. To a socially responsible American, the hurdles impeding foreign whistleblower hotlines look higher than they should have any right to get.

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