Alja Poler De Zwart, Annabel Gillham, and Dan Alam authored an article for Thomson Reuters’ Practical Law discussing the European Union’s Whistleblowing Directive and whether organizations can exclusively rely on centralized whistleblowing hotlines to meet the Directive's requirements.
“As multinational organizations grapple with compliance, another major stumbling block persists, namely, whether a corporate group operating only a centralized whistleblowing hotline will meet the Whistleblowing Directive’s requirements or whether separate, local hotlines are required for each EU legal entity with more than 50 workers.”
They added: “This uncertainty stems from the European Commission Expert Group’s position that it would be ‘an incorrect transposition of the [Whistleblowing] Directive’ if member states permitted corporate groups to rely solely on centralized whistleblowing reporting channels without offering separate local reporting channels. The ECEG argues that local hotlines are more easily accessible. However, this may not be the case.”