Whistleblowing and whistleblower hotlines in workplaces around the world have become very important in recent years. And so, a multinational operating internationally has a strong incentive to take a global approach here, issuing a global code of conduct, offering a global whistleblower hotline―and investigating whistleblowers’ claims in a globally consistent way.

The legal issues around whistleblowing have gotten surprisingly complex. And new whistleblowing laws have developed in quirky ways. For example, about 15 years ago, a huge hurdle was that European Union law threw up big barriers to company-sponsored whistleblower hotlines. Believe it or not, back then, France, Germany, Spain, and other European countries were hostile to whistleblower hotlines―especially ones that accepted anonymous whistleblower tips.

In those days, we had to give multinationals complex advice on how to restructure their American whistleblower hotlines for their European employees.

But then, surprisingly, the Europeans did a 180-degree about-face. In late 2021, the EU came out with its brand new “whistleblower directive” that now aggressively requires company-sponsored whistleblower hotlines (at least, at employers with 50 or more employees in a given European country). This new EU whistleblower law also prohibits whistleblower retaliation―and it establishes government hotlines. So Europe went from blocking hotlines to requiring them, and sponsoring them.

Beyond Europe and the U.S., some other...

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