

he Whistleblower Directive (Directive (EU) 2019/1937) (the Directive) requires every company or public body in the EU that has 250 or more employees to implement its own internal reporting policy for whistleblowing. Whilst one interpretation of the Directive allows for companies to have a group-level whistleblowing regime, the Directive is being interpreted by the EU Expert Group and the European Commission as requiring each subsidiary with 250 or more employees to have a separate internal reporting channel at the local level, and to give whistleblowers the option to report at the local or group level.
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The Whistleblower Directive (Directive (EU) 2019/1937) (the Directive) requires every company or public body in the EU that has 250 or more employees to implement its own internal reporting policy for whistleblowing. Whilst one interpretation of the Directive allows for companies to have a group-level whistleblowing regime, the Directive is being interpreted by the EU Expert Group and the European Commission as requiring each subsidiary with 250 or more employees to have a separate internal reporting channel at the local level, and to give whistleblowers the option to report at the local or group level.
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