Sarbanes-Oxley requires that companies listed on the US stock market provide a hotline for whistleblowers, so that the company can know about these concerns. This causes difficulties when applied in other countries than the US. For instance McDonalds and Exide Technologies tried to have a company wide hotline, with the data base in the US. A French juge with the CNIL (Commision National de l'Informatique et des Libertes) condemned the practice in both cases for the following 3 reasons: transfer of private information across boarders; could incite to denounce unfairly; and lack of possibility of defense for incriminated party. The only one that really holds up in court would be the transfer of private information across boarders, the rest is just filler and can be refuted, as well as providing the French with an opportunity to criticize the US. However it does pose problems for US subsidiaries abroad. The unions in France are also not too hot on ethical codes - they claim it can put the employee in a position where he knows something is wrong, but cannot do anything about it. Article in french on the subject on novethic.fr.
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