Whistleblowing: Europe compared to the United States

The usefulness of an anonymous whistleblowing hotline is obvious; more warnings will be picked up. However, it’s not immediately clear how a whistleblowing hotline should be set up as part of the integrity policy, at least not yet.

The American lead in the field of whistleblowing hotlines means that most practical knowledge and experience has originated from the US. The providers of the hotlines – the call centres – are also mainly located in the US, so they are designed for American principles and circumstances. When whistleblowing hotlines were embedded in daily practice at listed companies, it was nothing new for American employees, who were already well acquainted with them. However, the very opposite applied to employees in continental Europe and other parties involved. To this day, they still view the whistleblowing hotline as an unknown (and unloved) tool, as is indicated by the significant differences in the numbers of reports in the US and in continental Europe.

We can reasonably assume that the lower number of reports in Europe isn’t because there are fewer issues worth reporting. Just like American employees, European employees are a reflection of society, and there are also unacceptable things happening in Europe. The low number of reports therefore implies that lots of problems are being kept hidden.

However, copying the American approach in continental Europe and waiting for it to catch on isn’t a solution. We don’t believe this will raise the internal whistleblowing hotline in Europe to a higher level; the cultural differences are simply too great. The Anglo-Saxon approach to whistleblowing is all about protecting the whistleblower, on getting as many reports as possible via the whistleblowing hotline (which is why they are called hotlines), and emphasising the legal aspects when implementing the whistleblower procedure. Anglo-Saxon countries aren’t particularly concerned with privacy protection and avoiding a click culture. Despite all this, the unilateral approach has indeed reached the European continent, where it has caused uproar and controversy. The arguments against the introduction of whistleblowing hotlines are deeply rooted and highly emotive; comparisons are made with those who committed treachery or treason during WWII, the French Revolution, the Spanish Civil War and former authoritarian regimes where informants were rewarded for information on those opposed to an occupier or regime. This resistance mainly manifests itself in the application of privacy legislation and employee participation laws. There is, therefore, a need to adopt a European approach when setting up whistleblowing hotlines, where privacy aspects are taken into account, employee participation is well organised, the accused also has rights and, above all, cultural and historical aspects are respected.

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