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European SOX Compliance After <i>McDonald's</i> and <i>Wal-Mart</i>
The Sarbanes-Oxley Act (SOX), at '301 and '406, affirmatively requires SOX-regulated companies to set up anonymous hotlines or other mechanisms that encourage employees to “whistleblow” on co-workers who commit financial, auditing, or accounting frauds. For multinationals, this seemingly-simple rule raises an international law issue that has mushroomed into a vital concern: How does SOX's hotline requirement apply to employees abroad?
American multinationals subject to SOX tend to offer their foreign employees an extension of their stateside SOX policy and hotline. The standard SOX policy requires employees to report co-worker audit/accounting frauds using a telephone, e-mail or postal mail hotline that accepts anonymous tips.
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