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Your organisation is in scope of the EU Directive 2019/1937 and the national law transposing it and/or you need to implement internal alert arrangements under other laws and regulations, for instance CSSF Circular 12/552, Circular 18/698 or the Market abuse regulation (Regulation (EU) No 596/2014).
You want to follow the EBA Guidelines on internal governance under Directive 2013/36/EU or wish to implement whistleblowing systems voluntarily.
You want to ensure that your whistleblowing system is compliant with all the applicable regulations and best practices and allows a consistent and efficient handling of incoming alerts.
An effective whistleblowing system is not only about the creation of a mailbox or hotline. It needs to be properly communicated to ensure responsible reporting. Procedures need to detail the handling of reports, clearly outline the protection for reporting persons, but also the consequences for any misuse.
We review your existing policies and procedures and/or support you in updating all relevant communications to make your whistleblowing system as accessible and understandable as possible.
We support you in the design of your training - for all employees regarding the use of the whistleblowing system, but also for the dedicated staff handling the reports.
We advise you on the setup of an internal solution for your whistleblowing system or the choice of an external provider that fits your needs.
Our experts can assist in assessing whether an alert is substantiated, meaning if it needs further investigation. In that case, we can accompany you during the entire investigation life-cycle.
PwC and EQS Group have joined forces in a Joint Business Relationship (JBR) since August 2022, to offer a customizable solution for whistleblowing systems in line with the EU Directive 2019/1937 and GDPR.
Michael Weis
Partner, Forensic Services and Financial Crime Leader, PwC Luxembourg
Tel: +352 49 48 48 4153