Over the past few years, US and multinational corporations have
invested heavily in assuring compliance with the stringent demands
of the 2002 Sarbanes-Oxley Act (SOX). As its scope extends far
beyond United States boundaries, US executives must not only
restructure corporate policies in parent companies, but also those
of foreign subsidiaries.
Currently, there are approximately 375 US companies with
subsidiaries in Denmark (excluding multinational corporations
listed on the US stock exchange). Questions as to whether the SOX
Code of Conduct is actually applicable in Denmark remain, as of
today, unanswered.
One issue, the whistleblowing issue and the proportions it has
taken in the SOX Code of Conduct (e.g. anonymous hotlines, etc.),
has raised particular concern: although Danish legislation does not
specifically deal with this problem, whistleblowing policies could,
to a certain degree, be in direct conflict with local case law,
legal customs, culture, etc.
