The French CNIL Publishes Guidelines on Whistle-Blowing

On November 10, 2005, further to its decision of May 2005 to prohibit whistle-blowing practices, the French Data Protection Agency (Commission nationale de l’informatique et des libertés, or "CNIL") issued its guidelines with respect to the context in which such whistle-blowing practices would be deemed legal in France and thus authorized.

It should be noted that the CNIL is pursuing its discussions with the SEC and the NYSE in order to provide more detailed guidelines in this connection and in particular with respect to other U.S. laws providing whistle-blowing obligations such as the Federal Sentencing Guidelines. In addition, the CNIL is shortly going to implement an automatic procedure to declare whistle-blowing practices and obtain appropriate authorizations for them. This procedure will take the form of a "sole authorization" enabling companies that comply with the guidelines adopted by the CNIL to file a standard declaration of compliance with the CNIL and avoid having to