Whistleblowing Advisory Services and Legal Support - Hogan Lovells – Global Law Firm

Whistleblowing

We help clients proactively design and implement whistleblowing frameworks that align with local laws and regulatory expectations. When concerns are raised, our deep understanding of the legal and reputational risks enables us to respond swiftly, guide the initial steps with precision, and prepare clients for what follows.

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Our whistleblowing team works with clients in all sectors across the full spectrum of the whistleblowing lifecycle. Before an issue arises, we help our clients to design and implement whistleblowing policies and procedures which comply with local law and regulations. When concerns are raised, our understanding of the potential implications allows us to advise quickly, ensure the first steps taken are precise, informed and prepare our clients for what comes next.

Our team provides strategic guidance on how to respond to a whistleblower, conducting or supporting internal investigations and ensure that issues are addressed thoroughly in a manner consistent with both legal obligations and best practices.

Local issues can quickly escalate into cross-border investigations, our cross-border team are experienced in managing multi-jurisdictional matters, including those involving offshore entities. With teams across Asia-Pacific, Europe, the Americas, and the Middle East, we help you anticipate and respond to international legal risks.

In cases when whistleblowing turns to formal disputes, we are ready to represent clients in defending claims and work to resolve these matters efficiently and effectively, minimizing disruption to the business. We also represent clients in related regulatory inquiries and government proceedings, helping them respond to investigations, manage potential liability, and maintain compliance.

Through a combination of legal excellence, global insight, and a strong commitment to ethical practices, we deliver both global and local solutions tailored to the unique challenges our clients face.

Our capabilities at a glance

Representative experience

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Advised a public pharmaceutical development company where a whistleblower alleged improprieties in the clinical trials of its product that prompted FDA to postpone approval of the product. Conducted full internal investigation on behalf of the Board and resolved all allegations to its satisfaction so that the Company could move forward to close a transaction.
Advising a leading global automobile manufacturer on setting up and managing a whistleblower system for the USA, Brazil, Japan and South Africa, including advice on data protection, dealing with whistleblower reports, follow up measures and employee training.
Representing the Audit Committee of a major pharmaceutical company in a SEC whistleblower investigation which concluded with no government action against the company.
Representing a global consumer goods company on the review and implementation of a global whistleblowing and compliance reporting systems across 38 jurisdictions, including advising on related data privacy matters and the implementation of intragroup data transfer arrangements.
Dismissal of qui tam claims brought against a major pharmaceutical company, claiming an unlawful nationwide scheme to promote its drugs for “off-label” uses not approved by the Food and Drug Administration. Dismissal affirmed by the United States Court of Appeals for the First Circuit.
Representing a major Western Pennsylvania integrated health care system and its academic medical center in declined qui tam alleging violations of the civil False Claims Act and Stark Law; litigation focusing on physician compensation issues comes after we negotiated low-dollar settlement of lesser physician billing claims with the local U.S. Attorney’s Office, secured dismissal of declined claims under the Anti-Kickback Statute and on revival of Stark Law claims after remand from the Third Circuit Court of Appeals.
Conducting an internal investigation for a global medical products and technologies company, arising out of a whistleblower complaint which led to further allegations and discovery of commercial fraud and improper movement of sales incentives.
Conducting an internal investigation for a global financial services company on a whistleblowing report relating to activity on the trading desk.
Advising numerous U.S. and EU-based companies on the implementation and review of their whistleblowing and compliance reporting systems, including advice on the EU Whistleblower Directive and its impact on internal processes.
Advising a global pharmaceutical company and its Indian subsidiary on an internal investigation and parallel litigation pertaining to a whistleblowing complaint from a former employee that alleged misconduct, including harassment and fraud.
Represented a global health care and life sciences company in various Employment Tribunal claims and complex grievance and whistleblowing cases.
Conducted two whistleblower investigations for an insurance company involving senior executives, including a former General Counsel and Chief Accounting Officer.
Investigated board-level misconduct, advised on executive terminations, and defended whistleblowing and discrimination claims for a leading engineering institution.
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Resources

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Global Bribery, Investigations and Enforcement Outlook 2026
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False Claims Act Guide
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Steering the Course III

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