Whistleblower Programs

Is a whistleblower policy mandatory for private companies in Georgia?

Generally no, except for financial institutions under AML laws. However, it is highly recommended for compliance and attracting foreign investment.

Can I fire an employee who reports a violation?

No, retaliation against a whistleblower is illegal under labor laws and can lead to lawsuits for unfair dismissal and discrimination.

How to ensure reports remain anonymous?

We recommend using third-party encrypted platforms or dedicated hotlines managed by an independent compliance officer to guarantee anonymity.

What if the report is false?

Good faith reporting is protected even if incorrect. However, malicious false reporting can be grounds for disciplinary action.

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Implementing Whistleblower Programs is an integral part of modern corporate governance culture, involving the creation of internal mechanisms that allow employees to safely and confidentially report illegal activities, unethical behavior, or corruption. In Georgia, where corporate transparency standards are increasingly refined, having such programs is not only a matter of reputational prestige but also an effective risk management tool. A whistleblower system helps management detect internal fraud, conflicts of interest, or safety violations at an early stage before these issues escalate into public scandals or legal disputes. A properly designed program ensures anonymity and protects the whistleblower from retaliation, which increases employee trust and loyalty towards the company.

What does the Whistleblower Programs service cover?

Our service focuses on creating effective and legally compliant internal systems:

  • Policy Development: Drafting a detailed document (Whistleblowing Policy) defining what constitutes a violation, how reporting is done, and what guarantees the whistleblower receives.
  • Hotline Implementation: Technical and legal setup of anonymous communication channels (email, telephone line, online platform).
  • Response Procedures: Outlining a transparent process for reviewing, investigating, and making decisions on incoming reports.
  • Training and Communication: Informing employees and managers about the existence of the program and rules for its use.
  • Protection Mechanisms: Creating legal safeguards to prevent retaliation (dismissal, demotion) against the whistleblower.

Common Scenarios and Needs

Whistleblower programs are critical in the following situations: Internal Fraud: An accountant discovers that the CFO is using company funds for personal purposes. Conflict of Interest: A procurement manager signs a contract with a relative's company without a tender. Safety Violations: A factory employee sees that labor safety norms are being violated, endangering lives. Discrimination and Harassment: An employee becomes a victim of bullying by a manager and needs a safe channel to report it.

Georgian Legislation and Regulations

The whistleblower institution in Georgia is regulated by the Law of Georgia on Conflict of Interest and Corruption in Public Institutions, which defines reporting rules and protection guarantees in the public sector. In the private sector, this area is less regulated but relies on the Labor Code (prohibition of discrimination), the Criminal Code, and international standards (e.g., ISO 37002). Additionally, the Law on Facilitating the Prevention of Money Laundering obliges certain entities (banks, financial institutions) to have internal monitoring and reporting systems.

Step-by-Step Process

Program implementation begins with assessing company risks. Lawyers draft the policy document, which is approved by the Board of Directors. Then an anonymous channel is created (e.g., an encrypted web form). A responsible person (Compliance Officer) is appointed to review incoming reports. Presentations are held for employees. After the system is launched, it is periodically audited to ensure its effectiveness and the protection of anonymity.

Why Legal.ge?

An effective whistleblower program is a sign of a healthy business. Legal.ge connects you with corporate lawyers and compliance officers experienced in implementing international-level systems. We will help you create a trust-based environment where problems are solved in-house rather than in court. Protect your business from internal threats with Legal.ge.

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