Whistleblower Line
SOX and DOJ requirements

Know which rules apply. Show you meet them.

A plain-English guide to the US rules behind whistleblower hotlines, and how Whistleblower Line supports each one.

SOX Section 301

Applies to: US-listed public companies
What it asks

Audit committees must set up procedures to receive, keep, and handle complaints about accounting, internal controls, and auditing. Employees must be able to raise these concerns confidentially and anonymously.

How Whistleblower Line helps

Anonymous phone and web intake. Accounting concerns route straight to the audit committee chair. Records kept in a secure, searchable archive.

SOX Section 806

Applies to: employees of public companies
What it asks

Protect your people. The anti-retaliation provision (18 U.S.C. §1514A) prohibits covered companies, their officers, contractors, and others from retaliating against employees who report certain fraud or securities-law violations, internally or externally.

How Whistleblower Line helps

Retaliation is its own report category, so concerns about payback are tracked and routed like any other case.

SEC Rule 21F-17

Applies to: any company, especially SEC-regulated firms
What it asks

No one may stop a person from talking directly to the SEC about a possible securities violation. That includes enforcing or threatening to enforce a confidentiality agreement.

How Whistleblower Line helps

Our reporting pages remind staff they can always go to regulators directly.

DOJ compliance guidance (2024 update)

Applies to: companies facing a federal investigation
What it asks

Prosecutors ask whether a company has an anonymous reporting channel, whether staff know and trust it, and how the company prevents retaliation.

How Whistleblower Line helps

Awareness pulse surveys, manager training, anti-retaliation tracking, and metrics you can show a prosecutor or your board.

Federal Sentencing Guidelines

Applies to: any organization seeking credit for an effective compliance program
What it asks

Organizations should take reasonable steps to have and publicize a system where employees can report concerns or seek guidance without fear of retaliation, which may include anonymous or confidential reporting.

How Whistleblower Line helps

Anonymous phone and web reporting, plus a launch kit with posters and custom QR codes so the system is publicized, not just installed.

US state laws

Applies to: depends on your state and industry
What it asks

Whistleblower protections for private employers differ from state to state, and some industries have their own rules.

How Whistleblower Line helps

We do not give legal advice. We give you the channel, the records, and the reports your lawyer will ask for.

What the DOJ and regulators look for

DOJ compliance guidance (updated September 2024)
  • Effective, accessible, and well-publicized confidential or anonymous reporting
  • Policies and practices that encourage reporting, rather than ones that chill it
  • Strong anti-retaliation policies, plus training on internal policies and on outside whistleblower laws and programs
  • Checks on whether employees are actually willing and comfortable to report
  • Proper investigation of reports, review of reporting data for patterns, and fair treatment of employees who report
  • No practices, including certain NDAs, that discourage reporting to the government
What your hotline system should support
  • Anonymous and confidential intake across more than one channel: web, phone, and others
  • Secure record keeping, audit trails, and case documentation
  • Escalation paths that give the audit committee access to SOX accounting and auditing matters
  • Reports that show anti-retaliation steps, investigation quality, and program results to the DOJ, SEC, or other regulators
  • A channel that is easy to reach and well publicized, so people actually use it

Private companies are not subject to SOX Section 301, but many adopt similar practices to meet DOJ expectations, contract requirements, or general risk management. Review the requirements that apply to your company where you operate.

Program checklist

Ten things a strong speak-up program has.

Use it to check your program today. Whistleblower Line covers the channel, routing, records, and reporting.

  1. An anonymous channel, by phone and web, open 24/7
  2. A written whistleblower and anti-retaliation policy
  3. Regulator carve-outs in every confidentiality agreement
  4. Routing that keeps accounting concerns with the audit committee
  5. Nobody investigates a case that names them
  6. Reporters get acknowledgment and feedback
  7. Managers trained to receive concerns
  8. A yearly check that staff know and trust the hotline
  9. Case records kept securely, with an audit trail
  10. Board reporting on volume, types, and closure time
See plans

This page is general information, not legal advice. Rules change and depend on your company, industry, and location. Review your program with qualified counsel.