If the parent company is foreign, would it be enough to have a centralized policy and a single manager for the whole group?

(Recitals 33 and 47)

When the parent company is foreign, having a common policy is an accepted option, but each of the obliged entities must have its own channel, procedure and System Manager. The implementation of the internal channel in each company, of a certain size, satisfies the criterion of proximity to the whistleblowers. This is one of the principles that inspires the Directive (recitals 33 and 47) and explains the misgivings expressed by the European Commission's group of experts about the centralization of the channel. In this sense, as well as to correctly calculate the workforce of the group's entities and not fall into automatisms, we recommend that you consult the recommendations and the practical guide published by the European Commission: User guide to the SME definition | Publications Office of the European Union.