Last week the U.S. Department of Labor’s Administrative Review Board (ARB) issued an order inviting all interested persons to submit briefs on whether employees of subsidiaries are protected by the Sarbanes-Oxley Act (SOX). The briefs are due July 15, 2010. The invitation comes in the case of Carri Johnson v. Siemens Building Technologies, Inc., ARB No. 08-032, 2005-SOX-15, but we can expect that the ARB will be deciding this issue for all cases in which subsidiary coverage is an issue. I plan to write one for the National Whistleblowers Center (NWC) to explain why it should be obvious that SOX intends to protect all employees under the umbrella of any publicly traded company, no matter how that company chooses to organize its operations into subsidiaries. If anyone else is interested, I would be happy to confer about the contents of our briefs.
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