Whistleblower

For other uses, see Whistleblower (disambiguation).
For whistleblower protection in the United States, see Whistleblower protection in the United States.

A whistleblower (whistle-blower or whistle blower)[1] is a person who exposes misconduct, alleged dishonest or illegal activity occurring in an organization. The alleged misconduct may be classified in many ways; for example, a violation of a law, rule, regulation and/or a direct threat to public interest, such as fraud, health and safety violations, and corruption. Whistleblowers may make their allegations internally (for example, to other people within the accused organization) or externally (to regulators, law enforcement agencies, to the media or to groups concerned with the issues). It can be taken also in positive manner and in negative manner also.

Whistleblowers frequently face reprisal, sometimes at the hands of the organization or group which they have accused, sometimes from related organizations, and sometimes under law. Questions about the legitimacy of whistleblowing, the moral responsibility of whistleblowing, and the appraisal of the institutions of whistleblowing are part of the field of political ethics.

Overview

Origin of term

The term whistle-blower comes from the whistle a referee uses to indicate an illegal or foul play.[2][3] US civic activist Ralph Nader coined the phrase in the early 1970s to avoid the negative connotations found in other words such as "informers" and "snitches".[4]

Internal

Most whistleblowers are internal whistleblowers, who report misconduct on a fellow employee or superior within their company. One of the most interesting questions with respect to internal whistleblowers is why and under what circumstances people will either act on the spot to stop illegal and otherwise unacceptable behavior or report it.[5] There are some reasons to believe that people are more likely to take action with respect to unacceptable behavior, within an organization, if there are complaint systems that offer not just options dictated by the planning and control organization, but a choice of options for absolute confidentiality.[6]

External

External whistblowers, however, report misconduct to outside persons or entities. In these cases, depending on the information's severity and nature, whistleblowers may report the misconduct to lawyers, the media, law enforcement or watchdog agencies, or other local, state, or federal agencies. In some cases, external whistleblowing is encouraged by offering monetary reward.

Third party

The third party service involves utilizing an external agency to inform the individuals at the top of the organizational pyramid of misconduct, without disclosing the identity of the whistleblower. This is a relatively new phenomenon and has been developed due to whistleblower discrimination. International Whistleblowers is an example of an organization involved in delivering a third party service for whistleblowers.

Common reactions

Whistleblowers are sometimes seen as selfless martyrs for public interest and organizational accountability; others view them as "traitors" or "defectors." Some even accuse them of solely pursuing personal glory and fame, or view their behavior as motivated by greed in qui tam cases. Some academics (such as Thomas Alured Faunce) feel that whistleblowers should at least be entitled to a rebuttable presumption that they are attempting to apply ethical principles in the face of obstacles and that whistleblowing would be more respected in governance systems if it had a firmer academic basis in virtue ethics.[7][8]

It is probable that many people do not even consider blowing the whistle, not only because of fear of retaliation, but also because of fear of losing their relationships at work and outside work.[9]

Persecution of whistleblowers has become a serious issue in many parts of the world:

Employees in academia, business or government might become aware of serious risks to health and the environment, but internal policies might pose threats of retaliation to those who report these early warnings. Private company employees in particular might be at risk of being fired, demoted, denied raises and so on for bringing environmental risks to the attention of appropriate authorities. Government employees could be at a similar risk for bringing threats to health or the environment to public attention, although perhaps this is less likely.[10]

There are examples of "early warning scientists" being harassed for bringing inconvenient truths about impending harm to the notice of the public and authorities. There have also been cases of young scientists being discouraged from entering controversial scientific fields for fear of harassment.[10]

Although whistleblowers are often protected under law from employer retaliation, there have been many cases where punishment for whistleblowing has occurred, such as termination, suspension, demotion, wage garnishment, and/or harsh mistreatment by other employees. For example, in the United States, most whistleblower protection laws provide for limited "make whole" remedies or damages for employment losses if whistleblower retaliation is proven. However, many whistleblowers report there exists a widespread "shoot the messenger" mentality by corporations or government agencies accused of misconduct and in some cases whistleblowers have been subjected to criminal prosecution in reprisal for reporting wrongdoing.

As a reaction to this many private organizations have formed whistleblower legal defense funds or support groups to assist whistleblowers; three such examples are the National Whistleblowers Center[11] in the United States, and Whistleblowers UK [12] and Public Concern at Work (PCaW)[13] in the United Kingdom. Depending on the circumstances, it is not uncommon for whistleblowers to be ostracized by their co-workers, discriminated against by future potential employers, or even fired from their organization. This campaign directed at whistleblowers with the goal of eliminating them from the organization is referred to as mobbing. It is an extreme form of workplace bullying wherein the group is set against the targeted individual.[14]

Psychological impact

There is limited research on the psychological impacts of whistle blowing. However, poor experiences of whistleblowing can cause a prolonged and prominent assault upon staff well being. As workers attempt to address concerns, they are often met with a wall of silence and hostility by management.[15] Some whistleblowers speak of overwhelming and persistent distress, drug and alcohol problems, paranoid behaviour at work, acute anxiety, nightmares, flashbacks and intrusive thoughts.[16] Depression is often reported by whistleblowers, and suicidal thoughts may occur in up to about 10%.[17][18] General deterioration in health and self care has been described.[19] The range of symptomatology shares many of the features of posttraumatic stress disorder, although there is debate about whether the trauma experienced by whistleblowers meets diagnostic thresholds.[20] Increased stress related physical illness has also been described in whistleblowers.[18][21]

The stresses involved in whistleblowing can be huge. As such, workers remain afraid to blow the whistle, in fear that they will not be believed or they have lost faith in believing that anything will happen if they do speak out.[22] This fear may indeed be justified, because an individual who feels threatened by whistleblowing, may plan the career destruction of the ‘complainant’ by reporting fictitious errors or rumours.[23] This technique, labelled as ‘gaslighting’ is a common, unconventional approach used by organizations to manage employees who cause difficulty by raising concerns.[24] In extreme cases, this technique involves the organization or manager proposing that the complainant’s mental health is unstable.[25]

Organizations also often attempt to ostracise and isolate whistleblowers by undermining their concerns by suggesting that these are groundless, carrying out inadequate investigations or by ignoring them altogether. Whistleblowers may also be disciplined, suspended and reported to professional bodies upon manufactured pretexts.[26][27] Where whistleblowers persist in raising their concerns, they increasingly risk detriments such as dismissal.[28] Following dismissal, whistleblowers may struggle to find further employment due to damaged reputations, poor references and blacklisting. The social impact of whistleblowing through loss of livelihood (and sometimes pension), and family strain may also impact on whistleblowers’ psychological well being. Whistleblowers may also experience immense stress as a result of litigation regarding detriments such as unfair dismissal, which they often face with imperfect support or no support at all from unions. Whistleblowers who continue to pursue their concerns may also face long battles with official bodies such as regulators and government departments.[26][27] Such bodies may reproduce the “institutional silence” by employers, adding to whistleblowers’ stress and difficulties.[29] In all, some whistleblowers suffer great injustice, that may never be acknowledged or rectified.[25]

Such extreme experiences of threat and loss inevitably cause severe distress and sometimes mental illness, sometimes lasting for years afterwards. This mistreatment also deters others from coming forward with concerns. Thus, poor practices remain hidden behind a wall of silence, and prevent any organization from experiencing the improvements that may be afforded by intelligent failure.[16][29]

Some whistleblowers who part ranks with their organizations have had their mental stability questioned, such as Adrian Schoolcraft, the NYPD veteran who alleged falsified crime statistics in his department and was forcibly committed to a mental institution.[30]

Legal protection

Legal protection for whistleblowing varies from country to country and may depend on any of the country of the original activity, where and how secrets were revealed, and how they eventually became published or publicized. Over a dozen countries have now adopted comprehensive whistleblower protection laws which create mechanisms for reporting wrongdoing and provide legal protections to the people who informed them. Over 50 countries have adopted more limited protections as part of their anti-corruption, freedom of information, or employment laws.[31] For purposes of the English Wikipedia, this section emphasizes the English-speaking world and covers other regimes only insofar as they represent exceptionally greater or lesser protections.

Australia

There are laws in a number of states.[32] The former NSW Police Commissioner Tony Lauer summed up official government and police attitudes as: "Nobody in Australia much likes whistleblowers, particularly in an organization like the police or the government." Mr Lauer's comments are clearly at odds with public support for WikiLeaks.

Whistleblowers Australia is an association for those who have exposed corruption or any form of malpractice, especially if they were then hindered or abused.[33]

Canada

The Office of the Public Sector Integrity Commissioner of Canada (PSIC) provides a safe and confidential mechanism enabling public servants and the general public to disclose wrongdoings committed in the public sector. It also protects from reprisal public servants who have disclosed wrongdoing and those who have cooperated in investigations. The Office’s goal is to enhance public confidence in Canada’s federal public institutions and in the integrity of public servants.[34]

Mandated by the Public Servants Disclosure Protection Act (The Act), PSIC is a permanent and independent Agent of Parliament. The Act, which came into force on April 15, 2007, applies to most of the federal public sector, approximately 400,000 public servants.[35] This includes government departments and agencies, parent Crown corporations, the Royal Canadian Mounted Police and other federal public sector bodies.

Not all disclosures lead to an investigation as the Act sets out the jurisdiction of the Commissioner and gives the option not to investigate under certain circumstances. On the other hand, if PSIC conducts an investigation and finds no wrongdoing was committed, the Commissioner must report his findings to the discloser and to the organization’s chief executive. Also, reports of founded wrongdoing are presented before the House of Commons and the Senate in accordance with The Act. As of June 2014, a total of 9 reports have been tabled in Parliament.[36]

The Act also established the Public Servants Disclosure Protection Tribunal (PSDPT) to protect public servants by hearing reprisal complaints referred by the Public Sector Integrity Commissioner. The Tribunal can grant remedies in favour of complainants and order disciplinary action against persons who take reprisals.

PSIC’s current Commissioner is Mr. Mario Dion. Previously, he has served in various senior roles in the public service, including as Associate Deputy Minister of Justice, Executive Director and Deputy Head of the Office of Indian Residential Schools Resolution of Canada, and as Chair of the National Parole Board.

Jamaica

In Jamaica, the Protected Disclosures Act, 2011[37] received assent in March 2011. It creates a comprehensive system for the protection of whistleblowers in the public and private sector. It is based on the UK's Public Interest Disclosure Act.

India

The Government of India has been considering adopting a whistleblower protection law for several years. In 2003, the Law Commission of India recommended the adoption of the Public Interest Disclosure (Protection of Informers) Act, 2002.[38] In August 2010, the Public Interest Disclosure and Protection of Persons Making the Disclosures Bill, 2010 was introduced into the Lok Sabha, lower house of the Parliament of India.[39] The Bill was approved by the cabinet in June, 2011. The Public Interest Disclosure and Protection of Persons Making the Disclosures Bill, 2010 was renamed as The Whistleblowers' Protection Bill, 2011 by the Standing Committee on Personnel, Public Grievances, Law and Justice.[40] The Whistleblowers' Protection Bill, 2011 was passed by the Lok Sabha on 28 December 2011.[41] and by the Rajyasabha on 21 February 2014. The Whistle Blowers Protection Act, 2011 has received the Presidential assent on May 9, 2014 and the same has been subsequently published in the official gazette of the Government of India on May 9, 2014 by the Ministry of Law and Justice, Government of India.

Ireland

The government of Ireland committed to adopting a comprehensive whistleblower protection law in January 2012. The bill will reportedly cover both the public and private sectors.[42]

Netherlands

The Netherlands has measures in place to mitigate the risks of whistleblowing: the whistleblower advice centre (Adviespunt Klokkenluiders) offers advice to whistleblowers, and the Parliament recently passed a proposal to establish a so-called house for whistleblowers, to protect them from the severe negative consequences that they might endure (Kamerstuk, 2013). Dutch media organizations also provide whistleblower support; on 9 September 2013 [43] a number of major Dutch media outlets supported the launch of Publeaks, which provides a secure website for people to leak documents to the media. Publeaks is designed to protect whistleblowers. It operates on the GlobaLeaks software developed by the Hermes Center for Transparency and Digital Human Rights, which supports whistleblower-oriented technologies internationally.[44]

Switzerland

The Swiss Council of States agreed on a draft amendment of the Swiss Code of Obligations in September 2014. The draft introduces articles 321abis to 321asepties, 328(3), 336(2)(d).[45] An amendment of article 362(1) adds articles 321abis to 321asepties to the list of provisions that may not be overruled by labour and bargaining agreements.
Article 321ater introduces an obligation on employees to report irregularities to their employer before reporting to an authority. An employee will, however, not breach his duty of good faith if he reports an irregularity to an authority and

Article 321aquarter provides that an employee may exceptionally directly report to an authority. Exceptions apply in cases

The draft does not improve on protection against dismissal for employees who report irregularities to their employer.[46] The amendment does not provide for employees anonymously filing their observations of irregularities.

United Kingdom

Whistleblowing in the United Kingdom is subject to the Public Interest Disclosure Act (PIDA) 1998.

The Freedom to Speak Up Review set out 20 principles to bring about improvements to help whistleblowers in the NHS, including:[47]

United States

Under most federal whistleblower statutes, in order to be considered a whistleblower in the United States, the federal employee must have reason to believe his or her employer has violated some law, rule or regulation; testify or commence a legal proceeding on the legally protected matter; or refuse to violate the law.

In cases where whistleblowing on a specified topic is protected by statute, U.S. courts have generally held that such whistleblowers are protected from retaliation.[48] However, a closely divided U.S. Supreme Court decision, Garcetti v. Ceballos (2006) held that the First Amendment free speech guarantees for government employees do not protect disclosures made within the scope of the employees' duties.

In the United States, legal protections vary according to the subject matter of the whistleblowing, and sometimes the state in which the case arises.[49] In passing the 2002 Sarbanes–Oxley Act, the Senate Judiciary Committee found that whistleblower protections were dependent on the "patchwork and vagaries" of varying state statutes.[50] Still, a wide variety of federal and state laws protect employees who call attention to violations, help with enforcement proceedings, or refuse to obey unlawful directions.

The first US law adopted specifically to protect whistleblowers was the 1863 United States False Claims Act (revised in 1986), which tried to combat fraud by suppliers of the United States government during the American Civil War. The Act encourages whistleblowers by promising them a percentage of the money recovered by the government and by protecting them from employment retaliation.[51]

Another US law that specifically protects whistleblowers is the Lloyd–La Follette Act of 1912. It guaranteed the right of federal employees to furnish information to the United States Congress. The first US environmental law to include an employee protection was the Clean Water Act of 1972. Similar protections were included in subsequent federal environmental laws, including the Safe Drinking Water Act (1974), Resource Conservation and Recovery Act (1976), Toxic Substances Control Act of 1976, Energy Reorganization Act of 1974 (through 1978 amendment to protect nuclear whistleblowers), Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, or the Superfund Law) (1980), and the Clean Air Act (1990). Similar employee protections enforced through OSHA are included in the Surface Transportation Assistance Act (1982) to protect truck drivers, the Pipeline Safety Improvement Act (PSIA) of 2002, the Wendell H. Ford Aviation Investment and Reform Act for the 21st Century ("AIR 21"), and the Sarbanes–Oxley Act, enacted on July 30, 2002 (for corporate fraud whistleblowers).

Investigation of retaliation against whistleblowers under 20 federal statutes falls under the jurisdiction of the Office of the Whistleblower Protection Program[52] of the United States Department of Labor's[53] Occupational Safety and Health Administration (OSHA).[54] New whistleblower statutes enacted by Congress which are to be enforced by the Secretary of Labor are generally delegated by a Secretary's Order[55] to OSHA's Office of the Whistleblower Protection Program (OWPP).

The patchwork of laws means that victims of retaliation need to be aware of the laws at issue to determine the deadlines and means for making proper complaints. Some deadlines are as short as 10 days (Arizona State Employees have 10 days to file a "Prohibited Personnel Practice" Complaint before the Arizona State Personnel Board), while others are up to 300 days.

Those who report a false claim against the federal government, and suffer adverse employment actions as a result, may have up to six years (depending on state law) to file a civil suit for remedies under the US False Claims Act (FCA).[56] Under a qui tam provision, the "original source" for the report may be entitled to a percentage of what the government recovers from the offenders. However, the "original source" must also be the first to file a federal civil complaint for recovery of the federal funds fraudulently obtained, and must avoid publicizing the claim of fraud until the US Justice Department decides whether to prosecute the claim itself. Such qui tam lawsuits must be filed under seal, using special procedures to keep the claim from becoming public until the federal government makes its decision on direct prosecution.

Other countries

There are comprehensive laws in New Zealand and South Africa. A number of other countries have recently adopted comprehensive whistleblower laws including Ghana, South Korea, and Uganda. They are also being considered in Kenya and Rwanda. The European Court of Human Rights ruled in 2008 that whistleblowing was protected as freedom of expression.[57]

Advocacy for whistleblower rights and protections

Many NGOs advocate for stronger and more comprehensive legal rights and protections for whistleblowers. Among them are the Government Accountability Project (GAP), Blueprint for Free Speech, Public Concern at Work (PCaW) and the Open Democracy Advice Center (ODAC). Among the more publicly visible whistleblower activists are Thomas M. Devine of GAP, Cathy James of PCaW, Mark Worth of Blueprint for Free Speech.

See also

Notes and references

  1. "Yahoo Education". Education.yahoo.com. Retrieved 2012-07-08.
  2. "Etymonline.com". Etymonline.com. Retrieved 2012-07-08.
  3. "Wordorigins.org". Wordorigins.org. Retrieved 2012-07-08.
  4. Nader, Petkas, and Blackwell, Whistleblowing (1972).
  5. Dealing with—or reporting—"unacceptable" behavior (with additional thoughts about the "Bystander Effect") Mary Rowe MIT, Linda Wilcox HMS, Howard Gadlin NIH (2009), Journal of the International Ombudsman Association 2(1), online at ombudsassociation.org
  6. Mary Rowe, "Options and choice for conflict resolution in the workplace" in Negotiation: Strategies for Mutual Gain, by Lavinia Hall (ed.), Sage Publications, Inc., 1993, pp. 105–119.
  7. Faunce, T.A. "Developing and Teaching the Virtue-Ethics Foundations of Healthcare Whistle Blowing", Monash Bioethics Review. 2004; 23(4): 41–55
  8. Faunce, T.A. and Jefferys, S. "Whistleblowing and scientific misconduct: Renewing legal and virtue ethics foundations". Journal of Medicine and Law 2007, 26(3): 567–84.
  9. Rowe, Mary & Bendersky, Corinne, "Workplace Justice, Zero Tolerance and Zero Barriers: Getting People to Come Forward in Conflict Management Systems," in Negotiations and Change, From the Workplace to Society, Thomas Kochan and Richard Locke (eds), Cornell University Press, 2002. See also "Dealing with — or Reporting — 'Unacceptable' Behavior (With additional thoughts about the 'Bystander Effect')" ©2009Mary Rowe MIT, Linda Wilcox HMS, Howard Gadlin NIH, Journal of the International Ombudsman Association 2(1), online at ombudsassociation.org
  10. 10.0 10.1 European Environment Agency) (Jan 23, 2013). "Late lessons from early warnings: science, precaution, innovation: Full Report". p. 614.
  11. "whistleblowers.org". whistleblowers.org. Retrieved 2012-07-08.
  12. "whistleblowersUK.org". whistlebloweruk.org. Retrieved 2014-03-07.
  13. "pcaw.co.uk". pcaw.co.uk. Retrieved 2012-07-08.
  14. Matthiesen SB, Bjorkelo B, Burke RJ “Workplace Bullying as the Dark Side of Whistleblowing” in Bullying and Harassment in the Workplace: Developments in Theory, Research, and Practice (2012)
  15. Drew D (29 January 2015) Francis NHS whistleblower report: a new beginning? The Guardian
  16. 16.0 16.1 Peters, K. et al. (2011). The emotional sequelae of whistleblowing: findings from a qualitative study. Journal of Clinical Nursing, 20: P2907-14.
  17. Farnsworth CH (22 February 1987) Survey of Whistleblowers finds retaliation, but few regrets The New York Times
  18. 18.0 18.1 Lennane J (11 September 1993) "Whistleblowing": a health issue. 307(6905): P667–670
  19. Greaves R, McGlone JK (2012) The Health Consequences of Speaking Out Social Medicine Vol 6, No 4 P259-263
  20. Bjørkelo, B. (2013). Workplace bullying after whistleblowing: Future research and implications. Journal of Managerial Psychology, 28(3), P306-323
  21. Lennane J (17 November 1995) The canary down the mine: what whistleblowers' health tells us about their environment Paper given at Department of Criminology, Melbourne University, conference: "Whistleblowers: protecting the nation's conscience?"
  22. Sprinks J (2014) Survey highlights slow progress in increasing staff whistleblowing. Nursing Standard Feb 12-18;28(24) P14-5
  23. De Silva, P (2014) Tackling psychopathy: a necessary competency in leadership development? Progress in Neurology and Psychiatry September/October
  24. Lund CA, Gardiner AQ (1977) The gaslight phenomenon: An institutional variant. The British Journal of Psychiatry 131 P533–4
  25. 25.0 25.1 Lennane J (May 2012) What Happens to Whistleblowers and Why Classics in Social Medicine Vol6 No4 P249-258
  26. 26.0 26.1 Bousfield A (9 December 2011) 21 Ways To Skin An NHS Whistleblower Medical Harm
  27. 27.0 27.1 Patients First (23 Oct 2013) The Life Cycle of the Whistleblower)
  28. Public Concern at Work (2013) Whistleblowing: The Inside Story - A study of the experiences of 100 whistleblowers University of Greenwich research report
  29. 29.0 29.1 Public Accounts Committee Report of Inquiry into Whistleblowing, Ninth Report of Session 2014–15)
  30. Cop hauled off to psych ward after alleging fake crime stats
  31. Banisar, "Whistleblowing: International Standards and Developments", in CORRUPTION AND TRANSPARENCY: DEBATING THE FRONTIERS BETWEEN STATE, MARKET AND SOCIETY, I. Sandoval, ed., World Bank-Institute for Social Research, UNAM, Washington, D.C., 2011 available online at ssrn.com
  32. "Whistleblowers Australia". Whistleblowers.org.au.
  33. Whistleblowers Australia (2012-02-12). "Whistleblowers Australia". Whistleblowers.org.au. Retrieved 2012-07-08.
  34. Government of Canada, PSIC. "Background, Objectives, Scope". Office of the Public Sector Integrity Commissioner. Retrieved 16 June 2014.
  35. Government of Canada, PSIC. "The Servants Disclosure Protection Act". Office of the Public Sector Integrity Commissioner. Retrieved 16 June 2014.
  36. Government of Canada, PSIC. "Case Reports". Office fo the Public Sector Integrity Commissioner. Retrieved 16 June 2014.
  37. http://www.japarliament.gov.jm/attachments/341_The%20Protected%20Disclosures%20Act,%202011.pdf
  38. "Publin Interest Disclosure Bill" (PDF). Retrieved 2013-06-13.
  39. The Public Interest Disclosure and Protection of Persons Making the Disclosures Bill, 2010
  40. "Legislative Brief" (PDF). Retrieved 2013-06-13.
  41. PTI (2011-12-28). "Whistle-blowers Bill passed". Chennai, India: The Hindu. Retrieved 2012-07-08.
  42. "Whistleblower Bill to cover public and private sectors". Irish Times. 30 January 2011.
  43. "Vanaf vandaag: anoniem lekken naar media via doorgeefluik Publeaks". volkskrant.nl. Retrieved 22 February 2014.
  44. "Handling ethical problems in counterterrorism An inventory of methods to support ethical decisionmaking" (PDF). RAND Corporation. Retrieved 24 February 2014.
  45. "Schutz bei Meldung von Unregelmässigkeiten am Arbeitsplatz" (PDF). Retrieved 22 October 2014.
  46. "Botschaft über die Teilrevision des Obligationenrechts" (PDF). Retrieved 23 October 2014.
  47. Lizzie Parry Daily Mail 11 February 2015 Climate of fear leaves NHS whistleblowers 'on the brink of suicide' says report but campaigners warn new measures to protect workers 'don't go far enough'
  48. "DOL.gov". Oalj.dol.gov. Retrieved 2012-07-08.
  49. "Peer.org". Peer.org. Retrieved 2012-07-08.
  50. Congressional Record p. S7412; S. Rep. No. 107–146, 107th Cong., 2d Session 19 (2002).
  51. "Answers.com". Answers.com. Retrieved 2012-07-08.
  52. "Whistleblowers.gov". Whistleblowers.gov. Retrieved 2012-07-08.
  53. "DOL.gov". DOL.gov. Retrieved 2012-07-08.
  54. "Osha.gov". Osha.gov. 2012-04-28. Retrieved 2012-07-08.
  55. "Osha.gov". Osha.gov. Retrieved 2012-07-08.
  56. 31 U.S.C. § 3730 (h)
  57. Guja v. Moldova, Application no. 14277/04 (2008)

Bibliography

External links

Look up whistle-blower in Wiktionary, the free dictionary.
Look up whistleblower in Wiktionary, the free dictionary.
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