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This volume takes a look at the status quo of whistleblowing in several jurisdictions from around the world. Covering a topic that draws the attention of a broad public and is gaining importance amongst legislators, practitioners and scholars all over the globe, the book examines the various aspects of whistleblowing. It looks at what kind of legal protection of whistleblowers is in force, who is protected, what kind of behaviour is protected, and what kind of behaviour whistleblowers are protected against. This is achieved by a combination of a general comparative report with country-specific reports that give information on whistleblowing in various jurisdictions. These countries include, amongst others, Canada, Germany, France, Italy, the Netherlands and the USA. A synopsis comprises information on whistleblowing in 23 countries in one tabula. The chapters of this book were originally prepared for the XIXth International Congress of Comparative Law (20th and 21 July 2014) of International Academy of Comparative Law in Vienna.
Sommario
Part I: General Report.- Whistleblowing Around The World - A Comparative Analysis of Whistleblowing in 23 Countries; Gregor Thüsing and Gerrit Forst.- Part II: National Reports.- The Legal Response to Whistleblowing in Canada: Managing Disclosures by the "Up the Ladder" Principle; John P. McEvoy.- The Protection of Whistleblowers in the Republic of Croatia; Sandra Laleta and Vanja Smokvina.- Protection and Support for Whistleblowers: the Cypriot Experience; Constantinos Kombos.- Whistleblowing: National Report for the Czech Republic; Jan Pichrt and Jakub Morávek.- Whistleblowing: National Report for France; Katrin Deckert and Morgan Sweeney.- Duty to Loyalty, Fundamental Rights, and Public Policy - German Whistleblowing Law between Conflicting Values; Rüdiger Krause.- Whistleblowing: National Report for Ireland; Michael Doherty and Desmond Ryan.- The Whistleblowing dilemma in Malta continues: a personal view and analysis; David Fabri.- Country Report - The Kingdom of the Netherlands; Björn Rohde-Liebenau.- Whistleblowing in Poland according to legislation and case law; Dagmara Skupien.- Portugal: The Protection of the Whistleblower from the Perspective of a Country without Specific Legislation; Júlio Gomes.- Romania: First Steps to Whistleblowers' Protection; Raluca Dimitriu.- Protection of persons reporting corruption and other whistleblowers in the republic of Slovenia; Darja Sencur Pecek.- Financial Incentives and Truth-Telling: The Growth of Whistle-blowing Legislation in the United States; Shawn Marie Boyne.- Part III: Synopsys of Whistleblowing in 23 Jurisdictions.
Riassunto
This volume takes a look at the status quo of whistleblowing in several jurisdictions from around the world. Covering a topic that draws the attention of a broad public and is gaining importance amongst legislators, practitioners and scholars all over the globe, the book examines the various aspects of whistleblowing. It looks at what kind of legal protection of whistleblowers is in force, who is protected, what kind of behaviour is protected, and what kind of behaviour whistleblowers are protected against. This is achieved by a combination of a general comparative report with country-specific reports that give information on whistleblowing in various jurisdictions. These countries include, amongst others, Canada, Germany, France, Italy, the Netherlands and the USA. A synopsis comprises information on whistleblowing in 23 countries in one tabula. The chapters of this book were originally prepared for the XIXth International Congress of Comparative Law (20th and 21< sup="> July 2014) of International Academy of Comparative Law in Vienna.
