Accession No.20210415
TitleWhistleblower protection: a comparative study of South Africa, United Kingdom and the United States of America.
Authors/Creators Fathimath Azka Mohamed (TP052097)

This research paper explores the legislative efforts taken by South Africa, United States of America and United Kingdom in providing legal protections to the whistle-blowers. This area has been a widely debated topic due to the vast acknowledgement on the importance of whistle-blowers in exposing criminal activities and misconducts occurring in organizations to ensure better corporate governance of the organizations. The whistleblowing legislations were compared against the attributes of the international best practice on whistleblowing to find out it is in accordance to the standards. This paper is focused on four broad areas which are important for an effective whistleblowing legislation which are (1) scope of legislation (2) disclosure mechanism (3) protection mechanisms and (4) remedies and relief. In this research it was found that despite United States of America and United Kingdom being known for having comprehensive whistleblowing legislations they both have loopholes and in comparison, South Africa was not doing bad either.

SupervisorGeetha A. Rubasundram
InstitutionAsia Pacific University of Technology and Innovation (APU)
SchoolGraduate School of Business
No. of pages74
Date typeSubmission
RefereedYes, this version has been refereed
Additional Information

A thesis submitted in fulfillment of the requirement of Asia Pacific University of Technology and Innovation for the award of the degree of Master of Accounting In Forensic Analysis (UCMF1808AFA).

  • Social Sciences

Whistle blowing ; Law ; Legislation ; Employee ; Employer ; Corporate governance ; Whistle blower protection mechanism ; Legislative reforms.

View Login to view full text