Reporting of corruption-related offences and protection of whistleblowers: comparative analysis of national and international legislations

Whistleblowing represents a fundamental mechanism in the global fight against corruption and the promotion of integrity, accountability, and transparency in both the public and private sectors. It serves as a key instrument for exposing misconduct, maladministration, and unlawful activities that undermine institutional credibility and public trust. However, despite its recognized importance, the effectiveness of whistleblowing remains highly dependent on the existence of a robust legal and institutional framework that ensures adequate protection for whistleblowers. In many jurisdictions, legislative deficiencies and weak enforcement mechanisms continue to expose whistleblowers to retaliation, dismissal, or social ostracism, thereby discouraging potential informants from reporting wrongdoing. This article critically analyzes the concept and practice of whistleblowing within the framework of international anti-corruption instruments, including the United Nations Convention against Corruption (UNCAC) and the European Union Whistleblower Protection Directive (EU Directive 2019/1937). It explores comparative approaches to whistleblower protection, identifies existing gaps in national legislations, and assesses the extent to which effective protection mechanisms can contribute to fostering a culture of ethical governance. By establishing comprehensive legal safeguards, independent reporting channels, and awareness-raising initiatives, states can strengthen institutional accountability and enhance public confidence in governance systems. The study concludes that empowering whistleblowers through legal, procedural, and cultural reforms is indispensable for advancing transparency, good governance, and the rule of law. Keywords: whistleblowing, corruption, accountability, transparency, UNCAC, EU Directive 2019/1937, governance, legal protection, ethical behavior, public trust.