Title page 1

Contents 3

GLOSSARY 4

EXECUTIVE SUMMARY 5

Key Findings 5

Key recommendations 6

Methodology and scope 11

INTRODUCTION 7

WHISTLEBLOWING AUTHORITIES 12

Institutional models for whistleblowing authorities 12

Fragmentation and operational challenges 13

Emerging practices and the role of civil society 14

REMEDIES AND FULL COMPENSATION 17

The make-whole principle in the EU Whistleblowing Directive 17

National approaches to remedies and compensation 18

Access to remedies in practice 18

Quasi-judicial and administrative practice 19

REVERSAL OF THE BURDEN OF PROOF 22

A cornerstone of effective whistleblower protection 22

Incomplete and incorrect transposition in national laws 22

Divergent judicial interpretations across member states 23

PENALTIES FOR VIOLATIONS 25

Wide variation in penalties across the EU 25

INTERNAL WHISTLEBLOWING SYSTEMS 27

Establishment and functioning of internal reporting channels 27

Enforcement of organisations' obligations 28

ADVICE AND SUPPORT 29

Independent advice 29

Legal and financial support 30

DATA COLLECTION AND REPORTING 33

Monitoring implementation of the Directive 33

Emerging practices and data gaps 34

Gender and inclusion 35

CONCLUSIONS AND RECOMMENDATIONS 37

Recommendations 38

EXPERTS 42

National experts 42

International experts 43

RESOURCES 44

Resources from Transparency International 44

Other resources 44