Title page 1

Contents 3

GLOSSARY 4

EXECUTIVE SUMMARY 5

INTRODUCTION 8

ISSUES OF NON-CONFORMITY WITH THE DIRECTIVE 12

Conditions for whistleblower protection 12

Right to report directly to authorities 14

Reversal of the burden of proof 16

Penalties 17

ALIGNMENT WITH BEST PRACTICE 21

What can be reported (the material scope) 21

Anonymous reporting 23

Data collection 25

Gender-disaggregated data collection and analysis 26

RECOMMENDATIONS 28

Overall recommendations covering all 10 EU candidate and potential candidate countries 28

Country-level recommendations 32

RESOURCES 37

Resources from Transparency International 37

Other resources 37

NATIONAL EXPERTS 38

Graphs 10

Graph 1. WHISTLEBLOWER PROTECTION LAWS IN EU CANDIDATE AND POTENTIAL CANDIDATE COUNTRIES 10

Graph 2. CONDITIONS FOR WHISTLEBLOWER PROTECTION 13

Graph 3. RIGHT TO REPORT DIRECTLY TO AUTHORITIES WITHOUT ANY RESTRICTIONS 15

Graph 4. REVERSAL OF THE BURDEN OF PROOF 17

Graph 5. PENALTIES FOR VIOLATIONS OF WHISTLEBLOWER PROTECTION 18

Graph 6. SCOPE OF WHAT WHISTLEBLOWERS CAN REPORT 22

Graph 7. ANONYMOUS REPORTING - ACCEPTING AND FOLLOWING UP ON ANONYMOUS WHISTLEBLOWING REPORTS 24