The paper proposes to compare the relative success of the Public Interest Disclosure Act 1998 (UK) and the Protected Disclosures Act 2000 (South Africa) in providing protection for whistleblowers in the UK and South Africa.
The assessment is conducted in the light of case law in both countries and empirical research previously conducted.
The most important feature of the relevant statutes in both countries is that they recognise the need to protect workers who disclose in the public interest. Although the current provisions are important first steps, it is believed that much more needs to be done.
In the light of this research, 14 suggestions are made for change.
The article makes proposals for reform to the legislation in both countries. It also attempts to provide guidance to practitioners by identifying good practice in handling concerns about wrongdoing.
