Comparative analysis of whistleblower protection legislations in England, USA and Malaysia

Abstract

This article explores the legislative efforts undertaken by the United States, England and Malaysia in providing legal protection to whistleblowers. This area has become a regularly debated topic due to the vast acknowledgement on the importance of whistle-blowing in countering fraud and other misbehavior of corporations to ensure better corporate governance of corporations. A comparative analysis would be undertaken on the law on whistleblower protection in the earlier mentioned countries to determine their similarities, differences, strengths and weaknesses. The results of this analysis would be a useful source of information to countries who want to legislate on whistleblower protection or to improve the law in this area. Key words: Whistle-blowing, legal protection, whistleblower, corporate governance.