Guardians of integrity: comparative analysis of whistleblower protection frameworks in Lesotho, the United Kingdom, and South Africa
摘要
This study examines the intricate landscape of whistleblower protection, exploring the historical background, legal definitions, and evolving frameworks aimed at safeguarding whistleblowers who expose wrongdoing. This study meticulously examines Lesotho’s legislative provisions, focusing on the Prevention of Corruption and Economic Offenses Act, the Lesotho Revenue Authority Whistleblowing Policy, and the Lesotho Highlands Water Project Anti-Corruption Policy. In parallel, this paper conducts a comparative analysis of whistleblower protection in the United Kingdom and South Africa, examining statutory laws, definitions of protected disclosure, and case law in both jurisdictions. In addition, this paper explores the broader context of personal integrity, institutional integrity, and the whistleblowing culture as essential components in mitigating corruption. The conceptual framework and interactions within it are scrutinised to comprehend how personal and institutional integrity, along with a robust whistleblowing culture, collectively contribute to reducing corruption. The concluding section consolidates the findings, emphasising the significance of whistleblower protection in fostering transparency, accountability, and ethical conduct.