Упоредно-правни аспекти појма узбуњивач
Comparative Legal Aspects Of The Concept Whistleblower

Summary/Abstract: The Republic of Serbia has adopted the Law on the protection of whistleblowers in order to provide comprehensive and effective protection of whistleblowers. Diversity of different national legal provisions regarding protection of whistleblowers ilustrates conceptual confusion and theoretical discrepancy. The aim of this study is to identify universal whistleblowers` characteristics based on the analysis of standards in the European legislation, multilateral instruments and domestic law. Whether and to what extent whistleblowers differ from other persons who report irregularities and does that «specific» characteristics justifies the additional protection? The complexity of the problem is further demonstrated by the fact that the term whistleblowing is differently regulated in various legal systems. In the first part of the paper, the author deals with comparative legal practices of the EU Member States, researching the «European recipe» for the protection of the whistleblowers in Serbia. Second part comprises an overview of international legal instruments governing the protection of whistleblowers. In the third part of the paper, author undertakes analysis of whistleblowers` characteristics that could universaly define this concept regardless of the legal system.

• Details
• Contents