African Journal of
Business Management

  • Abbreviation: Afr. J. Bus. Manage.
  • Language: English
  • ISSN: 1993-8233
  • DOI: 10.5897/AJBM
  • Start Year: 2007
  • Published Articles: 3988

Full Length Research Paper

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

  Tan Pei Meng* and Ong Seng Fook    
  Faculty of Accountancy and Management, University Tunku Abdul Rahman (UTAR), Lot PT 21144, Jln Sungai Long, Bandar Sg Long, Cheras, 43000 Kajang, Selangor, Malaysia.
Email: [email protected], [email protected]

  •  Accepted: 20 June 2011
  •  Published: 09 November 2011



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.

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