Protecting whistleblowers in Norway and the UK: a case of mix and match?
International Journal of Law and Management
ISSN: 1754-243X
Article publication date: 13 November 2009
Abstract
Purpose
This paper aims to compare and contrast the approaches taken by the UK and Norway in providing employment protection for whistleblowers.
Design/methodology/approach
The paper examines the legislative provisions contained in the Employment Rights Act 1996 (UK) and the Work Environment Act 2005 (Norway) together with relevant case law and preparatory papers.
Findings
Unlike the UK, Norway affords employees a statutory right to notify wrongdoing and requires employers to develop internal reporting procedures. The authors believe that the approaches taken to protecting whistleblowers reflect the different systems of industrial relations in these two countries.
Practical implications
In the light of this research it is suggested that a right to disclose wrongdoing should be introduced in the UK together with a duty on employers to show that it has not been infringed. It is also recommended that what can be reported should be more precisely defined in Norway either by law or collective bargaining.
Originality/value
The paper makes proposals for the reform of legislation in both countries.
Keywords
Citation
Lewis, D. and Trygstad, S. (2009), "Protecting whistleblowers in Norway and the UK: a case of mix and match?", International Journal of Law and Management, Vol. 51 No. 6, pp. 374-388. https://doi.org/10.1108/17542430911005918
Publisher
:Emerald Group Publishing Limited
Copyright © 2009, Emerald Group Publishing Limited