بررسی مقایسه ای حمایت های قانونی از افشاگران فساد در کشورهای منتخب و جمهوری اسلامی ایران

Whistleblowers play an essential role in exposing corruption, fraud, mismanagement and other wrongdoings that threaten public health and safety, financial integrity, human rights, the environment, and the rule of law. By disclosing information about such misdeeds, whistleblowers have helped save countless lives and billions of dollars in public funds, while preventing emerging scandals and disasters from worsening. Whistleblowers often take on high personal risk. They may be fired, sued, blacklisted, arrested, threatened or, in extreme cases, assaulted or killed. Protecting whistleblowers from unfair treatment, including retaliation, discrimination or disadvantage, can embolden people to report wrongdoing and thus increase the likelihood that wrongdoing is uncovered and penalised. All global and regional treaties aimed at combating corruption have recognised the importance of whistleblower protection to address corruption, and have introduced requirements to protect whistleblowers. This includes the United Nations Convention against Corruption (Articles 8, 13 and 33), the Council of Europe Civil and Criminal Law Conventions on Corruption (Articles 9 and 22 respectively), the Inter-American Convention against Corruption (Article III(8)), the African Union Convention on Preventing and Combating Corruption (Article 5(6)) and the Arab Convention to Fight Corruption (Article 10). In this paper, we will look at the legal status of the protection of Whistleblowers in Iran and several selected countries, and suggestions will be made to improve and ratify the Whistleblower Protection Act in