These are the monthly roundups of updates provided by the EU Whistleblowing Monitor team of country editors detailing national developments in the transposition of the EU Directive on Whistleblowing.

This is the monthly roundup of updates provided by the EU Whistleblowing Monitor team of country editors detailing national developments in the transposition of the EU Directive on Whistleblowing during June 2021.

On the 21 June 2021 Denmark adopted a new dedicated whistleblowing law to implement the Directive and is now the first and only country listed as ‘transposed’ on the Monitor.

Further assessment of the national framework is required to ascertain whether a country has properly interpreted and implemented the minimum standards required by the Directive. Member states are also required to send a report analysing their compatibility to officially complete transposition.

Transposition remains underway in at least 21 countries and 5 Member States still listed as ‘not started’ - Austria, Cyprus, Hungary, Luxembourg, and Malta.

Country Updates:

15/07/21 – A draft proposal to transpose the Directive is expected in Slovenia following the appointment of a new minister of justice.

24/06/21Denmark has adopted new whistleblowing legislation. The Whistleblower Protection Act seeks to implement the Directive passed on 24 June 2021 is due to enter into force on the 17 December 2021.

22/06/21 – Draft whistleblowing protection proposals are under discussion and vote in Portugal.

14/06/21 –  In the Czechia a public awareness campaign on whistleblowing has been launched as final parliamentary discussions on the draft law continue. 

08/06/21 – A civil society coalition in France has formed to call for support on a petition for timely transposition of the Directive.

03/06/21 – In The Netherlands the draft Bill on whistleblower protection has now been submitted to Parliament.

Resources:

The second ‘WhistlePro’ international online conference on Whistleblower Protection at Work in the Visegrad Group countries, France and Slovenia held by the University of Lodz took place on the 15 June 2020.  Presentations were given by academics, public officials and civil society experts providing a comparative analysis of current national frameworks in France, Slovenia, Hungary, Czech Republic, Poland and Slovakia and the provisions of the Directive – see the programme here. A recording of the conference can be rewatched here.

This is the monthly roundup of updates provided by the EU Whistleblowing Monitor team of country editors detailing national developments in the transposition of the EU Directive on Whistleblowing during May 2021.

Transposition remains underway in at least 22 countries and 5 Member States still listed as ‘not started’ - Austria, Cyprus, Hungary, Luxembourg, and Malta.

Country Updates:

28/05/2021 – In Croatia, an invitation to join a working group on whistleblowing has been published to allow for the nomination of representatives of civil society organisations to contribute to the reform.

25/05/2021 – Civil society in Greece has recommended labour reforms which strengthen whistleblowing protection.

24/05/2021 – A draft proposal for whistleblowing law to transpose the Directive is soon expected in Luxembourg.

20/05/2021 – A draft whistleblowing Bill has been introduced to parliament in Sweden.

13/05/2021 – In Ireland, a proposal of amendments to the current whistleblowing law to transpose the Directive has now been published.

12/05/2021 – In Czechia, the draft Bill on whistleblowing has passed a crucial vote and is now scheduled for parliamentary discussion.

05/05/2021 – In Hungary, civil society is alarmed at the lack of progress on the transposition of Directive on Whistleblowing.

Resources:

Watch TI Ireland’s and other experts online webinar discussing the proposed ‘General Scheme of the Protected Disclosures (Amendment) Bill’ to transpose the EU Directive on Whistleblowing into Irish law. Held on 27 May 2021, key experts discuss key provisions and potential loopholes with the potential reform.

An online tool on whistleblowing for trade unions has been developed by Eurocadres includes a transposition toolkit, several interviews with key experts. The free online course is available in six languages.

For more Resources on transposition of the EU Directive on whistleblowing see here.

This is the monthly roundup of updates provided by the EU Whistleblowing Monitor team of country editors detailing national developments in the transposition of the EU Directive on Whistleblowing during April 2021.

Transposition remains underway in at least 22 countries with 5 Member States still listed as ‘not started’ – Austria, Cyprus, Hungary, Luxembourg, and Malta.

Country Updates:

29/04/2021 – In Germany, a civil society coalition of NGOs have criticised the failure of the new draft whistleblowing law presented in December, which means the opportunity to enshrine more comprehensive provisions prior to the end current elective and legislative period has been missed.

29/04/2021 – The Government in Portugal has begun transposition of the Directive by approving a new national strategy against corruption which introduces a whistleblower protection framework.

14/04/2021 - Despite having made substantive progress, the Government in Czechia has failed to support the whistleblowing draft law, which means it is now unclear whether it can be passed prior to the Autumn elections.

14/04/2021 – Officials in Ireland also now fear transposition of the Directive will be unlikely before the deadline.

02/04/2021 - In Italy after transposition of the Directive was periodically suspended, the Government can finally begin the process after approving a law giving the mandate to legislate.

Resources

Read the WIN’s third briefing paper as part of it’s series on transposition: “Implementing the EU Directive on Whistleblowing: Burden of proof for whistleblower claims must be fully reversed”  - downloadable here.

Watch UK whistleblowing charity Protect and other experts online webinar ‘Let’s Fix Whistleblowing Law.’ Held on 29 April 2021, key experts and whistleblowers discuss the Public Interest Disclosure Act - Europe’s first whistleblowing law and the urgent need for reform.

Watch Human Rights House online conference session on the transposition of the EU Directive into Croatian national law held on 20 April 2021 here.

WIN have published this Spotlight on WIN Member Oživení discussing the role of empirical research into cultural attitudes to whistleblowing and implications for the transposition of the EU Directive in the Czech Republic.

This is the monthly roundup of updates provided by the EU Whistleblowing Monitor team of country editors detailing national developments in the transposition of the EU Directive on Whistleblowing during March 2021.

Transposition remains underway in at least 21 countries and 6 Member States still listed as ‘not started.’ 

Country Updates:

05/03/2021 – In Romania, a draft Bill has been published and stakeholder consultation took place between 05 and 26 March. Civil Society is alarmed that the proposal restricts protections available under the current framework.*

(*Note: As of 01 April 2021, following demands from civil society, a public consultation (online debate) has been scheduled.)

17/03/2021 – A draft Law was also published in Lithuania. Opinions were welcomed from stakeholders until 17 March with civil society urging the government to reconsider it’s approach and establish a working group to allow debate on more detailed provisions 

31/03/2021 – In the Czech Republic, Civil Society is concerned Draft Bill to transpose the Directive has not been heard as scheduled in parliament. If the proposal is not prioritized by Government in the Fall then it may likely not be adopted prior to the deadline.

Resources:

WIN and Transparency International published a joint Report on Progress on transposition launched with an online webinar and two accompanying blogs which highlight key findings: Are EU Countries taking whistleblower protection seriously? and Can transposing the Whistleblower Protection Directive be done on time? Maybe, but not at the cost of transparency and inclusiveness.

WIN has also published its second briefing paper as part of a WIN series on transposition: “Implementing the EU Directive on Whistleblowing: All internal reporting must be clearly protected in law” 

The Network of European Integrity and Whistleblowing Authorities (NEIWA) have published their Brussels Declaration which makes several recommendations for governments implementing the Directive including extending the material scope.

The International Bar Association and The Government Accountability Project have now published their joint report: Are whistleblowing laws working? A global Study on Whistleblowers Protection Legislation  which looks at the successes and shortcoming of whistleblowing protection in 38 countries (including France, Hungary, Ireland, Italy, Malta, Romania, Slovakia and Sweden.)

Blueprint for Free Speech have published an analysis on the Draft Law in Germany.

Dimitrios Kafteranis, the country editor for Luxembourg, has published this blog for the University of Chicago on the EU Directive and obstacles for implementation.

Finally, this open access academic paper from the Journal of Business Ethics discusses the theory of whistleblowing and the Directive from a human rights perspective.

This is the monthly roundup of updates provided by the EU Whistleblowing Monitor team of country editors detailing national developments in the transposition of the EU Directive on Whistleblowing during February 2021.

Transposition is now underway in at least 21 countries and 6 Member States remain listed as ‘not started.’ 

WIN is delighted to publish a briefing paper as part of a WIN series on transposition: “Implementing the EU Directive: Whistleblowing protection laws must cover breaches of national law”. We hope this to be the first of several “one pager” publications to address key areas of concern as they arise to support the advocacy of our European partners.

Country Updates:

01/02/2021 – In Czechia, the Government has approved a draft law which it declares ‘reflects’ the EU Directive. Civil society in the Czech Republic have raised concerns about the proposed framework - see recommendations for improvement and Spotlight on WIN Member Oživení.

24/02/2021Public consultation on a draft law to implement the Directive has begun in Denmark. A list of stakeholder organisations have been invited to provide opinions on the proposal until 24 March 2021.

25/02/2021 – After many years of campaigning from civil society, whistleblower protection is embedded in Bulgaria’s future Anticorruption Strategy. Public consultation has now begun on the draft provisions which introduce personal liability for whistleblower retaliation.

05/02/2021 – In Slovakia, a much-anticipated Director has been appointed by Parliament to head up the national whistleblowing protection office. 

04/02/2021 – Civil society in Germany has raised alarmed at employer associations proposals for minimally implementing the Directive which seem to push again for mandatory internal reporting.

01/02/2021 – In Lithuania, the status of transposition and a draft bill underway has been confirmed during a meeting of the prosecutor general with civil society.

Resources:

WIN, in collaboration with Whistleblower-Netzwerk e.v., have published this Spotlight: “Experts say Germany must change approach to protect whistleblowers” which is a shortened translation setting out legal arguments that verbatim transposition of the Directive which only protects reports of breaches of EU Law is not justifiable under principles of equality under German constitutional law.

Whistleblowing Impact have published this report on the experience of whistleblowers which quantifies the personal cost of whistleblowing. These studies can provide persuasive empirical evidence of the need for laws and policies which comprehensively protect and fully compensate whistleblowers.

Finally, on the 23 February, WIN held an Event and Call to Action with EU Whistleblowing Meter partners TI Europe and Eurocadres which proved to be a lively discussion with over 180 people registering to attend. We hope to hold another event soon to continue to build momentum about the value of civil society working in coalition to hold governments to account and demand strong and effective national provisions.

This is the monthly roundup of updates provided by the EU Whistleblowing Monitor team of country editors detailing national developments in the transposition of the EU Directive on Whistleblowing during January 2021.

Transposition is now underway in at least 20 countries and 7 Member States remain listed as ‘not started.’ 

Country Updates:

25/01/2021 – In Czechia, the Government suspended discussions on a draft whistleblowing protection law due to ongoing ambiguities of the intended role of the Labor Inspectorate.

Note: On the 01 February 2020 it was announced that the Government had approved the draft law which has been declared to reflect the EU Directive. Civil society in Czechia have raised concerns about the proposed framework -  see recommendations for improvement and Spotlight on WIN Member Oživení.

27/01/2021 – In Spain, public consultation on a draft proposal to implement the Directive was launched by the Ministry of Justice, which closed on 27 January. Civil Society have responded to the call for submissions. You can read WIN Associate Xnet’s submission here.

20/01/2021 – Public consultation has also been announced in France. The Ministry of Justice has invited unions, associations and NGOs to submit opinions before the 21 March 2021. A position paper on implementation of the Directive has been presented to parliament by the Defender of Rights ombuds institution. Civil society have called for progressive implementation in this op-ed penned by Maison des Lanceurs D’Alerte.

25/01/2021 – In Italy, initial preparatory work has now begun in Parliament. Once discussed and approved, a draft Bill will officially appoint the Ministry of Justice and the Department for European Policies to commence transposition.

09/01/2021 – In Belgium, a second draft proposal relevant to whistleblowing protection has been introduced to parliament. The Government had previously published a tender to outsource a preparatory investigation into transposition, the results of which are still pending.

21/01/2021 – In Malta, the Justice Minister has been reported as confirming that the current whistleblowing law of 2013 will need to be reformed to transpose the Directive and that the Office of the Directorate for Strategy Support will become the coordinating office for implementation.

21/01/2021 – In the Netherlands, civil society have raised concerns about the Dutch Governments approach. This TI blog - Netherlands showing other EU Countries what not to do when transposing EU Whistleblower Directive - analyses the draft law proposed by the Government, which takes a minimal approach and does not expand the scope of protections to breaches of national law, despite repeated encouragement of the Commission to so. The Ministry of Internal Affairs has declared that amendments to improve the draft law are now ‘unfortunately impossible’ within the timeframe.

09/01/2021 – In Belgium, a second draft proposal relevant to whistleblowing protection has been introduced to parliament. The Government had previously published a tender to outsource a preparatory investigation into transposition, the results of which are still pending.

30/12/2020 – It has been reported that the government in Denmark has communicated an intention to expand the scope of the Directive, at least to reports of sexual harassment in the workplace. 

Resources:

Blueprint for Free Speech have published new research on public perceptions of whistleblowers and their response to public consultation in Spain which can be found here.

This is the monthly roundup of updates provided by the EU Whistleblowing Monitor team of country editors detailing national developments in the transposition of the EU Directive on Whistleblowing during December 2020.

Transposition is underway in at least 18 countries, with Croatia moving to ‘in progress’ this month.  9 Member States remain listed as ‘not started.’ 

Country Updates:

In Croatia, the Government have now adopted a plan for legislative activities and harmonization for 2021 which includes proposed amendments to whistleblowing legislation to be adopted later this year.

In Germany, a national newspaper has reported that a first whistleblowing law has been drafted by the Ministry of Justice which proposes to expand on the scope of the Directive to protect persons who report breaches of national law. A position paper on transposition has been published by the SPD party. Protect Whistleblowers Better makes several policy recommendations which are in line with best practice principles for whistleblowing legislation, including protecting disclosure of wrongdoing not considered a breach of a legal obligation.

In Poland, the Prime Minister has transferred responsibility for transposition of the Directive to the Ministry of Development, Labour and Technology. Public consultation on a dedicated whistleblowing draft bill is now expected.

This is the monthly roundup of updates provided by the EU Whistleblowing Monitor team of country editors detailing national developments in the transposition of the EU Directive on Whistleblowing during November 2020.

Transposition of the EU Whistleblowing Directive is underway in at least 15 Member States with 12 countries remaining listed as ‘not started.’ 

Country Updates:

In Germany, the Minister of Justice Christine Lambrecht has announced support for an extensive draft law which expands the scope of the Directive to cover breaches of national law. The announcement follows infighting between ministries on the issue, with the Minister for Economic affairs being criticised by NGOs for proposing a 1:1 transposition.  Legal scholars in Germany have published an analysis of such verbatim implementation, which they argue would create a hybrid system which could be found to breach the constitutional principle of equal treatment.  

In Czechia, the Legislative Council of the Government have suspended discussions of the Draft Law for amendments to be made to the text of the proposal, which, if finalised by the end of the year, may now be passed in the current election cycle. The NGO Oživení has published further reflections on the proposed regime which is deemed to be undermined by proposing a single competent authority which would be given no extra funding for its new remit, read more here.

All responses to public consultation on the draft proposal to transpose the Directive in The Netherlands and Sweden have now been published:

Eight interventions on the Dutch proposal were received and are available online – including the responses of Transparency International Netherlands and the Labour foundation which outline serious concerns of the proposed minimal approach.

Over 100 responses were received during the Swedish Ministry of Labour’s public consultation on the draft law. Concerns have been raised about the complexity of the proposed regime which would add additional rights to preexisting whistleblowing rules and constitutional freedom of expression rights.

A Civil network for Whistleblowing has been launched in Romania to promote public interest whistleblowing. CivicAIP held an online webinar on the current progress for transposition of the Directive into national law.

Transparency International Greece, Vouliwatch and Reporters United have formed a civil society coalition to advocate for strong whistleblowing protections. More than 20 NGOs have signed a joint letter sent to the Prime Minister and other officials advocating for stronger protections of whistleblowers.

Resources and Events:

A new toolkit on whistleblowing for trade unions has been published by Eurocadres in several languages. The best practice guide, developed in collaboration with NGO Protect, also outlines the role of trade unions in the transposition of the Directive. A webinar entitled ‘Workers with Whistles,’ discussing the complex but vital role trade unions play in supporting whistleblowers, took place on 3 December, see here.

Transparency International Irelands initiative Integrity at Work programme is holding an online workshop for prescribed competent authorities to discuss preparations for transposition of the Directive on the 7 December, see here.

The is our fourth monthly roundup of updates provided by the EU Whistleblowing Monitor team of country editors detailing national developments in the transposition of the EU Directive on Whistleblowing during October 2020.

Transposition of the EU Whistleblowing Directive is underway in at least 15 Member States, with Romania moving from ‘in progress’ this month. 12 Member States remaining listed as ‘not started.’  

Country Updates:

In Germany, a joint position paper of Reporters Without Borders and Whistleblowerz-Netzwerk e.v. has been published.  The report makes key recommendations for transposition of the Directive to prioritise freedom of expression and freedom of the press and warns against blanket exceptions for classified information.  It also calls for digital source protection and an extension of the material scope beyond breaches of Union law, which is currently a point of contention for German officials, read more here.

An open letter warning of the risks of a verbatim transposition of the Directive was published by a coalition of civil society organisations in August. The German Trade Union Confederation has also published a report making 53 detailed recommendations for the implementation of the Directive to create a comprehensive and coherent legal framework.

In Czechia, the Ministry of Justice has submitted the Draft Law on the Protection of Whistleblowers to the Government on Sept. 30, 2020. The Governmental Legislative Council and its individual working commissions have 60 days to review it. The meeting of the Governmental Working Committee for Whistleblowing as well as the meeting of the Government Council for the Coordination of the Fight against Corruption are planned to discuss the Draft and the comments of the Governmental Legislative Council later on in November.

Transparency International Portugal has responded to public consultation on the countries national strategy to combat Corruption, which includes a new mechanism to protect whistleblowers. They point out the proposals do not go far enough to meet the requirements of the Directive.

Following the establishment of a working group on transposition in Romania, Transparency International Romania has launched a Business Integrity Country Agenda research report which makes recommendations for whistleblowing protection, see here.

In Slovenia, after several delays, the National Assembly has, passed amendments to the Integrity and Prevention of Corruption Act. Transparency International Slovenia have expressed that the changes do not go far enough to meet the requirements of the Directive and have publicly called for a progressive transposition, see here.

In Austria, a campaign has been launched to address transposition of the Directive and pushing for the extension of provisions to cover national law, see here.

The Ministry of Justice of Estonia has sent its intention to draft a Bill on whistleblower protection to other ministries and relevant stakeholders. The proposals are for a new horizontal law which would widen the scope of the Directive. Transparency International Estonia has published a position paper on the proposal and official positions of other stakeholders can be found here.

In Croatia, the Ombudsman has joined the Network of European Integrity and Whistleblowing Authorities (NEIWA) which encourage cooperation of state institutions and the consistent application of the Directive.

Resources and Events:

The Network of European Integrity and Whistleblowing Authorities (NEIWA), which met in June 2020, has published it’s Rome Declaration which makes ten recommendations for governments to implement the Directive, including to consider various types of interim measures within the workplace to avoid negative consequences for whistleblowers.

An interesting article published on 30 September 2020 by Dimitrios Kafteranis, Country Editor for Greece ‘Enforcing EU Law: the case of the Whistle- blower’ which discussed the importance of the Directive, can be read here.

Two helpful resources concerning the implementation of GDPR Rules in whistleblowing legislation: The French data protection authorities opinion and Guidelines on processing personal information within a whistleblowing procedure, a 2019 report of the European Data Protection Supervisor (prior to the adoption of the Directive) which sets out some helpful points regarding confidentiality regimes.

International law firm Kohn, Kohn & Calapinto has published a memorandum of best practices on how to implement the Directive has been sent to Belgium, Bulgaria, Croatia, Denmark, Finland, Ireland, Latvia and Slovenia.

The second virtual symposium on ‘The EU Whistleblowers Directive: Transposition Imperative for Ireland’ will take place on 11 November: see here

This is our third detailed monthly roundup of updates provided by the EU Whistleblowing Monitor team of country editors detailing national developments in the transposition of the EU Directive on Whistleblowing during September 2020.

Transposition of the Directive remains ‘in progress’ in 14 countries with 13 Member States remaining listed as ‘not started.’

Country Updates:

Following criticisms from civil society experts of the Draft law published in Czechia last month, the Ministry of Justice is now preparing for a more detailed impact assessment.  You can read more about the concerns of the transposition working group members that the Bill would not sufficiently protect whistleblowers, and that the proposed agency and external reporting system lacked independence from the government here.  Due to legislative timetables in Czechia, it is unlikely the Bill will pass during the current election period and, despite being comparatively further ahead in the transposition process, Czechia now risks falling behind.

An international online conference on Whistleblower Protection at Work in the Visegrad Group countries, France and Slovenia (‘WhistlePro’) held by the University of Lodz took place on the 25 September 2020.  Presentations were given by academics, public officials and civil society experts providing a comparative analysis of current national frameworks in France, Slovenia, Hungary, Czech Republic, Poland and Slovakia and the provisions of the Directive – see the programme here.

This was the first planned conference aimed at improving whistleblower protections in the region and a second event is scheduled to take place in Prague in June 2021.  You can watch a recording of the conference here.

Transparency International Greece have published a detailed Report ‘Effective Integration of the EU Directive on the Protection of Whistleblowers, Analysis and Proposals of DD-E” to the Ministry of Justice and the newly established Legislative Drafting Committee.

Another Policy Paper has been published for Member States by key whistleblowing academics. “Transposing the EU whistleblower directive into National Law: What every policymaker should know” offers recommendations concerning key aspects of implementation.  The paper is written in the context of Ireland’s government call for submissions but has relevance for advocates in other Member States.

In Cyprus, MP Irene Charalambidou has called for stronger whistleblowing protection in a recent speech which highlighted the lack of national whistleblowing protection mechanisms compared to other European countries, stating that protecting whistleblowers was the only way to fight corruption in the country.

Resources:

Transparency International Secretariat have now published their comprehensive tool “Assessing Whistleblowing Legislation: Methodology and Guidelines for Assessment against the EU Directive and Best Practice.”  The tool Is designed to support policymakers and advocates to assess national legislation, draft laws and any amendments during the legislative process, to ensure optimal transposition of the Directive and to push for strong whistleblowing protection based on internationally recognized best practice.

This is our second detailed monthly roundup of updates provided by the EU Whistleblowing Monitor team of country editors detailing national developments in the transposition of the EU Directive on Whistleblowing during August 2020.

Transposition of the Directive is now updated to ‘in progress’ in Bulgaria, Czechia and Denmark pushing the total number to 14 – with 13 Member States remaining listed as ‘not started.’

Country Updates:

In Denmark, we see that Covid-19 Pandemic has slowed transposition process but that the Ministry of Justice have confirmed they plan to meet with stakeholders in Autumn 2020 and expect to have an implementation proposal ready in Spring 2021.

Ongoing discussions continue in Bulgaria as to whether transposition requires the enactment of a standalone whistleblowing protection law or can be achieved through amendments to the current existing legal framework – a preliminary impact assessment is currently being drafted by a working group, which now includes input from civil society NGOs – including TI Bulgaria.

Anticorruption NGOs in Czechia - Rekonstrukce státu (Frank Bold and Oživení) and Transparency International ČR - have published a paper analyzing the proposed new draft law from the Ministry of Justice which has also been criticized by opposition parties for providing only insufficient protection of whistleblowers.

This is our first detailed monthly round-up of updates provided by the EU Whistleblowing Monitor team of country editors detailing national developments in the transposition of the EU Directive on Whistleblowing during July 2020.

Transposition of the Directive is now updated to ‘in progress’ in Estonia and Slovenia pushing the total number to 11 – with 16 Member States remaining listed as ‘not started.’

Country Updates:

In Estonia, the Minister of Justice has made a public statement confirming preparations to develop a whistleblowing protection Bill to transpose the Directive.

In Ireland, Transparency International Ireland has shared their views with the Department of Public Expenditure and Reform on Submission on the transposition of EU Whistleblowing Directive. TI Irelands’ submission responds to ten questions posed by the Department of Public Expenditure and Reform on considerations for transposing the EU Whistleblowing Directive, and includes a number of additional recommendations to address existing shortcomings in the Protected Disclosures Act 2014 advocated for in previous submissions.

In Slovenia, the Minister of Justice and State Secretary met with representatives of Transparency International.  In a public report of the meeting, which took place on the 3rd of July, the ministry reiterated that transposition of the Directive was a priority and that a draft law is being intensively prepared by key members of the government and institutions. Whilst a draft law is therefore expected soon, there have been concerns that recent delays in passing amendments to address key loopholes in the national anti-corruption framework are evidence of a lack of political will for both these much-needed reforms and effective implementation of whistleblowing protection.

In Spain, a coalition of more than 15 civil society organisations have published an open letter requesting a more participatory legislative process for transposition following the establishment of a working group which did not include input from civil society experts or of whistleblowers.  Various draft proposals to transpose the Directive have already been presented in Spain with Congress recently blocking a draft initiative from a political party declaring the proposal ‘insufficient’ to protect whistleblowers, a move considered positive by experts who considered the proposal to be weak.