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Collection Highlights

Whistleblowing in the World: Government Policy, Mass Media

and the Law 1st Edition Carmen R. Apaza

Public and Social Services in Europe: From Public and

Municipal to Private Sector Provision 1st Edition Hellmut
Wollmann

Applying Behavioural Science to the Private Sector

Decoding What People Say and What They Do Helena
Rubinstein

Operational Policy Making for Professional Security

Practical Policy Skills for the Public and Private Sector
1st Edition Sondej
Cultural Influences on Public-Private Partnerships in
Global Governance Adam B. Masters

CSR and Sustainability in the Public Sector David Crowther

Quality of Internal Auditing in the Public Sector:

Perspectives from the Bulgarian and International Context
Plamena Nedyalkova

What makes time special? 1st Edition Craig Callender

Public Administration Understanding Management Politics

and Law in the Public Sector David H. Rosenbloom
What Makes Effective
Whistleblowing
Global Comparative
Studies from the Public
and Private Sector
Edited by
Carmen R. Apaza
Yongjin Chang
What Makes Effective Whistleblowing
 Carmen R. Apaza • Yongjin Chang
Editors

What Makes Effective

Whistleblowing
Global Comparative Studies from the Public
and Private Sector
Editors
Carmen R. Apaza Yongjin Chang
Universidad Privada Norbert Wiener Faculty of Global Management
Lima, Peru Chuo University
Tokyo, Japan

ISBN 978-3-030-40199-3    ISBN 978-3-030-40200-6 (eBook)

https://doi.org/10.1007/978-3-030-40200-6

© The Editor(s) (if applicable) and The Author(s), under exclusive licence to Springer
Nature Switzerland AG 2020
This work is subject to copyright. All rights are solely and exclusively licensed by the
Publisher, whether the whole or part of the material is concerned, specifically the rights of
translation, reprinting, reuse of illustrations, recitation, broadcasting, reproduction on
microfilms or in any other physical way, and transmission or information storage and retrieval,
electronic adaptation, computer software, or by similar or dissimilar methodology now
known or hereafter developed.
The use of general descriptive names, registered names, trademarks, service marks, etc. in this
publication does not imply, even in the absence of a specific statement, that such names are
exempt from the relevant protective laws and regulations and therefore free for general use.
The publisher, the authors and the editors are safe to assume that the advice and information
in this book are believed to be true and accurate at the date of publication. Neither the
publisher nor the authors or the editors give a warranty, expressed or implied, with respect to
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publisher remains neutral with regard to jurisdictional claims in published maps and
institutional affiliations.

Cover illustration: Pattern © Melisa Hasan

This Palgrave Macmillan imprint is published by the registered company Springer Nature
Switzerland AG.
The registered company address is: Gewerbestrasse 11, 6330 Cham, Switzerland
 Contents

1 Effective Whistleblowing Conceptual Framework  1

Carmen R. Apaza and Yongjin Chang

2 Whistleblowing in Belgium 11
Frankie Schram

3 Whistleblowing in Brazil 31
Carmen R. Apaza

4 Whistleblowing in Finland 49
Olli-Pekka Viinamäki, Niina Mäntylä, and Annukka Jokipii

5 Whistleblowing in Japan: The Case of Masaharu Hamada 71

Yongjin Chang

6 Whistleblowing in the Philippines 87

Gerald Glenn F. Panganiban

v
vi Contents

7 Summary and Conclusions101

Carmen R. Apaza, Yongjin Chang, Frankie Schram, Gerald
Glenn F. Panganiban, Olli-Pekka Viinamäki, Niina Mäntylä,
and Annukka Jokipii

Index113
 List of Tables

Table 2.1 Organisation of the channels in the Flemish whistleblowing

system17
Table 2.2 Summary table of the case 26
Table 2.3 Effectiveness indicators of the case 26
Table 3.1 Summary table of the case 45
Table 3.2 Effectiveness indicators of the case 45
Table 4.1 Summary table of the case 67
Table 4.2 Effectiveness indicators of the case 67
Table 5.1 Summary table of the case 82
Table 5.2 Effectiveness indicators of the case 83
Table 6.1 Summary table of the case 97
Table 6.2 Effectiveness indicators of the case 97
Table 7.1 Effectiveness indicators in the study of whistleblowing cases 110
Table 7.2 Assessment of effectiveness in the study whistleblowing cases 112

vii
 Introduction

In recent years whistleblowing has been crucial to uncovering corruption

scandals all over the world. For instance in the previous edition of this
book, four cases from Peru, South Korea, Thailand, and the United States
were analyzed. Each case was analyzed applying Apaza and Chang’s
(2011) effective whistleblowing conceptual framework, which identifies
five elements of effectiveness in whistleblowing that are relevant in all
democracies: type of whistleblowing, coverage by mass media,
documentation of evidence, retaliation, and legal protection. In all
instances, authorities successfully prosecuted or punished prominent
public figures in spite of high-level corruption and official cover-ups. Each
case had strong political, legal, and social repercussions that at least
promised permanent reforms.
In this edition, five more cases from Belgium, Brazil, Finland, Japan,
and the Philippines are analyzed applying the aforementioned
whistleblowing conceptual framework. Hence, in the first chapter we
revise the five factors of effectiveness in whistleblowing and explain the
methodology to conduct the research. Then, the cases of Belgium, Brazil,
Finland, Japan, and the Philippines are described and analyzed in the
second, third, fourth, fifth, and sixth chapters, respectively. Chapter 7
assesses the effectiveness of the whistleblowing process in each case and
analyzes the comparative findings including additional appropriate

ix
x Introduction

benchmarks for reform. Based on the results, it suggests improvements in

whistleblower protection systems for each country that may be applied in
other countries as well.

Reference
Apaza, C., & Chang, Y. (2011). What makes whistleblowing effective:
Whistleblowing in Peru and South Korea. Public Integrity, 13(2), 113–130.
 CHAPTER 1

Effective Whistleblowing Conceptual

Framework

Carmen R. Apaza and Yongjin Chang

Abstract Apaza and Chang develop an analysis framework for effective

whistleblowing that contains five crucial factors: (1) the type of whistle-
blowing (Internal and External Whistleblowing), (2) the role of the mass
media (use of mass media to disclose corruption), (3) the documentation
of evidence (collection of supporting documentation before blowing the
whistle), (4) the form of retaliation (inappropriate work assignments or
transfer, threats of physical harm, harassment, humiliation, or isolation,
etc.), and (5) legal protections (whistleblowing protection laws issued and
implemented).

Keywords Framework • Effective • Whistleblowing • Legal

protections • Mass media • Retaliation • Documentation of evidence

C. R. Apaza (*)
Universidad Privada Norbert Wiener, Lima, Peru
Y. Chang
Faculty of Global Management, Chuo University, Tokyo, Japan
e-mail: [email protected]

© The Author(s) 2020 1

C. R. Apaza, Y. Chang (eds.), What Makes Effective Whistleblowing,
https://doi.org/10.1007/978-3-030-40200-6_1
2 C. R. APAZA AND Y. CHANG

Whistleblowing is a crucial mechanism in the fight against corruption. It

is specially critical for public corruption because whistleblowing disarms
corruption (Perez 2018) through the revelation of secret wrongdoings
and operations that affect a whole nation (Guerrero 2018).
Whistleblowing is the disclosure of illegal, immoral, or illegitimate
practices by employee(s), former or current, of public or private organiza-
tions to persons or organizations that may be able to take or initiate some
action (Near and Miceli 1985; Figg 2000).
Whistleblowers are source of valuable information that neither the gov-
ernment nor the public can get from oversight systems. Moreover, they
are knowledgeable people who know precisely what their organizations
are doing. Thus, whistleblowing is an important means of improving gov-
ernment transparency and accountability (Apaza and Chang 2011;
Rosenbloom 2003; Jos 1991; Rosen 1998).
However, whistleblowing is not always welcomed by organizational
members and puts the person in very dangerous situations depending on
legal protection or organizational culture. But, in spite of the fact that
there is still negative belief in whistleblowing, whistleblowing is socially
desirable and positively influence employees, organizations, and society
(Culiberg and Mihelic 2017). This can be reflected by both the increasing
whistleblowing actions and whistleblowing research in the world.
Indeed, after the first edition of this book, whistleblowing actions and
whistleblowing research increased significantly. This happened not only
because more and more whistleblowers from the public and private sectors
decided to blow the whistle but also because an increasing number of
researchers analyzed the process. For example, whistleblowing and social
action against corruption in Latin America (Salas 2017), serious public
wrongdoings in Australia (Cassematis and Wortley 2013), whistleblowing
process in Norwegian labor market (Skivenes and Trygstad 2017), whis-
tleblowing intentions of public accountants in Indonesia (Latan et al.
2018), whistleblowing intentions in South Africa and Mauritius (Pillay
et al. 2018), propensity of whistleblowing in China, Taiwan, and the USA
(Hwang et al. 2013), moral reasoning and retaliation on whistleblowing
in New Zealand (Liyanarachchi and Newdick 2009).
In most of those cases there was a positive action against the wrongdo-
ing. Hence, they were somehow effective. But what is exactly effective
whistleblowing?
 1 EFFECTIVE WHISTLEBLOWING CONCEPTUAL FRAMEWORK 3

1   Effective Whistleblowing

In the first edition of this book we identified five factors that define effec-
tive whistleblowing: type of whistleblowing, role of mass media, docu-
mentation of evidence, retaliation, and legal protection (Apaza and Chang
2017). These factors were determined by a careful study of the theory
existed then.
In this regard, we found that Near and Miceli (1995) defined effective-
ness in whistleblowing as “the extent to which the questionable or wrong-
ful practice (or omission) is terminated at least partly because of
whistle-blowing and within a reasonable time frame” (p. 681). Likewise,
Dworkin and Baucus (1998) suggested that effectiveness is attained “if the
organization launched an investigation into the whistleblower’s allega-
tions—on their own initiative or required by a government agency, or if
the organization took steps to change policies, procedures, or eliminate
wrongdoing” (p. 1289). In the same sense, Ellison, Keenan, Lockhart,
and Van Schaik (1985) suggested that successful whistleblowing should
have two components: the activeness of the purpose and the influence
in others.
Based on those previous findings, and critically analyzing whistleblow-
ing cases in Peru, South Korea, Thailand, and the USA, we found that an
effective whistleblowing is a disclosure of a wrongdoing mainly done
through mass media coverage such as TV and internet), that led to: (i)
government or non-governmental investigation, (ii) to take steps to
change policies or procedures, and (iii) to terminate the wrongdoing
within a reasonable time frame (Apaza and Chang 2017). Accordingly, we
suggested 5 factors of effective whistleblowing:

1. Type of whistleblowing (Internal and External Whistleblowing)

An internal whistleblowing is the person who discloses the infor-
mation following the procedures of his/her organization. In con-
trast an external whistleblower is a person who reports an
organization’s illegal, immoral, or illegitimate workings to someone
outside the organization (Dworkin and Baucus 1998). Unfortunately,
in both cases whistleblowers usually suffer retaliation in differ-
ent levels.
But by looking at the results of the whistleblowing (i.e. investiga-
tions done, organizational positive changes implemented as a
consequence of the disclosure), external whistleblowing is more
­
4 C. R. APAZA AND Y. CHANG

effective than the internal one (Rothschild and Miethe’s 1999;

Dworkin and Baucus 1998). For example, corruption cases in Peru
and South Korean got attentions after blowing the whistle through
mass media (Apaza and Chang 2017).
2. Role of mass media
The use of mass media to disclose corruption highly depends on
social and cultural aspects, which may affect whistleblowers’ deci-
sion on whether to blow the whistle. For instance, in societies where
a high percent of the population watches popular national TV news
programs, such as in Peru, whistleblowers would prefer to blow the
whistle through this channel (Apaza 2017). However, in a culture
where people highly value group loyalty and safe face, like in Japan,
people would use other channels (Davis and Konish 2007).
But most of the effective whistleblowing started from the mass
media and nowadays more and more whistleblowers are choosing
mass media to blow the whistle (Dworkin and Brown 2013). In
most cases the whistle firstly was blown through internal channels
but then turned to external ones (Nielsen 2018; Callahan and
Dworkin 1994; Dworkin and Brown 2013).
3. Strong evidence
Strong evidence is necessary to initiate any kind of investigation
specially in the legal environment. Hence, whistleblowers need to
collect all the supporting documentation and even they need to be
cautious about determining when to blow the whistle (Devine
2017) because it may be long and may be “a tortuous path of litiga-
tion” (Rosenbloom 2015, p. 146), Actually, because during the liti-
gation the information will be exposed to hard scrutiny,
whistleblowers need to double check the veracity and relevancy of
their information before blowing the whistle (Amoedo 2017).
One thing to take into consideration is that having good quality
evidence usually lead whistleblowers to blow the whistle through
external means (Near and Miceli 1995; Dworkin and Baucus 1998).
This has been totally be proven in the Brazilian case about the huge
Odebrecht corruption scandal that negatively impacted all Latin
America. The whistleblower had objective evidence of all the cor-
ruption process (see the Brazil chapter).
To sum up, acquiring strong evidence should be the first element
when whistleblowers decide to blow the whistle (Apaza and
Chang 2011).
 1 EFFECTIVE WHISTLEBLOWING CONCEPTUAL FRAMEWORK 5

4. No retaliation
An effective whistleblowing means that the whistleblower did not
suffer a brutal retaliation. But in the real world a whistleblower
always suffers a certain level of retaliation, which may be defined as
an undesirable action taken against a whistleblower (Rehg et al.
2008). These actions include intimidation (Guerrero 2018) nega-
tive performance appraisals, inappropriate work assignments or
transfer, threats of physical harm, harassment, humiliation, or isola-
tion (Park et al. 2018), sent to jail (Jakes 2003), dismissal or even
killed (Devraj 2003).
When the whistle was blown through internal channels public
organizations common retaliations include: denial of a job promo-
tion (Apaza 2008), dismissal or forcing to resignation (Jos et al.
1989) or to retire (Rothschild and Miethe 1999).
But when the whistle was blown through external channels, orga-
nizations used more comprehensive forms of retaliation against
external reporting (Dworkin and Baucus 1998).
In any case, retaliation frequently happens after the whistleblow-
ing (Guerrero 2018; Kenny et al. 2018), and it is closely associated
with whistleblowing intention (Cho and Song 2015). Nevertheless,
in the dimension of an effective whistleblowing retaliation should be
prevented through a well-established and implemented whistle-
blowing legal protection system (Apaza and Chang 2017).
5. Legal protection
The existence of a legal protection system for whistleblowers is basic
for an effective whistleblowing. Recently many whistleblowing pro-
tection laws have been issued and implemented (Amoedo 2017).
Based on our case studies we find that whistleblowing were more
effective in countries where there was a legal protection system
already implemented for whistleblowers.

Usually, a legal protection system for whistleblowers reduces the

chances of retaliation against whistleblowers by their employers or col-
leagues (Guerrero 2018) and can change “organizational culture to view
whistleblowing as a civic obligation and public virtue, rather than insubor-
dination, snitching, or tattling” (Rosenbloom 2003, p. 133). The main
purpose of whistleblowing legislation is to defend whistleblowers from
reprisals (Vandekerckhove 2010; Rosenbloom 2015). Also, the existence
of an adequate legal protection law influences in the decision of
6 C. R. APAZA AND Y. CHANG

whistleblowers whether to blow or not the whistle (Chang et al. 2017;

Mesmer-­Magnus and Viswesvaran 2005; Rothschild 2008).
But apart from the existence of a legal protection system for whistle-
blowers, it is important to consider the present and positive influence of
independent, fair, and strong, law enforcement agencies (Amoedo 2017;
Johnson 2004). This is very important for effective whistleblowing, For
instance in Brazil, the investigation of the expensive Odebrecht corrup-
tion scandal was positively influenced by an effective law enforce-
ment system.
But unfortunately, only a few countries, such as the United Kingdom,
South Africa, the United States, Canada, and Japan have comprehensive
laws (Banisar 2006; Kaplan 2001), others have sectorial laws (OCDE
2011), and others don’t have any protection law for whistleblowers. But,
we don’t only need comprehensive laws (National Whistleblower Center
2019) but we also need the establishment of a comprehensive protection
system to adequately implement the whistleblowing protection law. It
means that the existence of an independent law enforcement agency and
an independent judicial system is also crucial (see more in the Brazil
chapter).
To sum up, the aforementioned five factors were considered for analyz-
ing effective whistleblowing in the first edition of this book. In this new
edition we apply the same factors and discover new ones through the study
of whistleblowing cases from Belgium, Brazil, Finland, Japan, and the
Philippines.

2   Methodology
To evaluate the aforementioned factors influencing effective whistleblow-
ing, we apply the case study method, as in the previous edition. A case
study is an empirical inquiry that investigates a contemporary phenome-
non within its real-life context, especially when the boundaries between
phenomenon and context are not clearly evident (Yin 2003, p. 13, 2009,
p. 18). The case study method is well suited to whistleblowing research
because it can show conditional findings in detail and can examine interac-
tions of a cause-and-effect relationship (Jensen and Rodgers 2001).
Moreover, the case study method helps to do an in-depth study of an
organization culture (Benson and Ross 1998), which is crucial for under-
standing why whistleblowers decide not to blow the whistle within their
own organizations.
 1 EFFECTIVE WHISTLEBLOWING CONCEPTUAL FRAMEWORK 7

Case analysis enables scholars to build concepts and theories of public

administration research with systematic knowledge (Rosenbloom 1994)
and can help practitioners understand “what to do and what to avoid,
what works and what does not in specific circumstances” (p. 44). Likewise,
George, Bennett, Lynn-Jones, and Miller (2005) also identified four
strengths of case study methods: (1) achieving “high levels of conceptual
validity” (p. 19); (2) identifying “new variables and hypotheses through
the study of deviant or outlier cases” (p. 20); (3) examining “the opera-
tion of causal mechanisms in individual cases in details” (p. 21); (4)
accommodating “complex causal relations” (p. 22).
Even though somehow case studies are criticized because of selection
bias, degree of freedom, generalizability of case study results, and lack of
replicability (Rosenbloom 1994; George et al. 2005; Jensen and Rodgers
2001), we believe that the case study method is a suitable method to study
whistleblowing.
To sum up, applying the case study method, this study considers five
units of analysis referring to effective whistleblowing in Belgium, Brazil,
Finland, Japan, and the Philippines.

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Yin, R. K. (2003). Case study research: Design and methods (3rd ed.). Thousand
Oaks: Sage Publications.
Yin, R. K. (2009). Case study research: Design and methods (4th ed.). Thousand
Oaks: Sage Publications.
 CHAPTER 2

Whistleblowing in Belgium

Frankie Schram

Abstract In recent years a whistleblowing legislation in the public sec-

tor has been developed in Belgium on the federal and Flemish level. In
both systems an important place is given to the ombudsman institutions,
because they can give legal protection to the whistleblower. In the given
case, it is shown that whistleblowing can move towards a more ethical and
effective decision making process. It makes also clear that the use of media
as channel for whistleblowing creates a pressure to change things in pub-
lic sector. From the point of legal protection it finds his limits in the free-
dom of expression. Civil servants must exercise restraint so as not to
unnecessarily jeopardize the public’s belief in the public sector.

Keywords Whistleblowing legislation • Belgium • Public sector •

Ombudsman • Legal protection • Media • Pressure • Freedom of
expression

F. Schram (*)
Faculty of Social Science, Public Governance Institute, University KU Leuven,
Leuven, Belgium
e-mail: [email protected]
© The Author(s) 2020 11
C. R. Apaza, Y. Chang (eds.), What Makes Effective Whistleblowing,
https://doi.org/10.1007/978-3-030-40200-6_2
12 F. SCHRAM

1   Introduction

1.1  Belgium, a Federal State

According to Transparency International Corruption Perceptions Index
2019 Belgium has a score of 75 on a scale of 0 (very corrupt) and 100
(very clean) (Transparency International 2020). Regarding previous
indexes Belgium obtained slightly better results this time. Although
Belgium has obtained a whistleblowing legal framework on the federal and
Flemish level, the better results cannot be subscribed to this. Belgium can
be considered as an old democracy with some control mechanisms (con-
trol by the Court of Audit for the federal administration and the adminis-
trations of regions and communities), structures and democratic culture
where the rule of law is consolidated. Belgium is indeed a federal state of
a special kind with three communities and three regions. Communities
deal with language, culture and education; regions deal with matters
linked to a territory. There is the Flemish community (Dutch speaking)
and the Flemish region, the French community (French speaking) and the
Walloon region, the German speaking community (German speaking) and
the Brussels-Capital region (bilingual). Each region has its own parlia-
ment, government, public administration and civil service. Regions and
communities have attributed powers, the federal level has everything that
is not attributed and competences that are expressly attributed to the fed-
eral level.
The Belgian federal system has some specific characteristics. One of
them is that the legal acts of the federal state (laws) and of the communi-
ties and regions (decrees and ordinances) have the same legal value.
Another feature is the asymmetric structure of the Belgian federal system:
in Flanders the institutions of the Flemish region and of the Flemish com-
munity are assimilated, although this is not the case for the French com-
munity and the Walloon region. But because of a lack of money the French
community has transferred powers to the Walloon region and the French
community commission of the Brussels Region. The result of the federal
system is a very high complexity of the structure of the Belgium state
(Deschouwer 2013, pp. 211–222; Deschouwer and Reuchamps 2013,
pp. 261–270).
 2 WHISTLEBLOWING IN BELGIUM 13

1.2  
Belgium and the Fight Against Corruption
The UNO, the Council of Europe, the European Union and the OECD
developed some instruments to avoid corruption. Belgium was party with
all these initiatives.
On 17 December 1997 Belgium signed the Convention on combating
bribery of foreign public officials in international business transactions.1 The
Ratification Act received royal approval on 9 June 1999.2 Belgium depos-
ited its ratification instrument with OECD on 27 July 1999. To meet the
requirements of this Convention, but also to modernise the Criminal
Code’s provisions on bribery, the Belgian Parliament adopted two Acts.
The first is the Bribery Prevention Act of 10 February 1999 which entered
into force on 3 April 1999.3 This Act amended in particular the provisions
contained in Title IV of the Criminal Code in Articles 246–252 of Chapter
IV on “The Bribery of Public Officials”. The second Act is that of 4 May
1999 Establishing the Criminal Liability of Legal Persons, which entered
into force on 3 August 1999. This Act established the criminal liability of
legal persons that are subject to the provisions of the Bribery Prevention
Act of 10 February 1999.
The main objectives of the amendments to the Criminal Code are
threefold.4 The first objective was to cover new offences contained in the
OECD Convention and not previously covered by Belgian legislation
(bribery of foreign public officials and international civil servants), as well
as other offences such as bribery of an applicant for a public function, trad-
ing in influence and private corruption. The second objective was to fill
some gaps in the field of sanctions, primarily by adapting penalties to
current penological trends higher minimum and maximum penalties for
sentences involving deprivation of liberty and for fines), by introducing
new administrative sanctions against public works contractors who engage
in bribery, and by amending the Income Tax Code to limit the tax deduct-
ibility of bribes. The third objective was to broaden the extraterritorial
jurisdiction of Belgian courts, in particular as regards bribery involving

1
http://www.olis.oecd.org/olis/1997doc.nsf/43bb6130e5e86e5fc12569fa005d004
c/5005eebd0c0be05880256754005d2ba0/$FILE/04E81240.ENG
2
Official Gazette, 20 November 1999, addendum, 26 March 2002.
3
Official Gazette, 23 March 1999.
4
Parliamentary documents, Chamber, 1997–1998, no. 1664/3, 3–8.
14 F. SCHRAM

foreign public officials.5 By this law the basic concepts were clarified, and
the terminology modernised. It enabled the receipt of bribes, trading
influence, corruption of candidates for public office, corruption of foreign
civil servants and of officials of international organisations and corruption
in the private sector to be made criminal acts. The Act also provides that
“secret commissions” may no longer be tax-deductible where they are
paid in connection with obtaining or retaining public procurement con-
tracts or administrative authorisations.6
Belgium ratified the Council of Europe Criminal Law Convention on
Corruption.7 The Ratification Bill was signed by the King on 19 February
2004.8 Belgium signed also on 7 March the Additional Protocol to the
Criminal Law Convention on Corruption9 and has ratified it on 26
February 2009. Belgium signed the Council of Europe Civil Law
Convention on Corruption10 on 8 June 2000 and has ratified it on 12
March 2007.
Belgium is also member of GRECO (Group of States against
Corruption). GRECO was conceived as a flexible and efficient follow-up
mechanism, called to monitor, through a process of mutual evaluation and
peer pressure, the observance of the Guiding Principles in the Fight against
Corruption and the implementation of international legal instruments
adopted in pursuance of the Program of Action against Corruption. Full
membership of the GRECO is reserved to those who participate fully in
the mutual evaluation process and accept to be evaluated. Belgium was the
fourth country to be evaluated in the first evaluation round of GRECO.11

5
OESO, Belgium—Phase 1 Bis: Report on Implementation on the OECD Anti-Bribery
Convention, Parijs, 2000, 21 p., http://www.oecd.org/dataoecd/13/7/2385130.pdf;
OESO, Steps taken and planned future actions by participating countries to implement the
Convention on combating bribery of foreign public officials in international business transac-
tions, Parijs, juni 2005, 7, http://www.oecd.org/dataoecd/50/33/1827022.pdf
6
Evaluation Report on Belgium adopted by the GRECO at its 4th Plenary Meeting
(12–15 December 2000), nr. 10, 4; http://www.greco.coe.int/evaluations/cycle1/
GrecoEval1Rep(2000)1E-Belgium.pdf
7
http://conventions.coe.int/Treaty/EN/Treaties/Html/173.htm
8
Official Gazette, 10 May 2004.
9
http://conventions.coe.int/Treaty/en/Treaties/Word/191.doc
10
http://conventions.coe.int/treaty/en/Treaties/Word/174.doc
11
Evaluation Report on Belgium adopted by the GRECO at its 4th Plenary Meeting
(12–15 December 2000), http://www.greco.coe.int/evaluations/cycle1/GrecoEval1Rep
(2000)1E-Belgium.pdf and Compliance Report on Belgium adopted by GRECO at its 14th
Plenary Meeting (Strasbourg, 7–11 July 2003).
 2 WHISTLEBLOWING IN BELGIUM 15

Belgium was the tenth GRECO member to be examined in the Second

Evaluation Round.12
According to its Statute, the aim of the GRECO is to improve its mem-
bers’ capacity to fight corruption by monitoring the compliance of States
with their undertakings in this field. In this way, it will contribute to iden-
tifying deficiencies and insufficiencies of national mechanisms against cor-
ruption, and to prompting the necessary legislative, institutional and
practical reforms in order to better prevent and combat corruption.
GRECO is responsible, in particular, for monitoring observance of the
Guiding Principles for the Fight against Corruption and implementation
of the international legal instruments adopted in pursuit of the Program
of Action against Corruption (PAC).
Belgium has signed the United Nations Convention against Corruption13
on 10 December 2003 and has ratified it on 25 September 2008.
On the EU-level Belgium has signed, ratified14 and implemented the
first and second protocol to the Convention on the Protection of the Financial
Interests and the Convention on the fight against corruption involving offi-
cials of the European Communities or officials of the Member States of the
European Union.15
In the Criminal Code there were also special provisions against bribery
and abuse of power. The Code’s provisions on bribery, which dated already
from 1867 has not been substantially amended till the Bribery Prevention
Act of 10 February 1999. In the Criminal Code there was only a limit
vision on corruption. Corruption was limited to bribery in the public
sphere. From the Bribery Prevention Act of 12 February 1999, the con-
cept was extended also to the private sphere. Before that Act there were
several gaps in these provisions, especially as regards the facts and conduct
capable of being the subject of a criminal charge. In addition, the existence

12
Second Evaluation. Evaluation Report on Belgium adopted by GRECO at its 21st Plenary
Meeting (Strasbourg, 29 November—2 December 2004), http://www.greco.coe.int/evalu-
ations/cycle2/GrecoEval2Rep(2004)1E-Belgium.pdf
13
h t t p : / / w w w. u n o d c . o r g / p d f / c r i m e / c o n v e n t i o n _ c o r r u p t i o n / s i g n i n g /
Convention-e.pdf
14
Law of 17 February 2002, Official Gazette, 15 May 2002.
15
Council Act 97/C 195/01 of 26 May 1997 drawing up, on the basis of Article K.3 (2)
(c) of the Treaty on European Union, the Convention on the fight against corruption involv-
ing officials of the European Communities or officials of Member States of the European
Union, Official Journal C 195 of 25 June 1997 and the Second Protocol, Official Journal C
221/02 19 July 97.
16 F. SCHRAM

of a corruption pact had to be proved, which rendered prosecution diffi-

cult. Moreover, owing to their size, especially in the field of real estate,
major town-planning projects created conditions favourable to the growth
of corruption.16

1.3  Whistleblowing Legislations
From 2000 on, more attention was paid to the ethical behaviour of civil
servants as a correction mechanism of the introduction of the New Public
Management in the federal and Flemish administrations. Deontological
codes were worked out, values were made a priority, training sessions were
organised for civil servants. In the same movement, whistleblowing legal
frameworks were created first at a Flemish level in 2004 and later in 2013
at a federal level (Schram 2017, pp. 601–703).
Long before whistleblowing legal frameworks were worked out, all civil
servants and public officials already had the duty to report crimes they
come across during the fulfilment of their mandate to the Crown
Prosecutor (article 29 Criminal Procedure Law). In practice this article
remains irrelevant to the realities of malpractice in administration, regard-
less of whether the wrongdoing constitutes a crime or questionable
behaviour.
Both the Flemish and federal whistleblowing framework are worked
out on different levels, where the intention of the legislator is for report-
ing to be done first on the first level (the level of the proper administration
or internal audit17), secondly on a second level (the level of the Ombudsman
function). There is the possibility of going directly to the public prosecu-
tor when the irregularity is to be considered a crime (Table 2.1).
The Flemish whistleblowing framework is not to be found in one single
legal text: parts of it can be found in the Flemish Personal Statue (VPS),
in a protocol dated 4 July 2005 between the Flemish Ombudsman and the

16
Evaluation Report on Belgium adopted by the GRECO at its 4th Plenary Meeting (12–15
December 2000), nr. 7, p. 3, http://www.greco.coe.int/evaluations/cycle1/GrecoEval1Rep
(2000)1E-Belgium.pdf
17
Established in the Decision of the Flemish Government dated 8 September 2000 estab-
lishing and organising the functioning of the Internal Audit of the Ministry of the Flemish
Community entity, O.J. 24 October 2000. It was transformed into Audit Vlaanderen from 1
January 2014 by the Decree of 5 July 2013 (Audit Decree) and the Decision of the Flemish
government of 14 March 2014 concerning the establishment of the internal autonomous
agency “Audit Vlaanderen”, O.J. 1 April 2015, 20.019. Some articles are transposed to the
Administrative Decree of 7 December 2018, OJ 19 December 2018.
 2 WHISTLEBLOWING IN BELGIUM 17

Table 2.1 Organisation of the channels in the Flemish whistleblowing system

Internal External

Inside the Inside the Autonomous Service Linked to the

Not
organisation administration audit function linked to the judicial power
linked
Legislator to the
public
sector
Hierarchy Spreekbuis Audit Ombudsman Article 29 Code Media
Vlaanderen Court of of Criminal
Audit Procedure
(Public
prosecutor)
Central Service
for the Combat
of Corruption
(Police)

Flemish Government regulating the protection of whistleblowers,18

between the Flemish Ombudsman and the Internal Audit Office and in
the Decree dated 7 July 1998 establishing the Flemish Office of the
Ombudsman.
The choice for The Flemish Ombudsman as a channel for whistleblow-
ing was not an obvious choice. The Choice of the Flemish Government
was essentially based on the wish of the Flemish Government not to create
new institutions (Schram 2005, p. 154).19 As justification for the choice it
was pointed out the independence of the Ombudsman Office and his con-
nection with the Flemish Parliament. According the Explanatory
Memorandum the Flemish Ombudsman has enough authority, expertise
and means to examine complaints from civil servants about irregularities.
Finally, the discretion with which the Ombudsman Service can deal with
such reports was cited as reason for this choice.

1.4  The Studied Case

The case studied is the most famous today and is situated within the
Flemish administration: the case of Rudy Aernoudt. Rudy Aernoudt was

18
At this moment replaced by the Protocol dated 9 May 2014 regulating the protection of
Whistleblowers, http://www.vlaamseombudsdienst.be/ombs/nl/nieuws/pdf/20140509_
klokkenluidersprotocol.pdf
19
Explanatory Memorandum, Parl. Doc. Vl.Parl. 2002–2003, nr. 1658/1, 3–4.
18 F. SCHRAM

Chief Economist of the European Commission and (Adjunct)-Chief of

Cabinet of the Walloon Minister of Economy Serge Kubla (1999–2003)
and of the federal (2003) and later Flemish (2004–2006) Minister of
Economy Fientje Moerman. In 2006 he became Secretary-general of the
Flemish Department of Economy, Science and Innovation.
As Secretary-general of the Flemish Department of Economy he dis-
tanced himself from the Flemish Minister of Economy, Science and
Innovation, whose chief of cabinet he had been (ita 2007). The problems
between the two people were not new. As Secretary-general he wrote a
note to his minister where he asked her cabinet to adopt the procedure
with regard to missions after the minister has made a voyage to Canada
that was extremely expressive. He labelled the unforeseen expenditure as
‘substantially out of proportion”. Aernoudt refused to budget for it and
pay the amounts. In response, the minister took the responsibility on the
budget travel expenses from him and he got the department of Foreign
Affairs (Department International Vlaanderen). There were problems
with a lot of consultancy contracts where the existing legislation was not
followed, and the Foundation Hercules was created against the advice of
several people.
He reformed the working of his department without the consent of the
other Secretary generals of the Flemish administration. His way of work-
ing created a lot of resistance. Internal Audit examined 28 complaints
against him, and the report was not favourable for him (svh 2007;
Tegenbos 2007). In December 2006 he filed a complaint with the Flemish
Ombudsman about unethical practices within the cabinet of the Minister
of Economy (De Standaard 2007). He received the protection that can be
given to whistle-­blowers by the Flemish Ombudsman.
On 11 September 2007, before the final report of the Flemish
Ombudsman (Belga 2009a, b, c; wwi/svh 2007), an article was published
in the journal Le Soir, where Aernoudt heavily criticised the policy within
the Flemish government. He talks about the unnecessary creation of
structures only to nominate political friends and about giving contracts to
friendly experts. In the interview it was not clear if Aernoudt talked as a
private person or as secretariat-general of the department. At the same
time, a petition circulated on the internet calling for Aernoudt to be prime
minister (De Morgen, Internetpetitie wil Rudy Aernoudt als premier, De
Morgen 2007a).
These facts led to the dismissal with cause of Rudy Aernoudt by the
Flemish government (Belga 2007; rbo/wle. 2007). Aernoudt went to the
 2 WHISTLEBLOWING IN BELGIUM 19

Labour Court of Brussels and he fought his resignation. The Labour

Court ruled in its judgment that the dismissal of Aernoudt was justified.
According to the Labour Court “does the freedom of thought and the free-
dom of expression, guaranteed by the Constitution not that it is forbidden for
a person to do prejudice to the authority and the good name of his employer,
the more we are talking about public figures.”20 The court also ruled that in
his capacity as Secretary general of a department of the Flemish adminis-
tration Aernoudt has the duty of restraint and discretion. The interview in
Le Soir was considered to be an infringement of these duties (Belga 2009a,
b, c; belga/vsv 2009; g.teg., svh 2009). The Labour Court considered
that he had behaved disloyally in relation to the Flemish Government and
that he had undeniably broken the trust of his employer, which justified
the dismissal as an urgent reason (Trends 2010).
Aernoudt went to appeal (Belga 2009a, b, c; belga/ka/sam 2009) and
in its judgement dated 3 September 2010, the Labour Court of Appeal of
decided in his favour.21 The Labour Court of Appeal ruled that Aernoudt
had not respected the deontological code of Flemish civil servants by not
making clear that he expressed his criticism of the Flemish government as
a private person, giving the impression that he expressed himself in his
capacity as Secretary General (belga/sps 2010; kld 2010). Then the Court
considered that the grounds for Aernoudt’s dismissal, namely the interview
and the petition “Aernoudt prime minister”, are not enough to proceed
with the weighty decision of dismissal: “The Flemish government had to
make a balance exercise if by this error immediately made the cooperation
impossible and in doing so, given the tense relationship between the Secretary
General Aernoudt and the minister Fientje Moerman (Open VLD), the court
decided not only to rely on the vision of the last one. The Flemish Government
could have obtained greater objectivity by hearing Mr Aernoudt and his point
of view more into consideration”, is explained in the judgement.22
The Court recognised that there was an infringement of the deonto-
logical code and agreed that a sanction was possible for this, but the
choice of a dismissal was disproportionate given the concrete circum-
stances. At the end the Court awarded him a termination payment, but

20
Labour Court of Brussels, 29 January 2009, nr. 1588/08, own translation.
21
Labour Court of Appeal Brussels, 3 September 2010, nr. 2009/AB/52094.
22
Labour Court of Appeal Brussels, 3 September 2010, nr. 2009/AB/52094, own
translation.
20 F. SCHRAM

his claim for compensation for damage to reputation was rejected (Het
Nieuwsblad 2010).
The Flemish Parliament had, on initial application of Filip Dewinter
(Vlaams Belang) asked for a screening as a reaction to the Moerman case.
In its report dated 17 July 2008, the Court of Audit confirmed the facts.
The Court of Audit examined the 68 consultancy assignments, worth 1.7
million euros, which the Flemish cabinets awarded between July 22, 2004,
the beginning of the Leterme I government (22 July 2004 to 26 July
2007) (which was succeeded by the Peters I government in July 2007),
and 31 December 2007. In his report dated 17 July 2008, the Court of
Audit showed that the Moerman-case was not an isolated case. At the
award of contracts bumped the trust relationship between the consultant
and the Minister more than once with the principle of competition. Apart
from the consultants, the cabinets paid 3 million euros to experts (Het
Laatste Nieuws 2008).
In 2011 it was made public that the Brussels Prosecutor’s Office
believed that criminal offences had been committed for the award of a
consultancy contract by the Cabinet of the Cabinet of former Flemish
Minister Fientje Moerman (De Morgen 2009). It prosecuted the consul-
tancy office and one of the policy advisors to Moerman, Guy Serraes
(Open VLD). According to the Public Prosecutor’s Office the award of
that contract was rigged and played the consultancy Office in collusion
with Serraes. There might even have been faked documents.

2   Analysis
The events in this case took place at high levels of government and had an
important political repercussion. It is one of the rare cases where whistle-
blowing has direct results because actions were taken almost immediately.
One specific thing about this case is that it is about a ministerial cabinet
in general and one minister in particular. In Belgium ministerial cabinets
plays a very dominant role in political life and this has been frequently
criticised. Ministerial cabinets are the personal collaborators of the Minister
and must be loyal to the political vision of the Minister and the political
party he or she is a member of. Cabinets monopolise all major policy
preparation tasks and form a parallel bureaucracy that duplicates the exec-
utive tasks of the administration. The pressure from the cabinets would
demotivate officials. Cabinets would further play a central role in the
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