Whistleblowing as a Corporate Governance Mechanism : A Comparative Analysis of Employee-Whistleblower Protection in the United Kingdom and Nigeria

Under the notion of effective corporate governance, transparency and information disclosure are ideal requirements for the successful running of a corporation. However, in this age of sophistication in information processing and storage, these do not always come easy. Given this reality, stakeholders are expected to be involved in seeing to it that a corporation is transparently run without giving room for the perpetration of sinister activities by the managers of the company, more so when taking into consideration the fallible human nature of the managers. Whilst several approaches are consistently birthed in this regard, whistleblowing over the years has come to be reckoned with as one of those corporate governance mechanisms that effectively checkmate the managers in their administering of corporate entities. Whereas, whistleblowing involves a wide range of players/actors touching invariably all stakeholders of the company including shareholders, managers, promoters, employees and even the society at large, in most cases the employee-whistle-blowers are susceptible to reprisal attacks by erring managers than others, resulting in demotions and even termination of their employment contracts. For this reason, there has been a growing regulatory intervention in various jurisdictions to protect whistle-blowers, particularly, employees from suffering any detriment as a result of their brave act of disclosure to serve the public good. This paper compares the employee-whistle-blower protection regimes in two jurisdictions, the United Kingdom and Nigeria. It concludes that whereas both countries have wide-ranging regulatory provisions protecting employee-whistle-blowers from victimisation, the UK adopts a more intentional approach, going by its unified regulatory regime on whistle-blower protection