Comparison of approaches to whistleblowing and whistleblower protection in the European Union and the United Sates of America

This thesis deals with the issue of whistleblowing, i.e., reporting illegal or unethical conduct, and focuses on an analysis of the legal protection of whistleblowers in the European Union and the United States. Whistleblowing is an important tool to ensure transparency, fairness and compliance with legal standards in organizations, especially where normal control mechanisms fail. Given the growing importance of this issue and the evolution of public and legislative attitudes, the thesis aims to assess the effectiveness of current legal frameworks and formulate recommendations for improving whistleblower protection in the Czech Republic. The research is based on comparative analysis of legislation, literature, statistical data and case studies. The key European Union document is Directive (EU) 2019/1937 of the European Parliament and of the Council, and on the United States side, key legislation including the False Claims Act, the Whistleblower Protection Act, the Sarbanes-Oxley Act, and the Dodd-Frank Act are analyzed. The thesis compares the approaches of the two legal systems, identifies their strengths and weaknesses, and assesses the impact on whistleblowers in practice. The result is a set of proposals that could contribute to increasing the effectiveness and legal certainty of whistleblowing in the Czech Republic.