근로자 내부고발 보호제도 국제비교

International Comparison of the Protection of Whistleblowing WorkersHwa-ik JangThis research analysed in detail the case of Japan and the U.K. where new laws have been enacted on the Protection of Whistleblowing Workers, and the U.S. where various mechanisms have been developed on this issue. This study analysed the current labor law in Korea on the protection of whistleblowing workers and tried to identify the implications for developing the related legal system based on the case studies in the three countries.First, this research found that the three countries have developed a legal system to meet social demands for the protection of whitleblowing workers as well as the prevention of incidents concerning the environment, food, finance, safety and so on. In Korea, it is necessary to introduce new legal regulations on the Protection of Whistleblowing Workers, especially in light of financial scandals involving large business conglomerates (Chaebol), public's lack of awareness to abide by the law, uninviting social culture to whilstleblowers, and inadequate legal system. In legislating for the protection of whitleblowing workers, such workers should be safeguarded from any illegal actions by their organizations. Illegal activities may need to be disclosed to the government, mass media and NGOs under certain conditions. An alternative is to endow the Labour Commission with the responsibility of protecting workers from dismissal and other disadvantages.