동아시아 4개국 부패방지법상의 내부고발자 보호에 관한 비교연구

The current study compares and analyzes whistleblower protection provisions on anti-corruption laws in Singapore, Hong Kong, Taiwan, and South Korea, considering essentials to make an effective whistleblower protection law. Based on the results of legal analyses, all countries in this study do not have a comprehensive whistleblower protection law. Singapore and Hong Kong provide limited protections to whistleblowers, even though the countries follow the common law tradition. Taiwan provides slightly better protection than Hong Kong and Singapore do, but the range of protection is limited. Although South Korea provides the most advanced whistleblower protection among these countries, whistleblower protection is not strongly guaranteed in the country because of limited power of the anti-corruption commission.