Whistleblowing as an anti-corruption strategy in health and pharmaceutical organizations in low- and middle-income countries: a scoping review

Figures & data

Figure 1. Article selection process .

Table 1. Definition and purpose of whistleblowing.

Organisation	Definition of Whistleblowing or whistleblower	Purpose
Global Fund [34,42]	“A pathway to report and expose corruption within an organisation [involving] open disclosure about significant wrongdoing made by a concerned citizen totally or predominantly motivated by notions of public interest.” [34] “To blow the whistle is to alert a third party that a person or entity has done, or is doing, something wrong. So, literally, “whistle-blowing” means that a party, in good faith, conveys or transmits a concern, allegation or information indicating that a prohibited practice is occurring or has occurred in the Global Fund or in a Global Fund-financed operation.” [42]	To improve accountability and transparency to ensure organisational credibility and effectiveness of funding. To manage risks effectively and prevent, detect, and stand up to corruption. To maintain trust. To fulfill the Global Fund’s “duty … to act as a responsible custodian or trustee of funds entrusted to it, by protecting the interests and assets of all its stakeholders—donor countries, recipient countries, or diverse beneficiaries alike.”
United Nations Office on Drugs and Crime [15]	According to article 8 of the UN Convention Against Corruption, states must establish “measures and systems to facilitate the reporting by public officials of acts of corruption to appropriate authorities.”	To detect serious instances of wrongdoing and address them as soon as possible in order to mitigate negative impact on health, finances, and the country’s reputation.
European Union [15,35,43]	Whistleblowers are “reporting persons working in the private or public sector who acquired information on breaches in a work-related context.”	An essential “upstream” component of law enforcement, providing information that leads to effective detection, investigation, and prosecution. It can help prevent and detect procurement-related fraud and corruption, and unfair or illicit manufacturing, import, or distribution of unsafe products.
Gavi [44]	“‘Whistleblower’ means an individual who reports suspected incidents of breaches of laws, rules or regulations in Gavi’s activities or of serious misconduct or serious infringement of Gavi’s rules, policies or guidelines, or any action that is or could be harmful to the mission or reputation of Gavi (each, a ‘Wrongdoing’).”	“To encourage reporting of suspected wrongdoing that may threaten the operations or governance of Gavi … without fear of retaliatory action, and to enable Gavi to effectively address such wrongdoing, manage risks and uphold standards of good governance.”
WHO [45]	“Whistleblowers [are defined] as individuals who report suspected wrongdoing that implies a significant risk to WHO, i.e. harmful to its interests, reputation, operations or governance.”	“To encourage the reporting of suspected wrongdoing when the wrongdoing implies significant corporate risk (i.e. harmful to the interests, reputation, operations, or governance of WHO) without fear of retaliatory action in order to enable WHO to take early action.”
Food Crime Management Systems [37]	Whistleblowing is “disclosure by organizational members of illegal, immoral, or illegitimate practices that are executed under the control of their employers, to persons or organizations that may be able to effect action as a result of that disclosure.”	Whistleblowing is seen as a management control strategy whose purpose is to deter potential food safety issues, recalls, and profit losses. To help businesses to identify and manage risks better.

Figure 2. WHO integrity hotline complaints, Jan-Nov, 2020.

Chang Z, Rusu V, Kohler JC. The global fund: why anti-corruption, transparency and accountability matter [Article]. Glob Health. 2021;17. DOI:10.1186/s12992-021-00753-w

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The Global Fund Office of the Inspector General. Whistle-blowing policy and procedures for the global fund to fight AIDS, tuberculosis and malaria. The Global Fund. 2019;1–7.

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United Nations Office on Drugs and Crime. Speak-up for health: guidelines to enable whistle-blower protection in the health-care sector. Vienna: UNODC; 2021. pp. 1–76.

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European Commission. Frequently asked questions: whistleblower protection. Memo 18/3442. Brussels: European Commission; 2018. pp. 1–5.

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European Union. Directive (EU) 2019/1937 of the European parliament and of the council of 23 October 2019 on the protection of persons who report breaches of Union law. Luxembourg: European Union; 2019. pp. 1–39.

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Gavi. Gavi alliance whistleblowing policy version 4.0. Geneva: Gavi; 2020.

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World Health Organization. WHO whistleblowing and protection against retaliation. Policy and procedures. Geneva: WHO Office of Compliance, Risk Management, and Ethics; 2015. pp. 1–14.

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