Whistleblowers are raising concerns about the lack of clarity surrounding their protections due to recent legal developments [1]. According to Jean-Baptiste Elias, former president of the National Anti-Corruption Authority (ANLC), “it is Articles 31, 32, 33, 34, 35, and 36 of Law 2011-20 of October 12, 2011, on combating corruption and other related offenses in the Republic of Benin [2], which provided for the protection of whistleblowers, and a decree was issued in 2013 to confirm the protection of whistleblowers, witnesses, and other whistleblowers. However, in 2020, this law was repealed”. It was done through a reform establishing the Court for the Repression of Economic Offenses and Terrorism (CRIET) and the High Commission for the Prevention of Corruption (HCPC). With this repeal, the 2013 decree became null and void, rendering obsolete the whistleblower protection mechanisms provided for in the 2011 law [1].

Whistleblowing is encouraged through information and guidance on the reporting of corruption and protections for whistleblowers [1]. Any military personnel can freely report case of corruption, and is protected from reprisals [2]. Indeed, any military personnel who thinks or is suspecting a situation of corruption knows he can report with no fear of reprisal. Once the case is reported, the General Inspection of Army will investigate for measures to be taken [3]. The Court for the Repression of Economic Offences and Terrorism (CRIET) is then responsible for carrying out investigations and imposing the necessary penalties [2]. The CRIET is a well-resourced independent unit that handles claims.

No cases of unprotected whistleblowers were mentioned. However, there are differing perceptions about whistleblowers protection. For top-level officers, officials and personnel are confident that adequate protections (and protection of identity) are provided for whistleblowers and individuals reporting corruption claims [1][2]. The perceptions of middle and lower officers are somewhat mixed. Some of them recognizse that mechanisms are in place for to protect whistleblowers, but doubt that in the event of denunciation against their hierarchies, they will be protected [3][4].

The law on the fight against corruption and related offences protects whistleblowers in cases of corruption in the State services in general without explicit reference to the defence sector This protection is envisaged in general terms without giving any details. Article 13 calls on anti-corruption bodies to take all necessary measures to protect whistleblowers. There are therefore no strong, concrete measures along these lines. [1][2]

Whistleblowing is not practically encouraged by the government. It should be noted that there is no specific legislation for the Defence and security sector in this area. There is no training, guide, or specific units for this. There is just the general anti-corruption law in Burundi which stipulates that anyone who denounces a case of corruption only receives one fifth of the value of the confiscated property, or if there is no confiscation, he will receive a sum ranging from one hundred thousand Burundian francs to three hundred thousand. [1][2]

Officials and members of staff live in fear of reprisals if they dare to denounce cases of corruption [2]. This is why some of them refer to untouchable cases, depending on the position of the perpetrator of the act of corruption. There is therefore a permanent fear that denouncing cases of corruption will cost those who dare to do so dearly [1] [2].

The National Anti-Corruption Commission’s statutory text provides protections for informants [4]; however, a comprehensive legal framework that safeguards whistleblowers remains absent [1] [2] [5]. Civil servants are particularly obligated by their duty of discretion, which further complicates the matter. While there are legal provisions that encourage reporting corruption, the law does not establish clear enforcement mechanisms to protect whistleblowers from retaliation, such as guaranteed anonymity, legal assistance, or consequences for those who retaliate. The absence of a well-defined framework creates uncertainty in its application, weakening its effectiveness.

In Cameroon, although legal provisions exist to encourage whistleblowing and protect whistleblowers, their practical application is limited. The 2006 Law on the Prevention and Repression of Corruption and the National Anti-Corruption Strategy (SNLCC) aim to provide mechanisms for reporting corruption, with institutions such as the National Anti-Corruption Commission (CONAC) created to facilitate this process [1] [2]. However, these legal frameworks are rarely enforced, and the protection of whistleblowers remains ineffective, especially in sensitive sectors like defence and the military. [3]

The implementation of these laws is severely lacking [3]. There is a lack of confidence among officers and military personnel in the effectiveness of whistleblower protection mechanisms. Although legal provisions exist, their implementation is weak, and whistleblowers reporting corruption regularly face reprisals, such as professional harassment, job loss, or even physical threats. The case of Admiral Jean Pierre Nsola perfectly illustrates this climate of repression. His dismissal after exposing irregularities in military procurement demonstrates that the system fails to effectively protect whistleblowers, particularly in the defense sector [4]. Furthermore, the influence of political patronage networks and the culture of impunity reinforce the perception that reporting corruption is risky and unlikely to result in sanctions against perpetrators [1] [2]. This climate of fear is further exacerbated by the pervasive culture of impunity, where corrupt officials are protected by powerful political networks, preventing meaningful accountability [1].

There is no specific legislation on whistleblowers. The Law of 13 June 2018 on the protection of witnesses, victims, informants, experts and other persons concerned appears to provide for certain protective measures, but the concept of whistleblower does not appear in the text. In theory, a whistleblower could apply to the National Office for Witnesses, Victims, Whistleblowers, Experts and Other Persons Concerned to request certain protective measures depending on their situation. However, no cases have yet been reported where this law has been used in the context of a public disclosure [1]. Finally, three years ago, the High Authority for Good Governance established a system for the prevention and detection of acts of corruption and related offences (SPACIA), which offers better protection to whistleblowers and other reporting persons. It is now possible to file complaints and reports on a secure platform [2, 3].

A communication campaign is being relayed by traditional media and conducted on social media to denounce unscrupulous agents. It also mobilises influencers close to the government. Facebook pages such as Police Secours specialise in security alerts. The connection between police units and this Facebook page in particular, and internet calls in general, is impressive. People even feel that raising the alarm on social media is more effective than complaining to the police station [1, 2, 3]. Some officials responsible for regulating public roads are sometimes singled out, but fundamentally, corruption in the awarding of contracts, recruitment, etc. is never a cause for concern [3]. Complaints and reports of corruption against the Ministry of Defence have been filed on the official platform. In 2021, out of 57 cases of alleged corruption in the public sector, three involved the Ministry of Defence [5]. However, no further reports have been published since then. Finally, there is no evidence of training on the subject or of the existence of a unit within the Ministry of Defence responsible for dealing with these issues.

There is not enough evidence to score this indicator. We have not received any response to our requests for interviews on this issue and there are no known cases of public whistleblowers in Côte d’Ivoire [1]. The HABG reported 3 cases of alleged corruption within the Ministry of Defence out of the 57 reported in the public sector in 2021. [2]

The Whistleblowers Act (Act 720) (1), passed in 2006, provides a legal framework for reporting unlawful or corrupt conduct, and military personnel are not exempt from its provisions. The Act acknowledges that whistleblowers may face victimization, such as dismissal, suspension, harassment, and intimidation, as noted in Section 12. To counteract this, the Act includes provisions to protect whistleblowers from any anticipated harm resulting from their actions. Additionally, Section 17 grants whistleblowers the option to secure police protection if there is an apparent threat to them or their families. The Act explicitly states that, unless there is proof of false information or malicious intent, whistleblowers are not subject to criminal or civil trials for their disclosures. Ghana also has a Witness Protection Act 2018 that establishes a Witness Protection Agency to provide protection to “persons who possess important information and face potential risk or intimidation due to their cooperation with the law enforcement agencies with respect to investigation and prosecution.” However, there is no evidence that the law has been implemented effectively (2)(3) Section 19. Armed Forces Regulations Section 19.3 indicates that all officers are entitledto acarry out orders that are legal. Officers have the right to refuse to undertake any illegal order as may be assigned and upon carrying out any illegal order by an officer he or she will be responsible for the sanction of such illegality. This legal provision under the regulation therefore grants offivers the right to refuse wrongdoing (1).

Public institutions and Civil Society Organizations have implemented anti-corruption sensitization programs among Ghanaians, primarily targeting the youth. This effort is exemplified by anti-corruption engagement campaigns launched by the Office of the Special Prosecutor (OSP). For instance, on June 18th, the OSP engaged with students at St.Thomas Aquinas SHS, and on July 2nd, they met with student leaders at the University of Ghana. (1)(2). Although these campaigns aim to educate the youth about anti-corruption measures and their role in reducing corruption, they have not placed a strong emphasis on whistleblowing.

In July 2023, Parliament passed the Whistleblowers Amendment Act to enhance the Whistleblower Act, 2006 (Act 720) (1). This amendment expands the sources of funding for the Whistleblower Reward Fund, establishes a ceiling for the fund, and specifies the mode of rewards for whistleblowers. Despite these improvements, the Act has seen fairly low patronage due to a lack of awareness about its procedures and its role in fighting corruption (2). Additionally, there is a prevalent misconception that whistleblowers are disloyal, further discouraging potential whistleblowers from making disclosures and hindering the development of a robust whistleblower culture in Ghana, an issue that urgently needs to be addressed (2).

Kenya has a legal framework for witness protection, primarily established under the Witness Protection Act No. 16 of 2006. Section 13 of the Act allows witnesses to obtain new identities to safeguard their privacy, while Section 3B (10) provides a framework for granting special protection to individuals who possess critical information and face potential risks due to their cooperation with law enforcement agencies. The Witness Protection Agency, created under Article 50 of the Constitution, ensures fair hearings in courts and tribunals by implementing various protective measures. These include redacting identifying information from court documents, allowing testimony via video link with voice distortion, providing physical protection, changing identities, and relocating witnesses and their close associates. The Agency operates under seven key pillars known as C.I.I. H.A.O.U.: Covert Capability, Institutional Independence, Inter-Agency Collaboration, Human Rights Approach, Accountability, Operational Autonomy, and Unity of Purpose [1, 2]. However, eligibility for protection is limited. Section 3 of the Witness Protection Act defines a witness as anyone willing to formally testify for the State about the commission or possible commission of an offence, who has made a statement to a law enforcement agency, or who is required to give evidence before a court, commission, or tribunal outside of Kenya [2].
The existing legal framework does not explicitly cover whistleblowing. Apart from Section 21 of the Bribery Act 2016, which provides protections for whistleblowers in bribery cases, there is no comprehensive whistleblower protection law in Kenya. It remains unclear to what extent these provisions have been applied within military affairs. A whistleblower protection bill is currently under consideration in Parliament, which, if passed, will establish a clear legal framework for whistleblowing. Notably, the Witness Protection Act is designed to safeguard witnesses in criminal proceedings rather than whistleblowers, which leaves a gap in protection for individuals who expose wrongdoing outside of formal legal proceedings [3].

The Ministry of Defence currently has a Citizen Service Delivery Charter and a Service Charter. These charters set expectations for MoD deliverables and outline how citizens can raise concerns and complaints. While the MoD website provides a feedback mechanism for submitting concerns and other issues, it does not explicitly mention whistleblowing. Kenya lacks a comprehensive Whistleblower law, with the sole exception being a provision within the Bribery Act 2016, which only pertains to bribery [1]. The Bribery Act includes whistleblowing provisions for preventing, investigating, and punishing bribery. In 2021, the Attorney General and EACC published guidelines for Section 9, which requires public and private entities to establish anti-corruption procedures [2].

Kenya Defence Force officers must strictly adhere to legal constraints on information disclosure to protect national security and operational integrity. However, defence-related whistleblowing in Kenya often occurs through media channels, revealing tensions between institutional secrecy and public interest. This highlights the challenges for potential whistleblowers in balancing their duty to protect sensitive information with ethical obligations to report misconduct [1].
In 2021, Capital Media reported concerns raised by a whistleblower regarding the direct procurement of Turkish Armoured Personnel Carriers (APCs) in a Sh.7.7 billion deal. The whistleblower alleged that the procurement board relied on “a doctored report” to approve the single-sourcing of the APCs from Turkey. Safety concerns were also raised, noting that the vehicles had not met User Specifications Requirements (USR) set by the Kenya Army. Two other firms—one from South Africa and another from North America—were excluded from the multi-billion-shilling deal, despite offering more internationally accepted military vehicles. “If the vehicles are modified for the Kenya Defence Forces (KDF), Kenya will become the Turkish firm’s guinea pig, despite the safety risks involved for our soldiers,” the whistleblower told Capital News. In the article, Capital noted that The Ministry of Defence did not respond to the article [2].

Liberia has a formal legal framework for whistleblowing that applies across all public institutions, including the defence and security sectors. The Liberia Anti-Corruption Commission Act (Amended 2022) explicitly extends LACC’s mandate to investigate corruption in defence and security agencies.[1] The Whistleblower Act of 2022, a supplemental law of the LACC, is aimed at protecting persons employed in both public and private institution that disclose information or give evidence against a person allegedly involved in criminal malpractice.[2] The Act guarantees confidentiality, protection from retaliation, and legal remedies in cases of discrimination. While perceptions of whistleblowing within the military may discourage its use in practice, the legal framework clearly provides protections for defence personnel.
Therefore, the Whistleblower Act (2022) covers defence personnel, since it applies to all public institutions; provides protections for confidentiality and protection against retaliation; includes liability waivers for those acting in good faith. However, it does not clearly establish: reversed burden of proof regarding retaliation, explicit protections for “misguided reporting” (i.e., reports made in error but not malicious), explicit right to refuse participation in wrongdoing.

Though whistleblowing is written into and protected by the LACC legal regime, and expressed in the National Code of Conduct of 2015, all of which apply to defence institutions as public bodies.
The LACC conducts outreach and awareness on the whistleblower and witness-protection laws (including promotion of reporting tools), which defence personnel can also use as public officials. The LAAC Annual Report outlines receiving whistleblower information about allegations of corruption involving senior officials in some government offices in the General Services Agency.[2]
However, there is no evidence of a dedicated, well-resourced independent unit within the MoD solely for whistleblowing; cases appear to flow through the LACC/MoJ frameworks rather than through an internal MoD office.

There is a prevailing perception within the Liberian military that it operates according to an internal code distinct from civilian norms. This informal code discourages reporting misconduct by fellow soldiers, reinforcing a culture of silence in which disciplinary matters are expected to be handled internally rather than exposed externally.[1]
There is also a lack of trust between lower-ranking personnel and senior command officers. This mistrust undermines the effectiveness of whistleblowing mechanisms, as personnel often fear repercussions or penalisations for reporting wrongdoing. Despite the enactment of the Whistleblower Protection Act of 2022, there is not enough sense of protection in its implementation.[2][3]

No legislation protects whistleblowers in Madagascar. However, such a text is considered necessary to combat corruption, including among military and official personnel. In the Guide for the Prevention of Corruption in the Public Procurement Process, it is clearly mentioned that among the anti-corruption measures to be taken must include the protection of denouncers and whistleblowers [1]. Society Civil calls for the adoption of legislation protecting whistleblowers [2] especially after the conviction for “defamation” of some of them [3].

In the fight against corruption, military officials have clearly announced the anonymity of whistleblowers. The Internal Political Plan for the Fight against Corruption states that “military administration personnel are invited to report suspicions of corruption, under the conditions of confidentiality and security provided for by the framework of alert systems in place. These conditions provide in particular for the protection of users of the system”[1]. It adds that “Reporting mechanisms, adapted to the situations encountered, are also made available to the population, to all users of public services of the military administration, and to all its co-contractors to contribute to achieving the objectives of the fight against corruption” [2]. However, the same Plan specifies that “in the event of suspicion of cases of corruption, it is up to the senior officials concerned according to the military hierarchy, to react and plan actions to be taken in order to follow up on the case corresponding to such phenomena according to the internal organization of the Ministry and the rules of criminal and disciplinary procedures in force”. This assumes that the reporting process does not fully guarantee the anonymity of whistleblowers [3]. Internally, the General Inspectorate of the National Police is responsible for investigating cases of corruption by investigating both parties. At national defence level, accompanying measures exist to avoid reprisals [4].

As a rule, officials, including civilians and military personnel, of the Ministry of Defense do not trust the anonymity system when reporting acts of corruption [1][2]. Moreover, the press has never reported a denunciation within the Ministry of Defense concerning acts of corruption. For external whistleblowers, they can use toll-free numbers, but the identity of the whistleblower remains anonymous. External whistleblowers use freephone numbers, but their identity remains anonymous [3].

Despite the ratification of the 2003 United Nations Convention against Corruption on 18 April 2008[1] and the 2003 African Union Convention on Preventing and Combating Corruption on 17 December 2004[2], which require ratifying states to introduce protective legislation for people who reveal sensitive information or illegal acts, the country has no legal arsenal in this area. Indeed, there is no legislation applicable to military or official personnel aimed at facilitating the reporting of acts of corruption or protecting whistleblowers. Law no. 01-079 of 20 August 2001 on the Criminal Code contains no provisions to protect whistleblowers.[3] The Code does, however, devote a section to punishing the disclosure of secrets. However, a bill is said to be in the pipeline to protect whistleblowers in the fight against corruption. The political will to bring the process to fruition seems to be lacking.[4]5

Wihistleblowing is not encouraged by the government. There is very little (if any) guidance or support in this area, and there are no training courses or information campaigns. A unit may have been designated to deal with alerts, but at the moment it has not been set up.[1][2] The General Inspectorate of the Armed Forces and Services is responsible for receiving complaints and reports.

There is little confidence among civil servants and staff that they would be afforded appropriate protection if they reported acts of corruption.[1][2]

Law No. 15/2012 establishes mechanisms for the protection of the rights and interests of victims, whistleblowers, declarants or experts in criminal proceedings. The law creates the Central Office for the Protection of Victims and defines victims more broadly to encompass general officers, senior officers, junior officers, sergeants, enlisted men and reservists [1]. This law also establishes the principles of identity protection, protection against retaliation, reversed burden of proof in relation to retaliation, waiver of liability for the whistle-blower, no sanctions for erroneous complaints, and the right of the whistle-blower to refuse to report irregularities [2]. According to Article 22, Law No. 15/2012, of August 14, the Central Office for Victim Protection is required to, among other duties, implement and monitor special extra-procedural protection measures; coordinate with the judicial, police and prison authorities the compliance with the protection measures; operationalise the special security programs decreed under the terms of this Law; monitor and provide psychological support to the beneficiaries, whenever requested to do so by the competent judicial authority; and prepare quarterly reports on the degree of implementation of the extra-procedural protection measures and special security programs, to be submitted to the Minister of Justice and the competent judicial authorities [3].

Twelve years after the approval of this law, this office is still not fully operational due to lack of financial resources. The Deputy Director of the Central Office for Combating Corruption made this observation during the Seminar on Reflection on Effective Mechanisms for Protecting Whistle-blowers, a Fundamental Instrument for Combating Corruption, held in Maputo, on July 10, 2024 [3].

Whistleblowing is encouraged through training, information, and guidance on the reporting of corruption and protections for whistleblowers as well as via lectures and pamphlets posted in the Ministry of National Defence, Provincial Recruitment and Mobilization Centers – CPRM and military units. [1]. However, an officer of the Armed Forces of Defence of Mozambique – National Directorate of Defence revealed in a Maputo interview that internal campaigns to promote whistleblowing are sporadic and need to be more systematic [2].
The Central Office for the Protection of Victims is intended to be the independent body handling whistleblower claims in defence and other sectors. [2].
Twelve years after the approval of this law, this office is still not fully operational due to lack of financial resources, posited the Deputy Director of the Central Office for Combating Corruption during the Seminar on Reflection on Effective Mechanisms for Protecting Whistle-blowers, a Fundamental Instrument for Combating Corruption, held in Maputo, on July 10, 2024 [3]. In practice, it lacks the financial and human (staffing) resources and operational capacity to fully carry out its mandate.

Despite the establishment of the Central Office for the Protection of Victims, Whistleblowers, Witnesses, Declarants, or Experts in Criminal Proceedings, officials and personnel interviewed expressed doubts about whether whistleblowers are adequately protected [1]. The Whistleblower Protection Act [2] contains vague or unclear language, as it lacks its own regulations, which raises concerns about the process and its effectiveness [1]. This uncertainty underscores the need to fully operationalise the Central Victim Protection Office [3], which, despite being approved 12 years ago, remains non-functional due to financial constraints [4].

Niger has some legal provisions that indirectly support whistleblowing, but these laws lack explicit protections for whistleblowers, particularly in the defence sector. The 1992 Law on Illicit Enrichment includes a provision in Article 8, which grants immunity from prosecution to individuals who report illicit enrichment before the offense is committed [1]. However, the law does not explicitly refer to these individuals as “whistleblowers” (lanceurs d’alerte), and its vague language does not offer strong protections. The law also does not provide safeguards against retaliation, meaning that potential whistleblowers may fear repercussions despite the immunity clause. Additionally, Article 132 of the 2003 Public Penal Code [2] stipulates that anyone who facilitates or accepts corruption is punished in the same way as those who solicit bribes. This creates a legal risk for individuals who might otherwise come forward, as they may themselves be subject to prosecution [3]. The Code of Military Justice is even more ambiguous [4]. Article 48 states that military personnel can take measures to detect offenses committed within military establishments, but it does not establish protections for those who report corruption. Given that there is no explicit legal framework defining and protecting whistleblowers, particularly in the military and defence sectors, the existing laws are weak and do not guarantee protection from retaliation.

Whistleblowing is not actively encouraged by the Nigerien government, particularly within the military and defence institutions. Despite the country’s commitment to regional and international anti-corruption frameworks, such as the African Union Convention on Preventing and Combating Corruption (2005) and the United Nations Convention Against Corruption (2008), no independent, well-resourced mechanism exists to handle whistleblowing claims within the defense sector [1] Although the Haute Autorité de Lutte contre la Corruption et les Infractions Assimilées (HALCIA) was established by Decree No. 2011-219 and reinforced by Law No. 2016-44, its effectiveness in whistleblower protection remained limited [2]. Article 27 of the law references protections for witnesses and informants, but it does not provide a comprehensive framework for encouraging or safeguarding whistleblowers in defence and security institutions. In 2011, the government established a so-called Green Number, 08001111, which any citizen could call to report acts of corruption. However, the law was not supposed to protect those who would use this number to report corruption. The Minister of Justice under whom the number was first introduced clearly stated: “All substantiated reports—those that are well-founded and justified—will lead to prosecution before the competent courts, let there be no doubt about that. But at the same time, for those who are guilty of false accusations or slanderous denunciations, the penal code also provides sanctions against them.” [5]. Since the military coup of July 2023, the Green Number has not been operational. Following the military coup of July 2023, HALCIA was dissolved and replaced by the Economic, Financial, and Tax Crime Fighting Commission (CoLDEFF) in September 2023 [3]. While CoLDEFF’s official mandate is to investigate economic and financial crimes, concerns have emerged regarding its independence and alignment with military leadership. Instead of focusing on judicial enforcement, CoLDEFF appears to prioritize financial recoveries, leading critics to view it as a tool for asset seizures and political intimidation rather than genuine anti-corruption reform [4]. Moreover, there is no structured process for reporting corruption within the defence sector, and no dedicated whistleblowing unit exists. The government does not conduct training or awareness campaigns to encourage reporting, and no internal or external mechanisms provide adequate protections against retaliation.

The criminalizsation of whistleblowers remains a significant concern in Niger, further exacerbated by the repressive legal framework and government crackdowns on dissent. The 2019 Cybercrime Law (Law No. 2019-33) has been systematically used to target individuals who expose corruption, leading to arbitrary arrests, legal harassment, and defamation charges against whistleblowers, journalists, and activists, particularly when they report on high-level corruption [1]. The “Uranium Gate” scandal of 2017 is a clear example, where those who denounced the corruption were prosecuted and intimidated, while the individuals implicated in the fraudulent deals remained largely unaccountable [2][3]. Similarly, Hamsatou Diallo’s arrest on May 20, 2019, for private comments in a family WhatsApp group about Niger’s deteriorating security situation, highlights the criminalization of free speech. Despite the private nature of her remarks, she was charged with undermining national defence morale, demonstrating how state authorities weaponize vague laws to suppress dissent and whistleblowing[3]. The July 26, 2023 military coup has further intensified the climate of fear, making whistleblowing even riskier. With military authorities consolidating power, arbitrary detentions have increased, and the press has been heavily censored. Journalists and activists critical of the regime face intimidation, arrests, and shutdowns of independent media outlets. A recent case illustrates this pattern of repression is the arrest of Moussa Tchangari, a human rights defender and secretary-general of the civil society organization Citizens’ Alternative Spaces. On December 3, 2024, he was arrested at his home in Niamey by three armed men in plain clothes who claimed to be police officers. His whereabouts remained unknown for nearly two days, raising serious concerns over enforced disappearance and incommunicado detention. He was later found at the Central Service for Combating Terrorism and Organized Transnational Crime in Niamey, where he was charged with advocating terrorism and criminal association in connection with terrorism. His arrest underscores how anti-terrorism laws are being misused to silence critics and human rights defenders rather than to combat genuine security threats [4]. The dissolution of key accountability institutions, such as the Haute Autorité de Lutte contre la Corruption et les Infractions Assimilées (HALCIA), and the creation of the Economic, Financial, and Tax Crime Fighting Commission (CoLDEFF) have raised concerns about the selective application of anti-corruption measures—used as a tool of repression rather than genuine governance reform [5]. The current political and security environment discourages whistleblowing, as state mechanisms serve to punish rather than protect those who expose misconduct.

The Federal Executive Council in 2016 approved a whistleblowing policy initially developed by the Federal Ministry of Finance [1]. The policy was meant to facilitate exposure of acts of fraud, bribery, looted government funds and assets, financial misconduct and other forms of corruption. The Policy stipulates that whistleblowers who disclose information that assist the government to recover plundered or misappropriated funds, will be eligible to receive between 2.5 and 5 percent [2]. However, the policy makes no mention of military personnel and its compatibility with military law is unclear. Regrettably, the policy is yet to be made a law after approving a draft bill in 2022 [3]. An investigation published by PREMIUM TIMES showed that many whistleblowers suffer from exposing wrongdoings in government agencies [4].

Despite the fact that the Federal Executive has an approved whistleblowing policy meant to facilitate exposure of acts of fraud, bribery, financial misconduct and other forms of corruptions, there has been little or no attempt to encourage whistleblowing through training and guidance on the reporting of corruption and protections for whistleblowers within the defence ministry [1]. There have been several public disclosures by soldiers via the social media on matters of misbehaviour of superior officers such as non-payment of salaries or allowances [2]. More importantly, the fact that the whistleblowing policy is not law may have prevented some officers from acting in courageous ways that could further the objective of the policy [3].

Although a Whistleblowing policy has been approved aiming at facilitating exposure of acts of fraud, bribery, or financial misconduct, the effectiveness of the policy is still plagued with increasing disinterest and distrust among the public to volunteer information due to lack of protection. More importantly, CSOs have called for a review of the draft whistleblower protection bill before its passage, noting that the bill only made provisions for financial frauds in the public sector, and also ignored the fact that whistleblowing as an anti-corruption and accountability tool could be deployed in other sectors, especially the security sector [1]. This is crucial given that one of Nigeria’s former National Security Adviser (NSA) once revealed intention to deploy whistleblowing to tackle the issues of illegal arms deal and circulation [2]. Whistleblowers face the fate of being haunted by those implicated in any reported case, as well as face unbearable marginalisation without the government providing support for protection [3]. A study has shown that although majority of Nigerians are aware of the whistleblowing policy, one quarter of the respondents are unwilling to report any form of corrupt practices while 3 of every 4 respondents have stopped reporting cases of looted funds due to nepotism and fear of victimization, among other factors [4]. It is interesting to note that, whether in the private or public sector, recent reports seem to reveal declining interest in the policy. The military has repeatedly emphasised compliance to the Oath of Secrecy Act of 1962 in ways that have tended to deliberately or inadvertently dissuade serving military personnel or civilians from disclosing information regarding the defence sector by even though it borders on corruption [5].

There is no legislation specifically applicable to military and official personnel to facilitate the reporting of corruption or the protection of whistleblowers, although whistleblowing systems are often used to facilitate the detection of corruption through freephone numbers. [1] . In his speech to the nation on 3 April 2024, new President Bassirou Diomaye Faye promised to step up the fight against corruption in Senegal and promote more transparent governance through a law to protect whistleblowers. [2] The law for the benefit of whistleblowers is struggling to materialise, despite its adoption on 15 May 2024 by the Council of Ministers and the Senegalese Ministry of Justice has taken into account the recommendations of the CSO Pplaaf alerte for a better law on the protection of whistleblowers, this law include military acts.

OFNAC has set up a Complaints and Denunciations Office (BPD) under the direct authority of the President. The BPD’s main mission is to receive, record, prepare and transmit complaints and denunciations to the President of OFNAC. The identities of the persons making these denunciations are highly protected for security reasons. [1] . In Senegal, one of the promises made by President Bassirou Diomaye Faye the day after his election was to protect whistleblowers involved in the fight for transparency. He instructed the Minister of Justice to propose a bill to the National Assembly. However, the law has not yet been passed, the project has not been implemented and no resources have been made available. [2]

The law for the benefit of whistleblowers is struggling to be materialised, despite its adoption on 15 May 2024 by the Council of Ministers and the Senegalese Ministry of Justice that took into account the recommendations of the CSO Pplaaf alerte for a better law on the protection of whistleblowers. [1] By adopting such a law, Senegal would be the first country in French-speaking Africa to legislate on the protection of whistleblowers. Its content has still not been disclosed. [2] The Senegalese maintain that the media should constantly investigate and publish corruption and government errors, but believe that citizens risk reprisals or other negative consequences if they denounce acts of corruption. They disapprove of their government’s efforts to combat corruption within the public administration. [3] Officials and staff have a certain lack of confidence that they will be adequately protected if they decide to expose corruption. In the army, blowing the whistle on your superiors, even if they protect your identity, is not a matter of course, and there may be consequences for the whistleblower. [4] .

Whistleblowing is protected by a range of legislation including the Labour Relations Act, the Companies Act and most importantly the Protected Disclosures Act [1]. These include provisions for protection from retribution, but only in relation to occupational detriment and does not prevent civil or criminal proceedings against whistleblowers. Legislation does not provide for anonymous disclosures, and the burden of proof is placed on the whistleblower to prove that the disclosure was made in compliance with the Protected Disclosures Act and that they suffered occupational detriment [2].

The Department of Defence’s website provides sign-posting to the National Anti-Corruption Hotline [1]. As part of managing enterprise risk, the Department of Defence engages in corruption and fraud awareness activities with the intent of encouraging whistleblowing. The Department conducted 69 such events in the 2022/2023 financial year and tracks whistleblower complaints submitted through the departmental hotline, directing cases for investigation [2]. There is no dedicated unit to tracking whistleblowing across government.

Trust in the whistleblowing system is limited across government with clear issues of retribution, a lack of consequences against wrong-doers, and in some cases, violence against whistleblowers. [1] The number of whistleblower complaints to the Department of Defence has more than halved in the last five years despite ongoing challenges in controlling corruption, likely illustrating the declining trust in the whistleblowing system. [2] [3]

South Sudan has not adopted whistleblower protection legislation [1].

South Sudan has not adopted whistleblower protection legislation. [1] Lack of such protection means that those who may have the desire to report corruption are discouraged due to lack of legal protection mechanisms.

South Sudan does not encourage whistleblowing, and no specific protections exist for those who report corruption within military or defence institutions [1]. Individuals who have exposed corruption in the army have faced harassment by security operatives, and the government has taken no action to shield them; whistleblower protection laws or mechanisms are completely absent. In practice, whistleblowers often endure retaliation—harassment, forced exile, or worse—with no legal recourse or institutional safeguarding [2].

The Whistleblower Protection Act of 2010 protects whistleblowers who report corrupt officials and their deals. Legislation on whistleblowing and reporting corruption exists and is applicable to military and official personnel. The law provides for the procedures by which individuals in both the private and public sector may in the public interest disclose information that relates to corruption. The act provides for protection from victimisation, protection against court action, state protection, application to court for assistance, and void employment contracts [1].
Section 12 states that the identity of a whistleblower should be kept confidential unless disclosure is necessary for an investigation or legal proceedings. Section 9 prohibits detrimental action against a whistleblower, including victimization, dismissal, or discrimination. Section 8(2) provides protection from civil or criminal liability for whistleblowers acting in good faith. However, the Act does not explicitly state that the burden of proof in retaliation cases lies with the accused. It only provides general protection against retaliation. The Act does not explicitly grant whistleblowers the right to refuse participation in wrongdoing, though general protections exist against retaliation for reporting.

The Inspectorate of Government has power to investigate or cause investigation, arrest or cause arrest, prosecute or cause prosecution, make orders and give directions during investigations [1]. The IGG provides official guidance and channels for reporting corruption, including in the Ministry of Defence and security agencies [2].
There is a reward for whistleblowers, which can be interpreted as encouraging whistleblowing (See: Section 19 of The Whistleblowers Protection Act, 2010) [3]. The act also provides for protection of whistleblowers from victimisation, court action. (See: Sections 9-10. Critique of explanation) [3].
While the office of the IGG exists to facilitate whistleblowing, its independence and effectiveness are frequently questioned.[4] [5]. The military and defence sector operate with a high degree of impunity and secrecy, which limits the IGG’s jurisdiction over the UPDF in practice. Internal military justice systems, which report up the chain of command to the CDF (Chief of Defence) and the President, are not considered independent for handling sensitive corruption allegations.
In the defence sector, the culture of hierarchy and obedience, combined with broad laws like the Official Secrets Act (See: Section 2(1) (c ); 2(2); 2(3); 2(4); 2(5); Section 4; Section 7 and 9), creates a powerful deterrent against whistleblowing.[6] Military personnel who blow the whistle could be prosecuted for compromising national security or insubordination. There are therefore no known specific independent channels for military personnel to report corruption safely. Fear of professional and personal reprisal could be a deterrent in the army.

A significant obstacle to effectively combating corruption within the Uganda People’s Defence Forces (UPDF) is the prevailing lack of trust among officials and personnel that they would receive adequate protection if they reported corrupt activity. This apprehension stems from a combination of factors, including fear of retaliation, concerns about the efficacy of internal reporting mechanisms, and a perceived culture of impunity, particularly among senior officials [4] [6]. For example, junior officers may be hesitant to report instances of corruption involving their superiors, fearing reprisal in the form of demotions, unfavourable postings, or even physical threats. The absence of a robust and confidential whistleblower protection system further exacerbates this fear, leaving potential reporters feeling vulnerable and exposed [5].
Moreover, the perception that senior officials are often shielded from accountability reinforces the belief that reporting corruption is a futile and potentially dangerous endeavour. Instances where investigations into high-ranking officers are perceived as being delayed, watered down, or ultimately dismissed contribute to this erosion of trust [2]. For example, the fictitious Russian pilot, Valerie Detrick, was on the payroll of the army for over 11 years, resulting in substantial financial misappropriation [3]. While the UPDF has legal frameworks in place, such as the Inspectorate of Defence Forces, the practical implementation of these frameworks, particularly in ensuring the protection of whistleblowers, remains a critical challenge. Without demonstrable evidence that those who report corruption will be protected and that corrupt officials will be held accountable regardless of rank, the culture of silence will persist, hindering efforts to eradicate corruption within the UPDF. Activists have revealed that his organisation had lost a number of community monitors who abandoned the fight against corruption for fear of being killed, after being intimidated [5].

Whistleblower Protection bill was passed by parliament March 2022 but is yet to be signed into law [1]. Currently, there is no law which covers and protects the whistle blowers in Zimbabwe. Even the Criminal Procedure and Evidence Act does not articulate the protection of whistleblowers [2].

The civil society host workshops on sensitising the public on whistleblowing to report cases of corruption in the country [1]. The anti-corruption commission has also been involved in creating awareness on whistleblowing [1]. The Whistleblower bill was passed by parliament and now only waiting for it to be signed into law [2]. In the military, whistleblowers are not afforded any protection, neither are they encouraged as the Defence Act does not provide for the protection of whistleblowers [2].

There are no provisions for whistleblowers in the defence forces [1]. While there is no whistleblowing in the defence forces, civilians are likely to whistleblowing on cases of corruption, but they fear to be victimised, and they are not protected by the government [2].