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| Address to Fiji Institute of Accountants “The Whistle-Blower’s Dilemma – Loyalty or Disclosure” Thank you very much for inviting me to attend the annual congress of the Fiji Institute of Accountants. I am very sorry that I shall be unable to be present in person to address you. I had thought that when I left my law firm in February this year to commence practice as a barrister sole that life would be less hectic and that I would have more time for quiet reflection and research. That’s how life at the independent bar has always been represented to me by my friends and colleagues who have left the pressures of the law firm to practise on their own account. It has proved not to be the case. Let me explain why I am trapped in Wellington. In 1992 the Crown settled historical fisheries disputes with Maori and enacted legislation to give effect to the settlement. That legislation, poorly drafted and rushed through the House of Representatives toward the end of 1992, far from resolving litigation, has spawned new litigation as various iwi throughout New Zealand have sought clarification on whether the allocation of the settlement benefits should be according to population or coastline. Various aspects of the case have gone to the Privy Council on two occasions. The Fisheries Commission, which has been charged with responsibility for devising a scheme of allocation, a few weeks ago announced it would report to the Minister on or about 9 May. Everything seemed to be going according to plan until a few days ago when certain groups announced that they would be challenging the right of the Commission to report to the Minister. That means that litigation could commence at any time within the next day or so and, in those circumstances, I am unable to leave New Zealand because it is at least possible I shall be in court on Friday or Saturday. I sincerely regret that I shall be unable, therefore, to give this address in person but I am comforted by the fact that my colleague, Shane Anderton, is able to step in and give the address on my behalf. Shane worked with me in my former law firm, Bell Gully, for a number of years and came with me to the Privy Council earlier this year. He is working for me for a month or so prior to his leaving for London to commence studies for an LLM at Cambridge University. He has also been helping me with this address and is very conversant with the issues which arise in this session. I hope I shall have an opportunity to attend your congress on another occasion. Introduction History is replete with examples of whistle-blowers, some good, some bad. The bad ones are the most interesting and perhaps the most easily identified. Perhaps the most well known whistle-blower was Judas Iscariot who blew the whistle on Christ for 30 pieces of silver and ended up hanging himself in a field. Another real shocker from the last century was a young Russian called Kolya who, one night at dinner, heard his parents criticise Joseph Stalin, then the ruler of Russia. He blew the whistle on his parents to the authorities who promptly sent Mum and Dad to a labour camp in Siberia. Kolya was awarded the Order of Lenin or some such other award. He was then presented by the State to the children of Soviet Russia as the very ideal of a person who had pure devotion to the State, even if at the expense of his parents. The issue of whistle-blowing has also become a major legal and ethical issue in many jurisdictions in recent years. Some of you may recall the movie “The Insider”, the story of US big tobacco company whistle-blower, Jeffrey Wigand. That film was the subject of a number of Oscar nominations. Earlier this year, Time Magazine had a major article on whistle-blowing and praised the steps taken by employees of companies such as Enron to blow the whistle on irregular and illegal practices within their companies. For many years it was well established that employees owed duties of loyalty to their employer, be that employer the Crown or a private corporation or partnership. Where employees left employment and then started to speak out about matters, redress was swift and effective. With major corporate collapses and allegations of abuse of power within Government, however, the situation has changed and a person who blows the whistle may in some circumstances no longer be regarded as a villain against whom an employer should have redress in a court of law but rather as a hero who exposes abuse or fraud. Speaking out about corruption or financial mismanagement within a Government or a large corporation can indeed be a difficult legal and ethical issue. Nor does it necessarily follow that the good guys always win. Most of the high profile examples have occurred in the United States but there are examples closer to Fiji. An example is the highly principled stand taken by the former Auditor General of Samoa, Su’a Rimoni Ah Chongto expose financial mismanagement in the Samoan Government. Mr Ah Chong paid a heavy price for his courage. In 1995 he was ordered by the then Prime Minister not to publish his annual report to Parliament if it contained concerns about the actions of the Samoan Ministry of Public Works. Mr Ah Chong told the Prime Minister he had a constitutional obligation to report to Parliament on those matters and when he did, he was promptly suspended. Mr Ah Chong commenced proceedings against the Samoan Government seeking declaratory relief. However the Samoan Government later altered the constitution of Samoa and had him removed. Attempts to progress his case through the courts of Samoa have proved to be unbelievably difficult. Almost five years ago I appeared for Mr Ah Chong in the Supreme Court of Samoa to argue an aspect of his case and I still have not received a judgment from the Chief Justice. To wait five years for a judgment is extraordinary and, given the passage of time, I am sure you will understand when I say I am not holding my breath for the early release of the judgment. Many of you may know Mr Ah Chong and thus will be delighted to learn that he has been short-listed by Transparency International for the Transparency International integrity award for 2003. These awards seek to underline the work of individuals and organisations that have shown great bravery and integrity in combating corruption, and the nominees are judged by a selection committee composed of representatives of TI National Chapters. This is what the press release said about Mr Ah Chong: "Su’a Rimoni Ah Chong, former Auditor General of Samoa, showed great determination to expose financial crime in the South Pacific region and has been an inspiration in the battle to promote Government and private sector accountability.” Other candidates are from Greece, India, Poland and Nigeria. A final announcement will be made on 16 May 2003 and the award ceremony will take place in Seoul, Korea on 25 May 2003. In this address, I will consider the following: - With particular reference to New Zealand, show how the clamour for such legislation developed in a New Zealand context; - Examine the statutory framework in New Zealand and codes of practice developed by Government departments; and - Briefly look at other developments in the United States of America where there has been a move toward what could be called compulsory whistle-blowing affecting the legal profession. New Zealand For many years, New Zealand has been affected by the international climate of the emerging information age and a development of a culture of openness to information. There has been a never-ending increase in the level of interest by the public into the daily running of Government and governmental organisations and an increase in demand for Government to be more accountable to the people. This trend has been apparent in New Zealand even though New Zealand is internationally regarded as being a country which is generally free of corruption and has high standards of public administration. This change in the way in which people regard the Government can be seen in a New Zealand context in public law developments of the last 40 years: The introduction of the Ombudsman in 1962 and the growth of that office over the years. The first ombudsman in New Zealand was a former lawyer and diplomat, Sir Guy Powles; today there are no fewer than five ombudsmen with responsibilities not only for central but also local Government. - In 1972 the Judicature Amendment Act was passed. This legislation greatly simplified the process of judicial review which is the means by which individuals and corporations may challenge divisions of Government and public bodies. In the years following the enactment of this legislation, judicial review of administrative action has become a very important tool in ensuring that governments are accountable for their actions and that they act reasonably and fairly. - In 1982, the Official Information Act came into force. Rather than emphasising the need for secrecy with governmental information, the focus was rather on availability of information unless particular circumstances (such as national security) could be demonstrated. - In recent years also, particular commissioners have been created to deal with perceived needs in the community. So, for example, we now have the Commissioner for Children, the Health and Disability Commissioner and the Commissioner for Retirement. Importantly also in this context, a Human Rights Act has been introduced, and its scope steadily expanded, and we also have a human rights commission with several human rights commissioners. For many years New Zealand was relatively slow in developing legislation directly dealing with “whistle-blowing” but in 1994 the now well known Neil Pugmire case hit the media. This was an important landmark in the development of a statutory regime for whistle-blowing in New Zealand. The case concerned a charge nurse, Neil Pugmire, who worked at Lake Alice Hospital which is a national psychiatric security hospital in the North Island. The case concerned the release of a patient back into the community. Unfortunately that patient, who had a history of violent offending, had apparently raped two young boys. Mr Pugmire was appalled at the imminent release of the patient and approached his employer, ironically called, Good Health Wanganui. His employer failed to respond to his urgent entreaties and accordingly he approached the Minister of Health and the Minister of Police. No action was taken by those ministers. When the patient re-offended, the opposition spokesman for Justice called for a public inquiry. Mr Pugmire then sent the opposition a copy of the letter he had written and the opposition then released that letter to the news media. [1] As a result of these events, Mr Pugmire was dismissed because of a breach of patient confidentiality. He was, however, subsequently reinstated after a massive display of support from the unions, the public and certain politicians followed by a case in the Employment Court which held that Good Health Wanganui had not treated Mr Pugmire fairly or in terms of natural justice. In due course an investigation was held and it was decided that Mr Pugmire should either be dismissed for serious misconduct or offered a job of lesser status, responsibility and pay. Mr Pugmire again brought an application for injunction to restore him to his usual duties and the court granted that injunction. The Employment Court judge hearing the case commented that: “The concentrated attention of the media in its various forms, and the public discussion which it has fostered, for which Mr Pugmire was in no way personally responsible, is something which this court has to and does disregard entirely. Bearing in mind that Mr Pugmire’s sincerity, integrity, skill as a charge nurse and genuineness of the motives behind his actions of not being questioned, I find and hold that the interests of justice and fairness demand that Mr Pugmire be restored to his previous position… the offer of alternative inferior employment contemporaneously with notification of an inflexible decision to dismiss is to me a reprehensible abuse of the concept of fair dealing by an employer. The defendants shotgun approach made its action even worse.” [2] So Mr Pugmire was returned to his normal duties until a full hearing had taken place and the matter was later settled out of court. The Pugmire case is very interesting in a number of respects. It shows that as an employee Mr Pugmire owed a duty to act in his employer’s best interests. However in Mr Pugmire’s opinion, this duty was outweighed by the public’s interest in preventing potential serious threats to public safety. He believed that by releasing the patient, Good Health Wanganui was creating a serious threat to public safety. He informed an opposition MP of the patient’s intended release. This is a very good example of whistle-blowing. Mr Goff commented that Good Health Wanganui had its own agenda, namely that by severely disciplining Mr Pugmire, they would deter and warn off other staff from making further disclosures. Although, as the history demonstrates, it failed in relation to Mr Pugmire, a question which arose was whether or not it succeeded in its general objective. [3] As a response to the whole Pugmire incident, Mr Goff introduced the Whistle-blowers’ Protection Bill to the House of Representatives on 15 June 1994. Mr Goff claimed this legislation was: “giving to those people who in good faith speak the truth and disclose risks or wrong-doings to the public, an opportunity to do so without the retribution, harassment and victimisation which has always followed when whistle-blowers have done their duty for the good of their country.” [4] The legislation was never passed because at that time Labour was in opposition. However in 1995 a ministerial review team was established to look at the whole issue of whistle-blowing. They recommended that public sector organisations needed to have mechanisms in place to facilitate whistle-blowing. The team said that the private sector didn’t need to have them but that private sector employees should have the same protections. Furthermore, they also said: - Formal institution of a public interest disclosure process would be a natural step in the increasing maturity of the public sector and one which reinforces and underpins existing statutory and ethical obligations; - Because of the blurring of lines between the private and the public sector, private sector employees would need to be included otherwise the public could be left at risk; and - The team recommended a uniformly applied and effective scheme but not a separate agency to deal with public interest disclosures. As I have said, Mr Goff’s bill languished mainly because of a lack of political commitment on the part of the Government. However, incidents showing a need for such legislation kept occurring throughout the 1990’s in the period leading up to the 1999 General Election. For example: - The now almost defunct Royal New Zealand Airforce had a base at Ohakea situated near Palmerston North in the Lower North Island. The airforce base commander decided to renovate his house. While the cost of those renovations didn’t exactly equate to the cost of purchasing F16’s, they certainly were rather expensive. The inevitable leaks occurred and the airforce base commander lost his job. - Then there was the former head of the Accident Compensation Corporation (the Government body charged with compensating people who suffer personal injuries by accident). He evidently used Corporation funds to purchase a plane because he had an interest in flying. - To continue the aviation theme, I should also mention the Ministry of Social Welfare, popularly called WINZ (Work & Income New Zealand). It was decided to take all the hardworking members of WINZ on a joy-ride to a resort on Wairakei, in the central North Island, where they would learn all about team-work (and hopefully also how to be frugal and conserve scarce Government resources). The exercise was a public relations disaster for WINZ when, surprise surprise, the inevitable leaks occurred. - Finally, there were the Inland Revenue Department staff members who developed a habit of selling information to debt collectors and again this all became public. [5] The political environment toward the end of the 1990’s was thus conducive to the introduction of legislation dealing with whistle-blowing. Since the Pugmire case, and the other incidents I have referred to above, the concept of “whistle-blowing” has received a great deal of public attention and Parliament passed the Protected Disclosures Act 2000 which came into force on 1 January 2001. That Act provides a statutory framework for employees and employers to follow when an issue of serious wrong-doing arises within the workplace. As stated in the long title of the legislation, the purpose of the Act is to promote the public interest: - “by facilitating the disclosure and investigation of matters of serious wrong-doing in or by an organisation; and - by protecting employees who, in accordance with this act, make disclosures of information about serious wrong-doing in or by an organisation.” It is important to note that the Act applies both to the private sector and to the public sector. There are three key areas in the Act: - The protection of the disclosure of public interest information; - The requirement that public sector organisations adopt internal procedures for dealing with disclosures (more about that shortly); and - Provides protections for employees who disclose information about serious wrong-doing, including immunity from civil and criminal proceedings. [6] When the legislation was going through the House, the opposition parties were very concerned about the unnecessary costs which could be placed on the private sector. One MP also commented that by including the private sector, “tittle-tattlers” [7] could be encouraged to cause trouble. For example, a disgruntled employee could do irrevocable damage to a business by protected whistle-blowing. Under the legislation, an employee may disclose information if: - The information is about serious wrong-doing in or by that organisation; - The employee believes on reasonable grounds that the information is true or likely to be true; - The employee wishes to disclose the information so that the serious wrong-doing can be investigated; and - The employee wishes the disclosure to be protected. Note that these requirements are conjunctive. In other words, all criteria must be satisfied to be covered by the Act. The employee does not have to be certain but he or she has to have a reasonable belief that can be tested. Presumably that would prevent malicious disclosures being made. What is an organisation? It is defined very widely in the Act as meaning a body of persons, whether corporate or unincorporate, in the public or private sector, and includes a body of persons comprising one employer and one or more employees. A serious wrong-doing is defined as: - An unlawful, corrupt or irregular use of public funds or resources; - An act, omission, or course of conduct that constitutes a serious risk to health or public safety or the environment; - An act, omission, or course of conduct that constitutes a serious risk to the maintenance of law, including the prevention, investigation and detection of offences in the right to a fair trial; - An act, omission or course of conduct that constitutes an offence; or - An act, omission or course of conduct by a public official that is improperly discriminatory, or grossly negligent, or constitutes gross mismanagement. Out of all these various categories of serious wrong-doing, it would seem that the misuse of public funds appears to be one of the Act’s primary objectives. [8] As mentioned above, the inclusion of private sector organisations such as private companies caused a great deal of controversy. It has been suggested that private sector disclosures will most probably be limited to issues relating to health and safety, the environment and criminal matters. In addition, there have been concerns about increased compliance costs for small business because they will have to follow the procedures of the Act. Such a complaint has some merit as small businesses in New Zealand seem to be increasingly afflicted by compliance costs of one sort or another. I have already referred to the fact that another concern is that private sector employers may face frivolous and baseless claims made by their employees and that even if such claims are eventually determined to be false, the employer could potentially suffer damage to their reputation during the interim investigation procedure. [9] While it is not mandatory for private organisations to establish internal procedures, it has been suggested that any procedural code should include the following: [10] - Confidentiality for the whistle-blower; - Protection from reprisals; - Identifying the person within the organisation to whom the whistle-blower should report; - The likely consequences of a successful investigation; - How each report is to be dealt with; and - Consequences for dishonest or bad faith enclosures. It is all very well to suggest such procedures; however a real problem with the legislation is that there is no real protection for employers faced with bad faith employees. For example, the Act does not provide for recovery of damages as a result of such disclosure. The employer would presumably try to have to recover those losses at common law and that may be no easy matter. As I have noted, governmental organisations must develop sets of internal procedures. In the course of preparing this address, I have looked at the guidelines of the New Zealand State Services Commission, the Treasury and the Inland Revenue Department. They all provide very clear guidelines for employees to follow in the event that he or she decides to make a protected disclosure. What happens if the internal procedures fail or there is not an internal procedure in place? In such a situation, there is provision for making disclosures to an “appropriate authority”. Such a person/authority includes the Commissioner of Police, the Auditor General, the Director of the Serious Fraud Office, the Inspector General of Intelligence and Security, an Ombudsman or the State Services Commissioner. An employee can approach a minister if no appropriate action is taken internally or by an authority. Note, however, that MP’s are specifically excluded. One of the ironies of this legislation is that Mr Pugmire, who made his disclosures to an opposition MP, would not be protected by the legislation. Such an exclusion is probably wise; as is well known, politicians generally tend to have five minute horizons and act in their own interests. Permitting disclosures to MP’s would probably be an invitation for ongoing trouble. Interestingly, disclosures to the media are not mentioned. This has drawn attention from the news media who point to their self-proclaimed watchdog role in a free society. They query whether the use of internal procedures may in fact lead to suppression of information in the public interests [11]. Far from promoting freedom of speech, there are those who have suggested the legislation restricts freedom of speech because it stops people going to the media as they have to go through internal channels. As one politician said: “There are many times when public servants have leaked information to the news media and its been right and proper that the information be provided.” [12] What happens where an employee makes a protected disclosure under the Act? There are various protections which include: - The ability to take a personal grievance action if the employee is dismissed because of the disclosure; - Immunity from civil and criminal proceedings; - Confidentiality on the part of the person to whom the information is disclosed; and - Protection under Human Rights Act victimisation procedures. Confidentiality looks to be guaranteed but a closer reading suggests that there are serious limitations. For example the identity of the whistle-blower would be revealed if it would help the investigation and in the majority of employment investigations, the complainant’s identity will simply have to be released. [13] How is the legislation going? Probably too soon to say. It seems to be an open question whether this is the most efficient method to deal with serious wrong-doing in public or private organisations. For myself, I think there has to be a real concern that the legislation could be used maliciously. I have already said that the protections conferred do not apply if the whistle-blower makes an allegation which he or she knows to be false or otherwise acts in bad faith. However this will not prevent damage to an organisation’s reputation until the disclosure is proved to be malicious or baseless. And note where the onus of proof lies. There are real concerns in New Zealand about ever-increasing compliance costs in the private sector, particularly on small businesses, and while it is all very well to say that baseless allegations could be investigated, there is a real risk that the company may have gone under before proper investigations can be made. And even if the investigation shows that the allegations were baseless, it may be impossible to recover damages. My particular concern is with the zealot or misguided whistle-blower and conspiracy theorists (there are a lot in New Zealand at the moment) who claim their complaints are not being taken seriously because the authorities themselves are corrupt. There is a real danger that this is a licence for monomaniacs to go overboard. Another element of unreality creeps in when one considers the position of ministers of the Crown. What if a minister decides not to investigate? There is nothing anyone can do. What if an appropriate person in the private sector organisation decides not to investigate? Is it appropriate or constitutional for public sector offices to receive and investigate disclosures in the private sector? Shades of big brother, or in the contemporary New Zealand context, big sister. There are real problems with the New Zealand legislation; however the Act requires a compulsory review to be presented to Parliament, in consultation with the Chief Ombudsman, by January 2004. The review will consider whether the law is working adequately and whether organisations are complying. The review will also recommend necessary amendments. The title of the speech focuses on the dilemma of the whistle-blower; is loyalty to prevail or is the greater good served by disclosure? One wonders whether the legislation adequately addresses that important question. The real concern for most employees these days is their own wellbeing and job security. One commentator perhaps talked about the need for whistle-blowers seeking convincing evidence that corrective action would be taken before they would consider blowing the whistle. She argues that the New Zealand legislation fails to connect with this theory as it does not accurately map the decision making processes of employees considering whistle-blowing. She says the Act needs to motivate employees to come forward. [14] United States I now wish briefly to address a potentially troubling development in the United States where compulsory whistle-blowing has become an issue post-Enron. This has important consequences for lawyers, not accountants, but is nonetheless of great significance as it highlights where the law may go. As is well known, the confidences expressed by clients to their attorneys will be subject to solicitor-client privilege (or, as it is known in the United States, the attorney-client privilege). In 2002, however, a bill sponsored by Senator Paul Sarbanes of Maryland passed through the Senate and the House of Representatives. It was signed into law in early August by President Bush and has become known as the Corporate Responsibility Law. It requires in-house and outside lawyers to report evidence of corporate wrong-doing to their clients companies’ boards of directors. There has been a real concern that the law will prevent employees and executives from seeking information from counsel. There are also worries about how lower level management will respond to the law. Koji Fukumura, co-chair of the American Bar Association Litigation Section Securities Committee said, for example: “[The clients] will be afraid of seeking advice, because the expectation they will have is the lawyer will immediately turn around and tell the CEO or general counsel. I envisage a chilling of communications of the lower level, because a lot of times when you are working on due diligence or a transaction, the success of which may have a material impact on the financial condition of the company, you are not dealing with the CEO on a day-to-day basis. You are dealing with someone below that.” Reporting client misconduct has become a major issue in the United States. Indeed as late as last week, the American Bar Association had a special taskforce on corporate responsibility which has just released its final report. The model rules of professional conduct have been amended to permit lawyers to breach client confidentiality to prevent fraudulent conduct. Already at least 41 states permit disclosure where disclosure is done to prevent reasonably certain death or bodily harm. However proposed amendments would permit disclosure to prevent a client from committing a financial crime or fraud – or to rectify injury from such wrong-doing – whether crime or fraud would be furthered in part by the lawyers services. “The culture and environment we operate in has changed” says the President of the American Bar Association, referring to the September 11 attacks and Enron’s bankruptcy. Financial scandals of the past couple of years, beginning with Enron have given new life to the idea that lawyers should be more assertive in ensuring their clients don’t use lawyers knowingly to break the law. The whole attitude to the issue has been quickened by the Sarbanes Act of 2002. As I have said, that requires lawyers to report up the corporate ladder any discovery of securities law violations. Now the proposed amendments would refine and clarify when corporate lawyers must engage in up-the-ladder disclosure and when they may disclose information outside the client corporation. The proposals also create a special requirement for lawyers who are discharged for reporting violations internally or who withdraw from serving the client for failure to address the violations. Conclusion In this address I have endeavoured to track some international developments. For obvious reasons I have paid particular attention to New Zealand where the issue of whistle-blowing has excited a great deal of attention in the last decade. As I have said, I believe the New Zealand legislation is flawed and places unnecessary and unfair burdens on private sector organisations. I also do not think that it encourages people to come forward. One can only hope that when the opportunity for a review arises in 2004, the legislation will be rigorously examined. There is no easy answer to the ethical dilemmas faced by whistle-blowers. Look at Mr Ah Chong; a real hero in the international community but victimised at home and unable to achieve justice in the courts of Samoa. Who can deny that Mr Ah Chong was seeking only to do his job and raise standards of public accountability in that country? Mr Pugmire’s case is a more difficult one. Certainly the events giving rise to the disclosure were most unfortunate and it seems that Good Health Wanganui was inept. He should not have disclosed to an opposition MP but I can see the justification for his going to the media. That could have been one example of a situation where the public interest outweighed private concerns. There will necessarily be situations where disclosure is in the public interest but they will be rare and they must not be permitted to underline the basic principle that employees do have duties of loyalty to their employers and that unless there is a very good case for disclosure in the public interest in extreme situations, employees should not take it on themselves to blow the whistle. Of greater concern is the move to compulsory whistle-blowing in the United States. While there has been a fundamental and irrevocable change in thinking in the United States post September 11, and there is a need to confront global terrorism, money laundering and other contemporary abuses, one has to wonder whether undermining legal professional privilege is the way to do it. This week’s Economist has a very interesting article on the current Attorney General for the United States, John Ashcroft. Prior to his appointment as US Attorney General, he was very much on the side of the individual and states versus federal government. Now he is expanding the power of the Federal Government at a rate which commentators regard as frightening. The Economist suggested he could well rue the day when those same powers are held by his political opponents. Making whistle-blowing compulsory, is a frightening development and should be resisted. [1] Pugmire v Good Health Wanganui (No.1) [1994] 1 ERNZ58 [2] Pugmire v Good Health Wanganui (No.2) [1994] 1 ERNZ174 [3] Hansard Political Debate Reports 15 June 1994 at 1750 [4] Hansard Political Debate Reports 15 June 1994 at 1771 [5] NZ Management Journal May 2000 Vol 47 p60 [6] “Protected Disclosures Act 2000” in Employment Contracts: Bargaining Trends; Employment Law Update – 1999/2000 [7] National MP Anne Tolley, in Hansard Political Debate Reports, 28 March 2000 at 1420 [8] Quigg Partners 2000, “The Protected Disclosures Act 2000 – An Overview” [9] “Protected Disclosures Act 2000” in Employment Contracts: Bargaining Trends; Employment Law Update – 1999/2000 [10] Aaron Dearden, “Whistleblowing – The Protected Disclosures Act 2000”, Employment Law Bulletin [11] “Protected Disclosures Act 2000” in Employment Contracts: Bargaining Trends; Employment Law Update – 1999/2000 [12] “Whistleblowers bill passes despite fears”, The Dominion, 30/3/00 – National MP, Tony Ryall [13] Michael Quigg – Sean Haywood, “Ethics Accountability and the Act of Whistleblowing”, Chartered Accountants Journal, September 2000, 24-26 [14] Louise Taylor, “Once more unto the breach…”, [2002] NZLJ 225 |
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