The Number of Whistleblowing Reports Currently Almost Doubles All Previous Reports Since 2019: Prosecutor General’s Advisor

“The example of countries with successful experience proves that public awareness campaigns about whistleblowing through various formats can significantly change the public’s skeptical attitude towards the effectiveness of the whistleblowing system and especially whistleblower protection mechanisms,” said Eva Saghoyan, Advisor to the Prosecutor General, in a conversation with Iravaban.net, discussing the whistleblowing system and results recorded after the nationwide whistleblowing campaign.

It should also be noted that October 2024 stood out with the number of whistleblowing reports received through Azdararir.am. The highest indicator was recorded, with 40 reports in one month.

-Representatives of the Ministry of Justice have repeatedly stated that whistleblowing numbers have increased after the nationwide campaign. Can you indicate when this increase was recorded and how much it is related to the campaign?

-Analysis of whistleblowing statistics from the platform’s launch in 2019 until 2023 shows that the annual number of reports received on the electronic platform during this period did not significantly fluctuate: the maximum was recorded in the first year of the platform’s operation in 2019, comprising 188 reports. The minimum was recorded in 2021, when 75 reports were submitted, however, in the same year, the proportion of criminal cases initiated based on whistleblowing reports increased significantly. Specifically, criminal cases were initiated based on 10 out of 75 reports.

In 2024, the number of reports received on the electronic whistleblowing platform has increased sharply compared to the previous year. Thus, while 116 reports were received through the platform in 2023, as of October 25, 2024, 276 reports have already been received, which means the number of reports currently almost doubles all previous reports submitted since 2019.

From this telling statistics, of course, one can conclude that the implementation of the public anti-corruption communication and awareness action program outlined in the Republic of Armenia’s 2023-2026 Anti-Corruption Strategy, and the efforts of state administration and law enforcement bodies and civil society aimed at taking consistent steps to raise public awareness about the whistleblowing system through its implementation, have yielded their noticeable results.

Nevertheless, it should be noted that despite ongoing efforts, the level of public awareness about the whistleblowing system and its components continues to remain insufficient, and work in this direction continues together with the Ministry of Justice’s partners.

-The Ministry’s partners note that the quality of whistleblowing reports has also improved. Can you indicate what kind of reports, in terms of quality, the prosecutor’s office has received?

-From January to October 2024, 57.71 percent of the reports submitted to the platform were verified through operational intelligence activities. This indicates that the content of submitted reports has become more precise and targeted.

The Law “On the Whistleblowing System” stipulates that a report containing criminal elements and submitted through the unified electronic platform is subject to verification under the procedure established by the Law “On Operational Intelligence Activities” only if the information presented in the report is sufficiently substantiated, relates to a specific official or body, and contains data that can reasonably be verified.

In other words, for reports to be verified through operational intelligence measures, they must meet certain criteria. Specifically, they should not be general and evaluative judgments, but rather describe specific acts containing criminal elements, should not relate to an indefinite or abstract circle of persons, but to specifically identifiable subject(s) or body, and, of course, the verification of the presented data should also be realistic.

From this perspective, it is very important to illuminate and clarify the content components of whistleblowing reports. It should be noted that the RA Prosecutor General’s Office actively participates in this process. In particular, a representative of the RA Prosecutor General’s Office has given presentations within the framework of the “Youth Against Corruption” educational program, specifically emphasizing the content requirements for reports sent to the electronic platform, as well as issues related to the application of whistleblower protection mechanisms.

-How many proceedings have been initiated from whistleblowing reports since November 2023?

-Since November 2023, criminal proceedings have been initiated on 15.70 percent of reports received on the whistleblowing platform, particularly on 19 reports, one of which under the corresponding articles of the previous RA Criminal Code. As can be noticed, the number of criminal proceedings initiated based on whistleblowing reports has also increased during this year.

-How do you assess the increase in the number of whistleblowing reports, why did the system record low results for several years after its launch?

-There are several reasons for the not widespread practice of submitting reports about corruption cases and other public service violations through the electronic whistleblowing platform, as well as through other whistleblowing mechanisms in general.

First of all, as in many countries, in Armenia both private and public sector employees and broadly speaking – the entire public, do not have a clear understanding of how to handle information that becomes known about corruption cases. The awareness about legal mechanisms for whistleblower protection is also not at a sufficient level, which inevitably leads to distrust in this system.

The example of countries with successful experience proves that public awareness campaigns about the whistleblowing institution through various formats can significantly change the public’s skeptical attitude towards the effectiveness of the whistleblowing system and especially whistleblower protection mechanisms.

From the perspective of public awareness campaigns’ effectiveness, the targeted nature of this process is also essential, which implies informing different groups of society through appropriate methods, information technology means and platforms, based on their age, social, occupational and other differences.

Besides the lack of public awareness about the essence of whistleblowing mechanisms and their existence in general, as well as trust in the effectiveness of these mechanisms and means of whistleblower protection, the main reasons contributing to the low performance of the whistleblowing system include the peculiarities of national mentality, stereotypes existing in society about this institution, the overcoming of which is in the value domain.

At the same time, in our conviction, the system’s effectiveness is evidenced not only and not so much by the number of submitted reports, but by the high proportion of criminal proceedings initiated based on them, which should be the aim of both public awareness campaigns and broadly speaking – the operation of the whistleblowing system.

This publication has been prepared within the framework of the “BlowtheWhistle, Armenia” project, which is implemented by the “Armenian Lawyers’ Association” NGO within the framework of the “Armenia Integrity” project, with generous support from the people of the United States through the U.S. Agency for International Development (USAID).

The contents of this publication are the sole responsibility of the “Armenian Lawyers’ Association” NGO and do not necessarily reflect the views of USAID or the United States Government.