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The introduction of whistleblowing (alerte éthique in French) mechanisms into the French business world resulted from the promulgation of the Sarbanes-Oxley Act (2002). Whistleblowing is the denunciation by employees of acts that do not comply with the rules (financial or accounting for the SOX Act, but which can extend to all illegal actions in the organization). In France, managers, union activists, and politicians have enquired about the practical application of whistleblowing. In this article, we first make a synthetic tableau of whistleblowing around the world (excluding the United States and France), then we study its application in the United States. Finally, we examine the difficulties of transposing the American model to France given the French cultural and legal constraints that companies face and the means of implementing it.
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