From conducting a doctoral thesis to writing a book at the Valencian anti-fraud agency with corruption whistleblowers (2021-2023)
Cristina Fernández is a Lecturer in Criminology at the European University of Valencia and a Fellow at the European Whistleblowing Institute. This article is a joint publication between the European Whistleblowing Institute (EWI) and the Whistleblowing International Network (WIN).
On 21 May, I had the honour of launching my book, “A Criminological Analysis of the Whistleblower: With Special Reference to the Valencian Community”. At the heart of this analysis lies a key but misunderstood figure: the whistleblower – the public servant who chooses to break the code of silence. I argue that understanding whistleblowers requires an analysis of both the mechanisms that motivate individuals to speak up and those that silence them. Why would anyone report corruption knowing that the consequences might include professional isolation, psychological distress, or even economic and personal retaliation?
In this regard, the Valencian Community emerges as a privileged case study. Through emblematic cases such as the Valencian branch of the Gürtel case or the Blasco case, and with the emergence of the Agency for the Prevention and Fight against Corruption of the Valencian Community (AVAF) as an institutional benchmark, I was able to examine a protection model that, while pioneering, is not without tensions and limitations.
Over the years, the Agency consolidated a comprehensive protection system for whistleblowers, becoming a national leader in the early application of EU Directive 2019/1937 and the first organisation in Spain to fully comply with the UN Convention against Corruption. This protection included free legal assistance, anonymity through the implementation of IP anonymisation systems, and psychological support and safeguards against retaliation.
In its preventive role, AVAF developed practical tools such as the Public Integrity Plan and sectoral risk catalogues, which helped anticipate and reduce the emergence of corrupt behavior in public administration. Another key pillar was education and public awareness, including the creation of an open-access virtual learning platform, programs for children, and partnerships with universities, offering lectures and courses to younger people who are likely to become future public servants. In terms of institutional cooperation, the Agency signed agreements with numerous administrations, actively participated in European networks such as EPAC (European Partners Against Corruption) and NEIWA (Network of European Integrity and Whistleblowing Authorities) and was recognised for its ability to collaborate with international bodies in incorporating good practices at both European and global levels.
Last but not least, AVAF had an ethics committee, a consultative and independent body made up of individuals external to the institution, from civil society organisations and academia. Its purpose was to safeguard institutional integrity and promote an ethical culture within the public sector. This committee provided public employees with a safe space to raise ethical concerns, report potential internal irregularities, and propose improvements to existing ethical standards, thereby contributing to the continuous improvement of the organization. The committee was dissolved by the new leadership of the Agency, resulting in the removal of one of the key mechanisms for safeguarding institutional ethics in the Valencian Community.
These best practices turned AVAF into a reference model in building more transparent, accountable, and ethical institutions, with the European Commission recognizing the Agency as an example in its 2023 Handbook of Anti-Corruption Good Practices.
Key findings
One of the most significant findings of my research and set out in more detail in my book, was the identification of factors that either inhibit or encourage whistleblowing. Among the former: fear of retaliation, lack of training on reporting mechanisms, absence of real protection, and hostile work environments. Among the latter: strong personal ethics, a sense of public duty, and in some cases, institutional support.
Far from fetishising compliance policies, I advocate for a broader approach: one that includes ethical education from an early age, psychological support for whistleblowers, symbolic and social (not just material) incentives, and, above all, a cultural shift within public institutions. Law 2/2023, which transposed the European Directive in the Spanish legal system, marks undeniable progress but, as my research shows, it is not enough to create independent agencies or enable reporting channels if we do not dismantle the culture of silence, eliminate the stigma around whistleblowers, train public officials, and embed the whistleblower figure in the democratic narrative.
My book is dedicated to those who were silenced for speaking out. Many of these individuals — in the Valencian Community and throughout Spain — continue to suffer the consequences of their ethical decisions in isolation. They have taught me more than any theory ever could. To them, I offer my deepest gratitude, and I dedicate every page of this book to them. I hope this work contributes, however modestly, to that transformation.
