The paper addresses possible approaches to and challenges with providing statutory definition of “conflict of interest”. Based on the analysis of legislation in more than 20 countries as well as relevant documents of international organizations, three widely used models for defining conflict of interest are identified and their comparative advantages and disadvantages are considered.

The analytical report addresses approaches to the organizational setting of the whistleblowing system, i.e. the mechanisms that allow public officials and employees to report the offences they have observed and provide for the protection of whistleblowers, in the US, UK and Canada. Proceeding from the analysis of the national practices of the three countries, a set of recommendations on the drafting of relevant legislation is produced.