duty speech because without such an understanding the Directive will "miss the iceberg of what's needed". France In France, several laws, all recent, have established a protection regime for whistleblowers. Prior to 2016, there were several laws in force which created disparate legislation with sector-specific regimes. The 2016 law on transparency, fight against corruption and modernization of economic life (known as the "Sapin 2 Law") provides for the first time a single legal definition of whistleblowers in France. It defines him or her as "an individual who discloses or reports, in a disinterested manner and in good faith, a crime or an offence, a serious and manifest breach of an international commitment duly ratified or approved by France, an unilateral act of an international organization adopted on the basis of such a commitment, of the law or regulations, or a serious threat or harm to general interest, which he or she has become personally aware of." It excludes certain professional secrets such as national defense secrecy, medical secrecy or the secrecy of relations between a lawyer and his client. In 2022, two laws are passed to transpose the European Directive 2019/1937 of 23 October 2019 on the protection of persons who report breaches of Union law. One of them strengthens the role of the Défenseur des droits - the French ombudsman - tasked with advising and protecting whistleblowers. The second amends the Sapin 2 law to bring it into line with the directive and adds substantial guarantees not included in the directive among which: The definition of whistleblowing in force under the ‘Sapin 2’ law – which includes not work-based whistleblowing - has been maintained. The protection applies to any natural person who facilitate or assist whistleblowers – as required in the directive – but also to entities such as NGO or trade unions which act as a facilitator. They are offered the same level of protection. Military personnel will now be afforded the same level of protection as other civil servants, so long as they do not disclose information that may harm national security. The law provides that whistleblowers may be granted financial assistance, when subjected to a suit, by making an application to a judge, who has the power to force the organization which is suing – the employer for instance - to provide to cover legal fees and, where relevant, to cover their living expenses where their