employee reports to someone in a higher position such as a manager, or to external factors, such as their lawyer or the police. Whistleblowing in the private sector is typically not high-profile or openly discussed in major news outlets, though occasionally, third parties expose human rights violations and exploitation of workers. Many governments attempt to protect such whistleblowers. In the United States, for example, there are organizations such as the United States Department of Labor (DOL), and laws such as the Sarbanes-Oxley Act and the United States Federal Sentencing Guidelines for Organizations (FSGO) that protect whistleblowers in the private sector. Thus, despite government efforts to help regulate the private sector, the employees must still weigh their options. They either expose the company and stand the moral and ethical high ground; or expose the company, lose their job, their reputation and potentially the ability to be employed again. According to a study at the University of Pennsylvania, out of three hundred whistleblowers studied, sixty nine percent of them had foregone that exact situation; and they were either fired or were forced to retire after taking the ethical high ground. It is outcomes like that which makes it all that much harder to accurately track how prevalent whistleblowing is in the private sector. Public sector whistleblowing Recognition of the value of public sector whistleblowing has been growing over the last 50 years. In the United States, for example, both state and Federal statutes have been put in place to protect whistleblowers from retaliation. The United States Supreme Court ruled that public sector whistleblowers are protected from retaliation by their First Amendment rights. After many federal whistleblowers were covered in high-profile media cases, laws were finally introduced to protect government whistleblowers. These laws were enacted to help prevent corruption and encourage people to expose misconduct, illegal, or dishonest activity for the good of society. People who choose to act as whistleblowers often suffer retaliation from their employer. They most likely are fired because they are an at-will employee, which means they can be fired without a reason. There are exceptions in place for whistleblowers who are at-will employees. Even without a statute, numerous decisions encourage and protect whistleblowing on grounds of public policy. Statutes state that an employer shall not take any adverse employment actions any employee in retaliation for a good-faith report of a whistleblowing action or cooperating in any way in