i agree ireckon!
the TOPS whistle is the same one that Victorinox once sold in their SwissChamp kits (and as a replacement part) WITHOUT any printing on it.
called the Victorinox Swiss Army Distress Whistle, Accessory Part #30481
a google search shows them still available on-line for as little as 59 cents each, all the way up to a ridicules $2.95 plus $7 shipping.
(fyi - they retailed for $2 when SAK still offered them in their catalog)