Whistleblower scheme

EKF has a whistleblower scheme, which you can use for reporting wrongdoing within EKF. The whistleblower scheme is designed to improve the capacity of staff and selected categories of persons to report and provide disclosures concerning wrongdoing within EKF without fear of retaliation.

Who can use the whistleblower scheme?

 EKF's whistleblower scheme is open to:

1.  Workers (staff of EKF).
2.  Self-employed persons. This would include self-employed persons providing services to EKF.
3. Members of management and the board of directors.
4. Voluntary staff.
5. Paid or unpaid trainees.
6. Persons working under the supervision and direction of contractors, sub-suppliers and suppliers. This category of persons includes the employees of an undertaking with which the place of work.
   has signed a contract. This category of persons also includes employees of an
   undertaking that is the supplier or sub-supplier of products or services to
   the place of work.
7. Persons who report or publicly disclose information acquired in a work-based relationship which has since ended. This category of persons also includes those employed at the place of work before the entry into force of the Danish Whistleblower Protection Act.
8. Persons whose work-based relationship is yet to begin in cases where information on breaches has been acquired during the recruitment process or other pre-contractual negotiations. This category of persons includes both those who subsequently gain employment at the place of work and those who do not gain such employment.

Use of the whistleblower scheme is conditional on information on breaches reported through the whistleblower scheme having been acquired in a work-related situation for EKF.

What is reportable?

Reports may be made concerning information on breaches of EU law comprised by the scope of the EU Whistleblowing Directive as well as serious breaches of law or other serious matters.
 
A breach of EU law would, for example, concern:

• public procurement;
• money laundering;
• product safety and compliance;
• transport safety;
• food and feed safety;
• animal health and welfare;
• protection of the environment;
• public health;
• consumer protection;
• protection of privacy and personal data;
• security of network and information systems.

 Serious breaches of law or other serious matters would, for example, include:

• breach of confidentiality;
• misuse of funds;
• theft;
• fraud;
• embezzlement;
• deception;
• bribery;
• breach of occupational safety;
• any form of sexual harassment;
• severe workplace harassment, e.g. bullying, assault and harassment on grounds of race or political or religious affiliation;
• severe or repeated breaches of good public administration practices, including the principle of investigation, the objectivity requirement, the abuse of power maxim and the proportionality principle;
• intentionally misleading members of the public and cooperation partners.

 
Information of a trivial nature, information concerning other matters, including information on breaches of internal policy on sickness absences, smoking, alcohol, dress code and
personal use of office supplies or breaches of accessory provisions such as non-compliance with the documentation duty, would not fall within the scope of the scheme.

Where can I report?

Written reports should be submitted via a website managed by Plesner, and hosted at this address:

Insofar as you have knowledge or reasonable suspicion thereof, please provide the following:

• a description of the wrongdoing;
•  who is involved;
• whether others are aware of your suspicion of the wrongdoing;
• whether the management is aware of the wrongdoing;
• whether documents exist as evidence of the wrongdoing;
• whether further information about the wrongdoing may be obtained, and if so, where;
• the duration of the wrongdoing; andwhether the whistleblower is aware of any attempt to conceal the wrongdoing.

Is there any option for anonymous reporting?

EKF urges you to disclose your identity in your report in order to permit the whistleblowing unit to ask you clarifying questions and subsequently notify you of the progress of its investigation.
 
You may, however, report information anonymously. In order to guarantee full anonymity, you are recommended to use a personal computer or a computer located in a public library. If you wish to remain anonymous, you should not use an EKF-internal connection or EKF equipment.

How does EKF process a whistleblower report?

EKF has appointed an internal whistleblowing unit which

1. receives reports and maintains contact with the whistleblower;
2. follows up on whistleblower reports;
3. provides feedback to the whistleblower.

 Examples of follow-up on whistleblower reports:

• Initiating an internal investigation within the authority.
• Notifying the authority's executive management or board of directors.
• Reporting the wrongdoing to the police or relevant supervisory authority.
• Closure of the procedure (e.g. on grounds of insufficient evidence).

The whistleblowing unit must subsequently provide you with feedback. This means that the unit must to the greatest possible extent inform you of what action is envisaged or has been taken, and the unit's grounds for such follow-up.

How are you protected?

You are protected by the Danish Whistleblower Protection Act if you have submitted a report to

• EKF's internal whistleblower scheme;
• The Danish Data Protection Agency's external whistleblower scheme (for details, see below).

You are protected under the Danish Whistleblower Protection Act if you had reasonable grounds to assume that the information you reported was accurate at the time of reporting, and that the information was within the scope of that Act and of the Danish Anti-Money Laundering Act.
 
To qualify for such protection, you must act in good faith upon reasonable grounds to believe, at the time of reporting, that the matters reported are true. Persons who deliberately report false information enjoy no protection.
 
Where these conditions are met, you are protected against retaliation, including any threatened or attempted retaliation for your internal or external reporting. You are also protected against actions to hinder or attempt to hinder reporting.

The Danish Data Protection Agency's external whistleblower scheme

If you do not wish to use EKF's internal whistleblower scheme, you may report matters of concern to the Danish Data Protection Agency's whistleblower scheme. You may report the same matters to the external whistleblower scheme, and there is no requirement to have first reported them via EKF's internal whistleblower scheme. EKF strongly recommends that you use the internal scheme provided that the breaches can be addressed effectively within EKF, and where you are confident that there is no risk of retaliation.
 
The Danish Data Protection Agency's external whistleblower scheme may be accessed via https://whistleblower.dk/. 

Processing of personal data

Learn more about how EKF processes your personal data if you report matters of concern via EKF's whistleblower scheme here: https://ekf.dk/om-ekf/ekf-s-forretning/ekf-s-persondatapolitik.