CLEMENS' compliance team advises all types of companies and public authorities on the obligations arising from the Whistleblower Act and the legal requirements for whistleblower schemes and proper handling of whistleblower reports.

How can we help?

CLEMENS offers customized management of whistleblower schemes, and we can assist with everything from full service management to isolated legal assessments and handling of individual reports.

Among other things, we can assist with:

  • Manage whistleblower schemes
  • Assess obligations under the Whistleblower Act
  • Develop whistleblower policies
  • Develop procedures for handling reports
  • Assess whether reports are covered by whistleblower legislation
  • Organize and conduct investigations into reported issues
  • Assess how best to deal with any illegal conditions
  • Provide feedback to the whistleblower

CLEMENS' whistleblower scheme

With CLEMENS' whistleblower scheme , we efficiently, pragmatically and with a high professional level, we take care of all aspects of your organization's whistleblower scheme - from advice on the requirements for your organization to the implementation and administration of the whistleblower scheme.

The whistleblower scheme includes, among other things:

  • A secure and easy-to-use platform with customizable setup and language options
  • Standard whistleblower policy in Danish and English
  • Guidance material
  • A whistleblower scheme that complies with data protection regulations and ensures a high level of confidentiality
  • Professional and confidential screening of whistleblower reports and handling communication with whistleblowers

Pricing structure

We offer a competitive and transparent pricing structure with low set-up and operating costs:

Setup: 2.000 kr. (one-off benefit)
Annual license (0-500 employees): 12.000 kr.
Annual license (500+ employees): Contact us for a separate agreement
Reporting: 2.000 kr. per report
All prices exclude VAT, valid for 2024

If CLEMENS' whistleblower scheme sounds like something for your organization, or if you need help on how to set up a whistleblower scheme yourself, you are welcome to contact us for a non-binding meeting.

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The Whistleblower Act requires employers with 50+ employees to establish an internal whistleblower scheme. "Employers" include all types of companies, associations, foundations, etc. as well as public authorities.

The whistleblower scheme must ensure that employees can confidentially and securely report illegal and serious matters that the whistleblower has become aware of in connection with his or her work. At the same time, the whistleblower scheme must ensure that there are no negative consequences for the whistleblower for having made a report.

Whistleblowing schemes are often established with access to make reports via a digital platform, possibly supplemented by access to make oral reports to the person(s) designated by the organization as the whistleblowing unit.

Proper handling of a whistleblower scheme also involves effective orientation on the procedures for making reports within the organization.

It therefore follows directly from the Whistleblower Act that a whistleblower unit must be appointed, which is responsible for, among other things, managing the whistleblower scheme and ensuring that the whistleblower scheme is effective.

The whistleblowing unit can consist of one or more employees in the company/authority or in an affiliated company, but the whistleblowing unit function can also be handled by an external provider, e.g. Attorney.

The person or persons appointed as the whistleblower unit are subject to a special duty of confidentiality with regard to the information included in reports and information about the identity of the whistleblower, and since failure to comply with this duty of confidentiality may result in personal liability for fines, it is important that the whistleblower unit is continuously trained in the requirements for handling the whistleblower scheme.

The number of employees must be calculated based on head counts per legal entity and thus independent of the employment rate of the employees.

Part-time employees, young workers, flex job employees, etc. must therefore be included in the calculation of the number of employees on the same terms as full-time employees.

However, there are a few exceptions to this for seasonal or project-oriented businesses.

The obligation to establish a whistleblower scheme is generally triggered when the organization has had an average of 50+ employees in the 4 preceding quarters.

For public authorities and organizations with 50+ employees, the obligation to establish a whistleblower scheme follows directly from the Whistleblower Act.

However, many organizations with fewer than 50 employees choose to establish a voluntary whistleblower scheme, just as more and more organizations and authorities are choosing to expand their whistleblower scheme so that it is also available to suppliers, customers, citizens, etc.

This is often because the whistleblowing scheme speaks to the sustainability aspect that is linked to the G (governance) in the ESG context.

Similar to environmental and social sustainability, good governance is crucial to an organization's long-term sustainability and ability to create value.

The whistleblower scheme is therefore also an important management tool that contributes to responsible corporate governance and to ensuring and managing the company's integrity, ethical behavior and, not least, legal compliance.

With our help in setting up and managing your internal whistleblower scheme , you'll not only keep your organization from learning the hard way. You'll also ensure that your compliance is turned into a valuable business benefit for you, including increased employee trust because you take reporting and compliance seriously.

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