Whistleblower routines

Whistleblowing routines

When the management, in collaboration with employee representatives, has mapped the risk that matters worthy of criticism may arise, and prepared the ethical guidelines, the management can facilitate whistleblowing routines. In accordance with the Working Environment Act, the whistleblowing routines must be available to everyone who works for the business. This includes students, apprentices, temporary staff and others who perform work for the business.


In the routines it should be informed about 

  • What whistleblowing is
  • What to notify about, to whom and how to notify.

In the whistleblowing routines, the employees should be encouraged to notify of matters worthy of criticism. The routines shall contain information about case processing, including whistleblower protection, contradiction and how a notification is stored (in accordance with the GDPR).  The management should follow-up the whistleblower during and after the case processing. When routines for notification are in place, everyone should know what is meant by matters worthy of criticism in the company and how to notify about it. Furthermore, what consequences can be experienced if you break the rules, about the GDPR, whistleblower protection and retaliation.

The employer shall ensure that a notice is adequately investigated within a reasonable time. The employer shall ensure that the whistleblower has a safe working environment, and if necessary, the employer shall provide measures to prevent retaliation.

The employer should ensure that the following three principles are observed:

  • Confidentiality: The notification must be handled confidentially, which means that no other than a few should know the content of the notification and the identity of the whistleblower.
  • Impartiality: The person who is to handle the notification must be impartial, which means that he / she is without interest in the case. This is important to make sure that the notification is handled correctly. If persons who are in the notification group or the management are a part of the notification, they shall not process the notification. It is possible to use an external party to handle the notification if the employer is incompetent.
  • Contradiction: The person who is notified about has the right to access the personal information that concerns him / her. This means that the person / persons have the right to provide their version of the case. The employer must ensure that the right to contradiction is respect