Here you can make a report to the Danish Financial Supervisory Authority's internal whistleblowing system

The whistleblowing system meets the following purposes: 

• to increase opportunities for employees and partners to speak out about critical situations in the authorities without fear of negative consequences;
• to protect persons who submit information to the whistleblowing system; and 
• to detect malpractice and thereby raise the level of services provided by the authorities. 

The whistleblowing system offers employees of the Financial Supervisory Authority a place to go if they experience or suspect that serious legal violations are taking place.

Whistleblowing systems complement the direct and daily communication at the workplace about errors and unsatisfactory conditions, etc. Problems should therefore first be resolved by contacting, for example, the immediate manager, the HR department or the union representative. 

The whistleblowing system is merely an additional option if you become aware of or suspect serious matters and you do not feel comfortable going to one of these parties. 

There must be serious wrongdoing or suspicion thereof. This may be, for example, information relating to criminal offences, non-compliance with legal obligations, danger to the safety of individuals and the like. Examples include:

• criminal offences, such as breach of professional secrecy, misuse of financial resources, theft, fraud, embezzlement, fraud, bribery, etc. 
• legal violations, such as legislation on the use of force, administrative law, data protection law, the law on public access, etc.
• infringements of principles of administrative law, such as the principle of investigation, requirements of fairness, the principle of distortion of powers and proportionality, etc.
• gross or repeated breaches of significant internal guidelines on such matters as business trips, gifts and financial reporting, etc.
• serious personal conflicts at work, such as serious harassment, including of a sexual nature.
• deliberate misrepresentation of citizens and collaborators.

Knowledge or reasonable suspicion that such serious matters have been committed is presumed.

The systems do not cover information on matters other than those described below.

As a rule, information on other matters must be handled through, for example, the immediate manager, the personnel/HR department or a trust representative. Information on other matters may include, for example:

• information on breaches of minor internal guidelines on sick leave, smoking, alcohol, dress, use of office supplies, etc. and
• information on less serious employee-related conflicts in the workplace.

The whistleblowing system can be used by persons working for the Financial Supervisory Authority. It includes collective bargaining employees, part-time and full-time employees and civil servants, volunteers, and paid and unpaid interns.

The systems may also be used by persons who have previously worked for the Financial Supervisory Authority and who report information that they came into possession of during the period that they worked for the Financial Supervisory Authority.

Furthermore, the systems may be used by persons who have not yet started working at the Financial Supervisory Authority but who report information acquired in connection with the recruitment process or other pre-contract legal negotiations.

In addition, the systems can be used by partners with whom the authority has a more continuous or formalised cooperation, including private companies (e.g. suppliers and subcontractors). This means that the systems could be used by persons working under the supervision and management of, for example, one of the authority’s contractors, subcontractors or suppliers.

Others parties, such as citizens who have a case under consideration with the Financial Supervisory Authority, will not generally be covered.

If you become aware of or suspect that violations are taking place here at the Financial Supervisory Authority, as mentioned in the section above “What should we use an internal whistleblowing system for”, you can report the situation by using the following link, which allows you to make an anonymous report.

You have the option to make a report anonymously. Please refer to the description below “Guide to anonymous reporting”.

Please note that in practice, it may be difficult to investigate anonymous inquiries. For example, it may turn out not to be possible to investigate an alert without compromising anonymity. In this context, the Financial Supervisory Authority must not place weight merely on anonymous information as part of an intrusive decision – e.g. against one of the Authority's employees. This may lead to a report having to be dropped.

If information is reported to the whistleblowing system from a computer that is on the Financial Supervisory Authority's network, this may be recorded as part of the regular logging.

If you wish to remain anonymous, please ensure that the request does not disclose your name, telephone number, email address or other personally identifiable information. In addition, please ensure that when uploading or transmitting files, including documents, films, photos, etc., information about your identity is not inadvertently disclosed. Throughout the course of the case, the Financial Supervisory Authority's whistleblower unit will have the opportunity to ask additional questions and, if necessary, obtain additional information via an anonymous two-way communication channel.

After you submit a report, you will receive a confirmation of receipt showing that your report has been received.

You will also receive a 16-digit code that you will need to access the report again.

Incoming reports are recorded and processed through the Financial Supervisory Authority's whistleblower unit.

The whistleblower unit consists of the Financial Supervisory Authority's Chairman of the Board of Directors. Authorised employees of the Financial Supervisory Authority's Board Secretariat assist the Chairman in the processing of contacts.

The Financial Supervisory Authority's Chairman of the Board of Directors and authorised employees in the Board Secretariat have a duty of confidentiality with regard to information included in the reports received.

Once the whistleblower unit has received an alert, confirmation of receipt is sent to the reporting party within seven (7) days. The report shall be deemed to have been received on the same day, regardless of the time of receipt. This means that a report received outside normal office hours is deemed to have been received on that day. Saturdays, Sundays and public holidays must be included in the calculation of the deadline.

In addition, an initial assessment is made as to whether there are grounds for the matter to be properly handled or whether the request should be dismissed as clearly unfounded, for example because it relates to matters or has been submitted by a person who is not covered by the Financial Supervisory Authority’s internal whistleblowing system.

Persons submitting information to a whistleblowing system will be informed as soon as possible – and no later than three months from receipt of the report being confirmed – on the proceedings and any outcome.

If the three-month time limit cannot be met, the whistleblower must be informed – upon confirmation of receipt – of the expected processing time.

The general rules of administrative law shall also apply. Reporting to the whistleblowing systems will not in itself result in you becoming a party to a case before the Financial Supervisory Authority, including gaining the usual party rights (e.g. party consultation, justification, access to party documents and the possibility to appeal). However, there may be cases where you want to obtain party status in a case that the report addresses or gives rise to.

Under current rules, access to the name of the person who submitted the information may be available if the report is not submitted anonymously. For example, the persons to whom the information relates may have the right to know who submitted the information.

Persons submitting alerts through the whistleblowing system are protected from adverse consequences associated with a report made in good faith.

If an employee of the Financial Supervisory Authority uses a whistleblowing system, it cannot in itself lead to dismissal or other forms of direct or indirect sanction, such as changing the employee’s area of work, or to the employee not being awarded salary supplements.

However, there may be instances where the consequences of an employee lawfully exercising their right to report are of such a serious nature that it can provide a legitimate basis for management to employ the aforementioned reactions towards the employee.

If you, as an employee, experience negative management reactions because you have used one of the whistleblowing systems, you can contact the whistleblower unit, the union representative or professional organisation.

If an employee has experienced reactions which are not warranted under labour law as a result of submitting a report, the employee may be awarded compensation, reparation or financial compensation in accordance with the applicable regulations at any given time.

The persons to whom the information relates will normally be notified if information about them is submitted. A party to a case concerning or giving rise to a report shall be heard or given access to the other information contained in the report, in addition to information on the identity of the whistleblower. The person concerned will thus be notified when the case is dismissed as clearly unfounded, and the person concerned will be involved in the proceedings if the case is adjudicated. In this context, the person concerned has the right to request that incorrect information be corrected, that the data be deleted and that the authority restrict the processing of information about the person.

No knowingly false or misleading information may be submitted via the whistleblowing systems. Information submitted in bad faith may result in a police report and may have adverse employment law consequences or result in contractual consequences for the person who submitted the information.

The general deletion rules also apply. Reports and follow-ups may only be kept for as long as is necessary and proportionate to meet the requirements of the Whistleblower Act.

A period of deletion is set at five years from the end of the case, with the possibility of setting a longer period on the basis of a concrete assessment.

An extension of the retention period may, for example, be made if it is assessed in concrete terms that it is likely that persons (the whistleblower or persons concerned) protected under the Whistleblowers Act may need to document the report, or if it is specifically assessed that the report in question could be corroborated by subsequent reports on the same matter. If multiple reports have been filed on the same subject, this may suggest that reports should be kept to be linked with one another.

If, on the basis of the information collected, a disciplinary sanction is imposed on the employee or, moreover, there are reasons why it is appropriate and necessary to continue to retain information about the employee, the information will be kept in the personnel file of the employee concerned.

If you make a report to our internal whistleblower unit, you will receive information about how we process your personal data in accordance with Article 13 of the General Data Protection Regulation.

If you wish to inform yourself about this, you can also access the information here.