Are you receiving few or no reports to your whistleblower scheme?

General trends

The number of whistleblower reports to the Danish National Whistleblower Scheme and the number of reports in C25 companies is increasing and continues to rise. In the period from 1 January 2024 to 31 December 2024, the Danish National Whistleblower Scheme received a total of 186 reports. This is 37 more reports than the year before (corresponding to an increase of approximately 25%).

However, there are several workplaces that receive few or no reports at all to their whistleblower scheme. 

The reasons for few or no reports at all may be many. For example, everything may be as it should be, which is really positive. But it may also be a lack of knowledge about the scheme and what it may be used for.

Is your whistleblower scheme easily accessible?

According to section 13 of the Danish Whistleblower Act, an employer is obliged to make information about its whistleblower scheme available to its employees (and such other group of people that the employer may have voluntarily chosen to allow to use the scheme) "in a clear and easily accessible form".

Section 13 of the Whistleblower Act means that the information must be made available in a visible place that is easily accessible to the persons who can use the system. This could be on the intranet and/or website or similar. 

If you are one of the workplaces that receives few or no reports, you may consider whether the scheme is really accessible to the people who can use it?

How to draw attention to the whistleblower scheme

You may also consider whether it would be value-adding and appropriate for you to launch initiatives that put (greater) focus on the whistleblower scheme and its scope. We have gathered some inspiration and examples below that, from experience, we find appropriate to use:

• Awareness campaigns: Consider whether your employees (and any other people who may use the scheme) can be made more aware of your whistleblower scheme and what it may be used for. To ensure awareness of the scheme, it is advisable that your employees are informed about the scheme on an ongoing basis, for example at least once a year. This may be through a shared e-mail, a post on your intranet, a post on your website, a physical post on the notice board or any place else that your employees use. It may also be included as an item on the agenda for management briefings, staff meetings or similar.
  
• Inclusion in on-boarding processes: Consider whether information about your whistleblower scheme may be included as a mandatory part of the on-boarding of new employees to the workplace. Make sure your new employees are aware of the whistleblower scheme, where it can be accessed and what it may be used for when they join.
  
• Inclusion in relevant courses and training seminars etc.: Consider whether information about your whistleblower scheme can be included as an ongoing item in relevant courses, training seminars or similar.
• Interactive information: Consider whether information about your whistleblower scheme can be made more interactive, for example through compliance games, quizzes, tests, videos and/or concrete cases.
  
• Greater transparency in management: Consider whether management can be more transparent about the whistleblower scheme in relation to security in the use of the scheme, including that employees who use the scheme are protected from retaliation
  
• Transparency about the whistleblower team: If employees are not aware of who handles the reports internally, consider whether they should be informed of this. This may help reassure employees about the use of the scheme.  
  
• Possibility of anonymity: If it is not possible to report anonymously to your whistleblower scheme, consider allowing this option.
  
• Shop stewards and health and safety representatives' knowledge of your whistleblower scheme: Consider whether your shop stewards and health and safety representatives are aware of and have enough knowledge about your whistleblower scheme, and whether they can make employees aware of the scheme in relevant meetings and dialogue.

If you want to raise awareness of your whistleblower scheme among your employees, we are happy to visit you to give a presentation and have a dialogue about how a whistleblower scheme works and what employees can generally expect if they make a report.

More information about Poul Schmith's whistleblower service.