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Whistleblowing scheme at SDU

SDU’s whistleblower scheme can be used by:

  • SDU’s employees
  • SDU’s former employees
  • Members of SDU’s Executive Board and Board
  • Volunteers at SDU
  • Paid and unpaid interns at SDU
  • Self-employed business owners who collaborate with SDU
  • Persons who work under the supervision and management of SDU’s contractors, subcontractors and suppliers
  • Persons whose working conditions at SDU have not yet begun but report on information to which they have gained access during the employment process or other pre-contractual negotiations

You can use the whistleblower scheme to report all serious offences and other serious matters that concern SDU. For example, this could be if there is suspicion or knowledge of illegal, unethical behaviour or misconduct, including matters of bribery and corruption, misuse of financial resources, theft, fraud, embezzlement and other financial crime as well as breaches of personal data security, serious or repeated breaches of ethical rules in the field of research, academic misconduct, conflicts of interest, cases of sexual harassment or other serious molestation as well as serious or repeated violations of the law in general. The examples are not exhaustive.

You can also report violations of EU law, which are covered by the scope of the whistleblower directive. For example, this could be violations within public procurement, financial services, product safety and compliance and environmental protection.

Reports are made via the link below.

The purpose of the whistleblowing scheme is:

  • To bring critical and serious matters to light, which otherwise would not have come to SDU’s attention
  • To ensure openness and transparency in relation to possible unlawful acts and serious irregularities at SDU

The whistleblower schemes should be seen as a supplement to existing options, such as contacting your immediate manager, the HR department, your union or health and safety representative, etc.

A whistleblower who reports in good faith about matters covered by the whistleblower scheme cannot face reprisals of any kind as a result of the report. In addition, SDU has a duty of confidentiality regarding your identity if you choose to disclose your identity in connection with a report. You can read more about this below.


You can submit information to the whistleblower scheme via this link https://whistleblowersoftware.com/secure/962587bd-0f09-4df1-8c00-22ac587bd6ce

It is important that you describe all the facts in as much detail as possible. As far as possible, please document the matter about which you are providing information.

When you submit information via the whistleblower portal, the template allows you to attach documentation in digital form. Factual information and any relevant documentation provide the best possibilities for investigating the matter about which you are submitting information.

The Poul Schmith law office screens every report made via the whistleblower scheme. If the initial screening shows that you and the reported matter are covered by the whistleblower scheme, the report will be investigated in more detail by SDU’s whistleblower unit, which was set up for this purpose and is composed of people from Financial Services, the Rector’s Office and SDU HR. Upon receipt of reports of serious incidents, the Rectorate (Rector, Pro-Rector and University Director) or the Chair of the Board will be informed.

Yes. You can submit information anonymously to the whistleblowing scheme. If you wish to remain anonymous, do not provide your name or other personally identifiable information such as address or phone number.

In making an anonymous report, you can choose whether you wish to be available for any further investigation by saving the password that you receive in connection with your report. The password allows you to access and follow up on your report in the whistleblower portal, including communicating with SDU’s whistleblower unit. We encourage you to save the password when making a report, as it may be difficult for SDU to carry out an investigation without additional information from you.

The reporting system logs neither the IP address nor the machine ID of the computer from which the report is made, and the system does not use cookies. If the computer from which the report is made is owned by SDU or connected to SDU’s network, there is a risk that the IP address and/or the machine ID from which the report was made will be logged in the browser’s history and/or SDU’s log via the logging that takes place in SDU’s IT systems.

You can eliminate this risk by making the report from a computer that is not owned by SDU or connected to SDU’s network.

To ensure your anonymity, you can therefore do the following

  • If possible, do not report from a PC provided by SDU
  • Do not use a PC that is connected to SDU’s network/intranet
  • Access the reporting system directly by copying or typing the URL address into an internet browser instead of clicking on a link
  • Do not provide your own personal information

As a reporter, as soon as possible and no later than seven days after making your report you will receive a receipt confirming that the report has been received. You will receive a receipt for the report via the whistleblower portal or via the personal contact details you have provided in connection with your report. If you make an anonymous report, you will receive the receipt in the whistleblower portal only if you have saved the password received in connection with the report.

As the reporter, you will receive feedback on the status of the report within three months, including what kind of follow-up on the report may have been carried out. You will receive feedback via the whistleblower portal or via the personal contact information you provided in connection with your report. In certain cases, the feedback may be limited by rules about confidentiality, etc.

You are free to choose whether your report will be anonymous or whether you want to state your identity in connection with a report.

If you choose to disclose your identity in connection with a report covered by the whistleblower scheme, SDU’s whistleblower unit has by law a duty of confidentiality regarding your identity. As a rule, your identity will only be disclosed if you expressly consent to this.

However, information about your identity may be disclosed to public authorities, such as the police or prosecutor’s office, if this is necessary to deal with reported matters or to ensure the right of defence for affected persons, as well as to external advisers, such as a lawyer or accountant, with a view to further investigation of the reported matter. You will be notified prior to the disclosure to the extent that it is possible with respect to the specific case processing.

A reporter who in good faith reports serious matters covered by the whistleblower scheme cannot face reprisals of any kind as a result of the report. An assessment as to whether a report has been submitted in good faith includes assessing whether the reporting person had reasonable cause to believe that the reported information was correct at the time of the report and that the reported information fell within the scope of the whistleblowing scheme.

The identity of the natural or juridical person being reported on, or a natural or juridical person associated with this person, e.g. the person’s spouse, will be protected during the processing of the report and will only be disclosed to persons outside SDU’s whistleblower unit as part of a follow-up to a report in order to deal with serious offences, other serious matters or breaches of EU law (that are covered by the scope of the whistleblower directive) or as otherwise required by law.

These persons have the right to an effective defence in cases where the reported information is included in the presentation of evidence, and for this reason received reports are registered, just as information about your identity can be disclosed in such cases.

You are free to choose between reporting to SDU’s whistleblower scheme or to an external whistleblower scheme. Consequently, the Danish Data Protection Authority has established an external whistleblower scheme, which supplements employers’ obligation to establish whistleblower schemes. You can read about the procedure for making a report to the Danish Data Protection Authority’s scheme on their website: https://whistleblower.dk/. On the website, you will also find a link to the Danish Data Protection Authority’s reporting portal, from where you can choose to make your report.

We encourage you to make your report to SDU’s whistleblower scheme if the violation can be effectively dealt with internally and you assess that there is no risk of reprisals – then SDU can quickly and directly follow up on the reported matter.

SDU’s processing of whistleblower reports received during the period 17 December 2021 – 31 December 2022

In accordance with Section 27 of the Whistleblower Act, SDU publishes the following information:
No. of reports received: 6
No. of reports processed: 4
No. of rejected reports: 2
No. of reports pending: 0
No. of reports for which a police report was filed: 0

The themes of the cases under active consideration are:
Violation of Danish legislation under EU law, Abuse of position and Other serious circumstances.

Grounds for dismissal of cases:
2 reports were rejected as the matter did not fall within the scope of the Whistleblower Act (see Section 12(3) of the Whistleblower Act).

 

 

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Last Updated 27.02.2023