Guidelines on the whistleblower scheme
We have set up a whistleblower scheme in Envidan. We do so because it is important to us that serious matters that are reprehensible or illegal are highlighted and dealt with in the right way.
You can read more about our whistleblower scheme in our whistleblowing policy and on this page. We encourage you to read this before reporting your suspicion or concern through the scheme.
Who can use the whistleblower scheme?
You can use the whistleblower scheme if you work in Envidan A/S (“Envidan”), or have previously been employed by Envidan, if you are a business partner, supplier, customer or otherwise have a connection to Envidan.
What can you report?
You can use our whistleblower scheme, if you have knowledge or reasonable grounds to suspect serious criminal offences and other serious matters, as well as breaches of EU law, as defined in the Directive of the European Parliament and of the Council on the protection of persons reporting breaches of EU law.
This could be the following:
- Criminal offenses, such as fraud, embezzlement, misappropriation of assets, falsification of documents, manipulation of accounts, bribery, corruption, money laundering and terrorist financing
- Breaches of competition and procurement rules
- Risk to the health and safety of individuals, including serious or repeated breaches of occupational safety
- Significant breaches of environmental rules and pollution of the environment
- Breach of professional secrecy
- Breaches of privacy and personal data protection
- Serious violations of internal Envidan guidelines and rules (e.g. Envidan Staff Handbook and Code of Conduct)
- Discrimination, severe bullying, severe harassment, physical violence, threats and sexual harassment
The above are examples only. If you are unsure whether your report falls within the scope of the whistleblower scheme or not, we encourage you to use our whistleblower scheme. The report will then be assessed and you will receive feedback on whether your report falls within the scope of the scheme.
Issues such as cooperation difficulties, dissatisfaction with pay, minor breaches of internal guidelines on sick leave, smoking, alcohol, use of office supplies etc. should not be reported through the whistleblower scheme, but should instead be reported through our normal management structure, i.e. to your line manager.
We encourage you to use our whistleblower scheme if you have a concern or suspicion about serious matters. However, you can also choose to report your suspicion or concern to the Data Protection Authority. The Danish Data Protection Agency is a public authority that operates an external whistleblower scheme.
Your report goes directly to an independent and external third party (PwC Statsautoriseret Revisionspartnerselskab “PwC”). PwC is an independent audit, tax and advisory firm that receives reports on behalf of Envidan to ensure an independent and anonymous channel for you, the reporter. Your report will then be forwarded to Envidan for processing.
PwC makes an initial assessment of whether the report is covered by the whistleblower scheme and engages in a dialogue with the whistleblower if there is a need for further information or if the report gives rise to follow-up questions. PwC will then conduct an impartiality assessment to identify who can handle the report in Envidan so that the report can be processed by an impartial and competent person in Envidan, and thus not forwarded to a person to whom the report relates directly or indirectly or where there may be a risk of conflict of interest.
Chief Legal Officer of Envidan
The Head of Legal at Envidan is responsible for the whistleblower scheme. The Head of Legal is a particularly competent and independent person who is responsible for ensuring a careful follow-up on reports, and the Head of Legal is responsible for assessing what actions need to be taken based on your report and for ensuring that reports are handled in accordance with Envidan’s whistleblower policy.
You can see who processes alerts in the flowchart at the bottom of the page.
Confidentiality, objectivity, and anonymity
All those who receive and follow up on alerts are subject to a special duty of confidentiality. Investigation of alerts is carried out with due regard for independence, confidentiality, data protection and security.
Envidan and PwC will treat all information about the identity of the whistleblower and persons concerned as confidential to the greatest extent possible. Whistleblowers have the right to remain anonymous.
Protection of whistleblowers
Envidan does not allow any form of retaliation or harassment against whistleblowers.
A whistleblower who reports a reasonable suspicion through the whistleblowing scheme in good faith will not face retaliation or negative consequences, including employment law consequences, even if the report is later found to be unfounded.
Create your report here
If you make a report from your work computer and while on our network via the above link to the scheme, please be aware that this will be recorded as part of the regular logging of user activities on our network.
If you wish to remain anonymous, do not report from your work computer. Instead, you should access the whistleblowing scheme by entering the following web address from your private PC or a public computer not connected to our network:
Alternatively, you can use our QR code to report via your phone or tablet. Please note that you must not be connected to the WIFI network when submitting your report.