WHISTLE- BLOWER SCHEME
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WHISTLE- BLOWER SCHEME
Transcript of WHISTLE- BLOWER SCHEME
WHISTLE-BLOWER SCHEME
WHISTLE-BLOWER SCHEME
REPORTING OF POSSIBLE IRREGULARITIES IN THE DANISH INSTITUTE FOR HUMAN RIGHTS’ NATIONAL AND INTERNATIONAL ACTIVITIES
INTRODUCTION
The Danish Institute for Human Rights is an independent institution within the
Danish government sector. The institute is therefore subject to the legislation
that applies to Danish public administration, including the Danish Public
Administration Act, the Danish Open Administration Act and the Danish Act on
State Accounting. The institute’s activities are also regulated by internal and
external demands, including demands from various donors.
The board of the Danish Institute for Human Rights, the department of the
Ministry of Foreign Affairs of Denmark and the National Audit Office of Denmark
oversee that the institute meets its obligations. Ernst & Young acts as the
institute’s auditor.
The institute strives to ensure that all of its activities meet present-day demands of financial accountability, anti-corruption, good administrative behaviour and openness. Staff, collaborators and other actors must be able to express criticism to ensure that cases of maladministration are identified.
The objective behind the institute’s whistle-blower scheme is thus to render clear the various available opportunities for internal and external actors to report serious irregularities.1
WHAT DOES THE SCHEME COMPRISE? Via the whistle-blower scheme the institute wishes to receive reports of serious incidents such as criminal offences, serious or persistent breaches of legislation or essential rules, breaches of contract, deliberate misrepresentation and sexual abuse etc.
Less serious incidents such as dissatisfaction with the work of the institute,
wages, collaboration difficulties etc. are handled by and reported to the day-to-
1 The institute has drawn inspiration from the Ministry of Foreign Affairs of Denmark’s guide to handling reports of and enquiries into possible irregularities from May 2017.
day management, the cooperation committee, employee representatives or
similar.
TO WHOM SHOULD REPORTS BE SUBMITTED? Reports can be made to a person of your choice. If you wish to report an incident
to the institute, you should contact one of the following persons:
TITLE PERSON MAIL PHONE NO. Chairman Dorthe Elise Svinth [email protected] +45 6148 2898
Executive Director Louise Holck [email protected] +45 5093 3960
Department Director Ann Lisbeth Ingerslev [email protected] +45 3269 8891
Chief Legal Adviser Lise Garkier Hendriksen [email protected] +45 9132 5775
In most cases, reports of suspicions of irregularities should naturally be made
directly to the institute.
If you do not wish to submit your report directly to the institute, it may – depending on the nature of the case – be relevant to contact external
authorities:
AUTHORITY MAIL PHONE NO. National Audit Office of Denmark [email protected] +45 3392 8400
Ministry of Foreign Affairs of Denmark [email protected] +45 3392 0000
Danida’s anti-corruption programme [email protected] +45 3392 0000
Danish police [email protected] +45 3314 1448
Foreign police [depends on country] [depends on country]
In case of suspicion of misuse of funds from another donor, a report should be made to the donor in question.
CAN I BE ANONYMOUS? Reports can be made anonymously. However, anonymity may weaken a report,
as it can be difficult to use anonymous information in a concrete case.
If you wish to be anonymous, you must remember never to reveal your identity, as the one who receives the report is obligated to record all relevant
information, including the name of the person submitting the report.
If a member of staff has recorded the name of the person submitting the report if can as a rule not be deleted. Subsequent access to documents will thus reveal
the identity of the person.
It is therefore important to make it clear from the start that you wish to remain anonymous. You can always choose to reveal your identity at a later point.
INVESTIGATION PROCED URE
REPORTING
The report must as far as possible describe all facts – including factors that are
considered unimportant. The report must as far as possible provide documentation of the claim that is being made. Any written documentation in
the form of documents or similar should be submitted. The report may e.g. contain the following:
• Information about the person/department which the report concerns
• Brief description of the alleged irregularities
• Brief description of concrete observations (with documentation, if possible)
• Contact information
INVESTIGATION
The Danish Institute of Human Rights will investigate all cases of violations made by institute staff or collaborators of the rules that apply to the work of the
institute.
The institute has a duty to investigate cases where there is a fair, factual basis for suspecting staff or collaborators of especially serious, topical irregularities, which
make it relevant to launch an investigation.
According to the institute’s anti-corruption policy, the institute has zero tolerance for corruption of any kind. Reports of breaches of this policy will
therefore always result in an investigation.
The chairman of the board is informed of all reports received by the institute.
INVESTIGATION PROCES S
Typically, the investigation process is as follows:
MORE INFORMATION You can get more information and advice by contacting either the chairman of
the board, the executive director, the department director or the chief legal adviser. See contact information above.
REPORT IS RECEIVED
• The report is received, and the day-to-day management decides how the case should be investigated
• The chairman of the board and the accused is informed of the report and the decision
INVESTIGATION IS PREPARED
• The management prepares an investigation (e.g. by checking supporting documents etc.)
• The National Audit Office of Denmark is informed, where necessary (in so-called 'C cases')
INVESTIGATION IS CONDUCTED
• The management conducts a thorough investigation
• Staff and collaborators are involved, where necessary
• In special cases the case is assigned to an external auditor, lawyer or similar
CASES IS COMPLETED
• A memo is written, completing the investigation
• The person who submitted the report, the chairman of the board and, where relevant, authorities are informed
• In case of suspicion of a criminal offence, a police report is made
