Guideline for the whistleblower scheme at DTU

Background and purpose

For DTU, credibility is an essential value, and DTU wishes to promote a culture of trust and respect across the organization. This implies that people are able to express themselves freely, without fear of negative reactions or reprisals if they experience irregularities or unlawful activities in connection with their work at DTU or in their collaboration with DTU.

To make sure that people have access to confidential reporting of issues and conduct of a more serious nature, DTU has introduced a whistleblower scheme.

The purpose of the whistleblower scheme is:

to ensure openness and transparency in connection with infringements and serious offences taking place at DTU,
to protect employees and collaborators submitting reports through the scheme,
and to ensure that the submitted reports are used constructively to improve, prevent and avoid malpractice and unlawful activities in the administration and operation of DTU.

Who can submit a report?

All employees at DTU and all DTU's external collaborators and persons employed with external collaborators.

What can be reported?

The whistleblower scheme aims at revealing serious offences about which the whistleblower has knowledge or suspicion.

Serious offences may include:

Criminal offences, such as financial abuse, theft, fraud, embezzlement, bribery, infringement of professional secrecy, etc.

Other kinds of infringements, e.g. of the Danish public administration act, the data protection legislation, the Danish access to public administrative documents act or other relevant legislation.

Serious or repeated breaches of important internal guidelines such as guidelines and policies on business travels, gifts, conflict of interest, accounting, etc.

Serious person-related episodes in the workplace, such as severe bullying and harassment, violence, physical and sexual abuses and the like.

Matters of a ”less” serious nature such as cooperation difficulties, incompetency, breach of less essential internal guidelines on for instance sickness absence, smoking, alcohol abuse, use of stationery, dress code, etc. are not included in the whistleblower scheme. As previously, this type of matters is handled in dialogue with the immediate superior, the HR department or the union representative.

False or misleading information must not deliberately be submitted through the whistleblower scheme. Information submitted in bad faith may result in the case being reported to the police, and it may have employment or contractual consequences for the person who submitted the report.

How to report?

To be able to handle a report correctly and efficiently, it is important that the report contains all essential information and facts, such as:

What does the matter concern?
Who are involved in the offence described in the report?
Where and when did the offence take place/takes place?
How big are the values comprised by the offence?
How has the reporter obtained the information?

If you want to submit a report, you can use this form.

In case of a situation in which not all information is available, it is important that you do not start an investigation yourself. It is better to report a matter through the whistleblower scheme based on a less secure basis than to destroy possible proofs.

You can submit a report to the whistleblower scheme in the following ways:

By e-mail to: wbdtu@dtu.dk

By telephone: 93 51 00 01

By letter: DTU
Anker Engelundvej 1
DK-2800 Lyngby.
Att. : JESHER personal/confidential

May you submit an anonymous report?

The reports may be submitted anonymously, but it is however a good idea to provide name and other contact details. In this way, it is possible to get in touch with the reporter if further information is needed.

In addition, investigations based on anonymous reports may give rise to troubles, e.g. if a witness statement from the whistleblower can be decisive for the correct handling of the matter. As a rule, DTU cannot rely on anonymous information as part of a decision, e.g. regarding an employee. This may result in a report about unlawful activities etc. being dropped without getting to the bottom of the matter. We therefore urge you not to submit an anonymous report.

DTU protects the persons who make use of the whistleblower scheme, and in case they are subject to reprisals for using the scheme, it will be reported to DTU's HR department that will take the appropriate steps.

How is a report handled?

When DTU receives a report, an acknowledgement of receipt is sent to the reporter as soon as possible and not later than 7 days upon receipt.

Furthermore, a preliminary evaluation is made to establish whether there is basis for a more thorough processing of the report or whether it should be rejected, e.g. if it concerns a matter or has been submitted by a person that are not comprised by DTU's whistleblower scheme.

If the report does not concern the above-mentioned serious offences that fall within the scope of the scheme, the reporter may alternatively be told to contact his/her immediate superior, union representative or DTU's HR department.

If the report falls within the scope of the scheme, and there is ground for a case handling, a more detailed investigation of the offence is initiated.

If the investigation reveals critical aspects, several courses of action are available:

If the offence concerns a violation of the penal code, it may be reported to the police.
If the matter concerns severe cases of maladministration committed by an employee (or employees) at DTU, it may have employment consequences, including disciplinary sanctions such as warning or dismissal.
If the matter concerns severe cases of maladministration to which an external collaborator has contributed, it may result in contractual consequences for the collaborator, e.g. notice or cancellation of a contract.

In principle, reporters will be informed about the handling of the case and the possible result not later than three months after the reporting.

In case of reports about more complex matters, the notification deadline can be extended to six months. In certain cases, the notification can be restricted due to rules on confidentiality, etc.

Who handles the report?

Reports submitted to DTU are received by DTU's General Counsel who in this connection refers directly to DTU’s President.

All reports are handled by DTU's General Counsel with the exception of the following:

Reports concerning DTU’s Executive Board are handled by DTU's Board of Governors.

Reports concerning DTU’s Board of Governors are handled by an external lawyer.

Reports concerning DTU’s General Counsel and his/her immediate superior are handled by DTU's University Director.

Information of the person(s) concerned by the report

The person(s) (in the following referred to in the singular form) concerned by a report will normally be informed, if information is submitted about him/her in a report. The reported person will thus be informed, if the case is dropped because it turns out to be overtly unfounded. The reported person will be involved, if it is decided to initiate an investigation of the matter.

In each individual case, it will be evaluated when this information can be provided so that it does not affect the investigation of the reported offence and the collection of evidence.

According to the applicable rules on access to documents, there will also be access to the name of the person who submitted the information, if the reporting was not made anonymously. This will give the person or persons reported the right to know who submitted the report with the information.

In addition to the above, the general rules on deletion apply. If the collected information results in a disciplinary sanction of the employee, or there are valid and necessary grounds to keep the information about the employee, the information will be stored in the personnel file of the employee in question.