Whistleblowing: Best practice for etablering af whistleblower-ordninger i Danmark

Snezana Janjic & Mia Hofgart Serup

Student thesis: Master thesis


This thesis aims to explore knowledge about whistleblowing in order to define a best practice for establishing effective whistleblowing schemes in Denmark. Studies show that there has been an increase in the number of detected cases of fraud in the past 10 years. In 2012, 43% of all known cases were detected through whistleblowing, why companies increasingly use whistleblowing schemes to prevent and detect fraud. Also in Denmark there is a growing trend for the use of whistleblowing. Since whistleblowing is a relatively new phenomenon in Denmark we have seen a need for developing a best practice, Danish companies can use when implementing a whistleblower scheme. We have reviewed relevant literature and studies in this area in order to determine how whistleblowing is defined, what whistleblower systems will usually contain, including the scope of the scheme, and what it takes to design an effective whistleblower system. In order to determine the legal framework, we have clarified the relevant regulations in the U.S., the EU and in Denmark. In addition, five large Danish companies have been interviewed in order to explain their use of whistleblowing. On the basis of this knowledge a best practice has been organized. A questionnaire has been sent out to Danish employees in GN Store Nord, to examine the employee’s knowledge and opinion on the whistleblowing scheme. GN’s coming whistleblower scheme was then compared with best practice and the results from the questionnaire in order to evaluate the schemes' design and the way the company will implement this. When designing a whistleblowing scheme organizations have to consider three components; scope, process and regulation. When defining the scope, it should be considered, who is entitled to file a report and whom the report may concern, whether the scheme should be handled only internally or an external provider of hotlines can be used. Further it should be considered whether it should be possible to file an anonymous report, and what measures the company will take to provide protection of the whistleblower. The company should clarify what regulation and law that is applicable for them. The US regulation under SOX requires that public stated companies in the US implement whistleblowerschemes, which allow anonymous reporting. The Danish data protection law requires that information processed in the scheme, will be handled confidential. Further all whistleblower-schemes should be approved by the Danish data authorities. The study of Danish companies’ whistleblower schemes reveals that the primary reason for implementing the whistleblower scheme, was because of the value it will signal, facing their business partners. Further the implemented scheme was in many cases not effectively securing the whistleblowers anonymity. The questionnaire in GN revealed that the knowledge of the current whistleblower scheme was relatively high, considering the company’s limited communication. GN Store Nord’s coming whistleblower scheme is designed in accordance with best practice.

EducationsMSc in Auditing, (Graduate Programme) Final Thesis
Publication date2013
Number of pages120