Anyone who becomes aware of misconduct in a work-related context is encouraged to report it. This includes current and former employees, temporary workers, contractors, interns, trainees, job applicants, suppliers, and business partners.

The whistleblower mechanism is intended for serious breaches such as violations of Danish or EU law, criminal offences, corruption, fraud, harassment, discrimination, health and safety violations, environmental breaches, data protection or IT security issues, or the deliberate concealment of such misconduct. It is not intended for minor internal issues, such as disputes between colleagues, dress code violations, or general dissatisfaction with management. These should be handled through normal channels, such as your manager or HR.

All reports are handled with strict confidentiality. Only designated case handler(s) have access to the reports, and any information that could reveal the whistleblower’s identity will not be shared with anyone who does not have a legitimate need to know.

All staff involved in handling whistleblower reports are bound by a special duty of confidentiality. The identity of the whistleblower may only be disclosed in limited situations: with the whistleblower’s consent, to comply with legal obligations, or to ensure individuals named in the report can defend themselves. Unauthorized disclosure is punishable under Danish law.

Upon receiving a report, the whistleblower handler will acknowledge receipt within seven days and conduct an initial screening to determine whether the report falls within the scope of the whistleblower scheme. Reports outside the scope will be communicated to the whistleblower. Relevant reports will be investigated either by the handler or, if necessary, by a qualified person appointed to assist. In all cases, the whistleblower’s identity will remain confidential unless disclosure is strictly necessary and limited to individuals with a legitimate need to know. Findings are documented, and substantiated cases are shared with management or HR for further assessment. The handler does not make disciplinary decisions but ensures proper case handling.

Whistleblowers who submit reports in good faith are protected from retaliation. This includes protection against suspension, dismissal, demotion, transfer of duties, pay reduction, denial of training, and negative performance assessments. Whistleblowers are also protected when disclosing confidential information if it is reasonably necessary to report serious misconduct. Submitting false or intentionally misleading information, however, is not protected.

Individuals named in a report have the right to be informed about the processing of their personal data, though notification may be delayed if immediate disclosure would impede the investigation. They also have the right to request correction, deletion, or restriction of personal data, and to provide a response to any allegations. If the investigation concludes that a report is clearly unfounded, the person named will be informed.

BWO has appointed designated handler(s) to receive, assess, and handle whistleblower reports confidentially and independently.