Whistleblower scheme
We have established a whistleblower scheme. We encourage you to read this before reporting your suspicions or concerns through the scheme.
Who can use the whistleblower scheme?
You can use the whistleblower scheme if you are a current or former employee of the DS Group (“whistleblowers”).
What can you report?
You can use our whistleblower scheme if you have knowledge of, or reasonable grounds to suspect, serious breaches of the law 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 who report breaches of EU law. This may include, for example:
- Criminal offences, such as fraud, embezzlement, misuse of assets, falsification of documents, accounting manipulation, bribery, corruption, money laundering and terrorist financing
- Breaches of competition and procurement rules
- Danger to the health and safety of individuals, including serious or repeated breaches of workplace safety rules
- Serious breaches of environmental regulations and environmental pollution
- Breaches of confidentiality
- Breaches relating to the protection of privacy and personal data
- Serious breaches of the DS Group’s internal guidelines and rules (such as the individual companies’ employee handbooks and guidelines)
- 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, we encourage you to use our whistleblower scheme. The report will then be assessed, and you will be informed whether your report falls within the scope of the whistleblower scheme.
Matters such as difficulties in working relationships, dissatisfaction with pay and minor breaches of internal guidelines concerning sickness absence, smoking, alcohol, the use of office supplies, etc. should not be reported through the whistleblower scheme, but through our normal management structure, i.e. to your immediate manager.
Do not use the whistleblower scheme to report events that pose an immediate threat to life or property. If you require emergency assistance, please contact the public emergency services. We encourage you to use our whistleblower scheme if you have a concern or suspicion regarding serious matters. However, you may also choose to report your suspicion or concern to the external whistleblower schemes established by the authorities.
PwC
Your report is submitted directly to an external third party (PwC Statsautoriseret Revisionspartnerselskab, “PwC”). PwC is an independent audit, tax and advisory firm that receives reports on behalf of DS Gruppen, ensuring an independent channel for you as the reporting person. Your report is subsequently forwarded to DS Gruppen for processing.
PwC conducts an initial assessment to determine whether the report falls within the scope of the whistleblowing scheme and engages in dialogue with whistleblowers if further information is required or if the report gives rise to follow-up questions. PwC will then conduct an impartiality assessment to determine who can handle the report within DS Gruppen. This ensures that the report is handled by an impartial and competent person within DS Gruppen and is not forwarded to anyone directly or indirectly implicated in the report, or where there may be a risk of a conflict of interest.
DS Gruppen’s Group HR Business Partner
DS Gruppen’s Group HR Business Partner is responsible for the whistleblowing scheme throughout DS Gruppen. The Group HR Business Partner is considered particularly competent and independent in this area and is responsible for ensuring that reports are followed up carefully and for assessing what measures need to be implemented based on your report.
You can read more about our whistleblowing scheme in our whistleblowing policy
Download the whistleblowing policy
You can find more information about the allocation of roles and responsibilities in this process overview
Confidentiality and objectivity
Everyone who receives and follows up on reports is subject to a special duty of confidentiality. Reports are investigated with due regard for independence, confidentiality, data protection and security.
DS Gruppen and PwC treat all information concerning the identities of the whistleblower and affected persons as strictly confidential to the greatest extent possible.
Protection of whistleblowers
DS Gruppen does not tolerate any form of retaliation or harassment against whistleblowers. A whistleblower who, in good faith, reports a reasonable suspicion or concern through the whistleblowing scheme will not face retaliation or suffer any adverse consequences, including employment-related consequences, even if the report later proves to be unfounded.
If you submit a report from your work computer while connected to our network, or via the above link to the scheme, please be aware that this will be recorded as part of the routine logging of user activity on our network.
Alternatively, you can use our QR code to submit the report via your phone or tablet. Please note that you must not be connected to the Wi-Fi network when submitting your report:
