Whistleblower Scheme

Whistleblower Scheme for Team Rynkeby Fonden

The purpose of Team Rynkeby Fonden’s whistleblower scheme is:

to increase the opportunity for participants, employees and business partners to express themselves about violations of the law and other serious matters in Team Rynkeby,
to protect participants, employees and business partners who submit information to the whistleblower scheme in good faith, and
to detect and prevent serious or repeated violations of internal guidelines.

The whistleblower scheme is a supplement to the direct and daily communication within the team, between the teams and in collaboration with Team Rynkeby Fonden, as well as internally at the workplace and in general in the project. As a starting point, please try to solve the situation through cooperation with the Team Manager/Steering Group and the Country Manager or with the immediate manager, if possible.

A voluntary whistleblower scheme

The whistleblower scheme is voluntary, which means Team Rynkeby Fonden has chosen to establish the Whistleblower Scheme, even though Team Rynkeby Fonden is not obliged to do so under the Act on the Protection of Whistleblowers ("The Whistleblower Act").

A voluntary whistleblower scheme differs in several aspects from the statutory whistleblower scheme. Reports must, among other things, not contain so-called "sensitive personal data", and whistleblowers are not covered by the Whistleblower Act's protection against reprisals when a report is made. If you are employed by Team Rynkeby Fonden, we instead guarantee you equivalent protection as part of your employment.

You can read more about how you are protected when you report via the whistleblower scheme below.

The scheme can be used by all participants in the project, employees, collaborators and employees of collaborators to, in good faith, report about observed or suspected serious or repeated offenses or other serious matters at Team Rynkeby.

Reports must be submitted in good faith and relate to serious or repeated offenses or other serious matters that may have an impact on Team Rynkeby as a whole, or that may have a decisive impact on the life or health of individuals, for example:

criminal offences, including breach of confidentiality, misuse of funds, theft, fraud, embezzlement, deception and bribery,
serious or repeated violations of the law,
serious or repeated violations of internal guidelines,
serious personal conflicts in the workplace. For example, serious harassment, including any form of sexual harassment, and
deliberate misleading of management, employees and business partners,
misuse of collected funds, benefits made available for the project or other behaviour for personal gain.

The scheme does not cover reports regarding other conditions, for example:

relations of other companies,
information about minor violations of internal guidelines,
information about less serious personnel-related conflicts in the team or on the workplace, such as difficulties in working together, minor disagreements and a lack of trust between the participants, employees or managers.

We draw particular attention to the fact that reports must not contain sensitive personal data. This is because the whistleblower scheme is not covered by the Whistleblower Act.

Sensitive personal data is information about racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership as well as processing of genetic data, health information or information about a physical person's sex life or sexual orientation, Article 9(1) of the General Data Protection Regulation.

All reports are taken seriously, and Team Rynkeby Fonden has appointed an internal whistleblower person who screens all reports, evaluating whether they are covered by the whistleblower scheme and whether the report should be investigated further.

The internal whistleblower person in the Team Rynkeby Foundation is director Solvejg Lauridsen. If the report concerns the whistleblower person, then contact must be made to Peter Frank Andersen, vice chairman of the board of the Team Rynkeby Foundation.

When a report has been received, the internal whistleblower person screens the report. If the internal whistleblower person finds that the report falls within the framework of the whistleblower scheme, the internal whistleblower person decides whether the report should be investigated further.

When the report has been examined in more detail, a decision will be made on follow-up to the investigation.

Whistleblowers will be informed about the processing of the case and any outcome via the secured and anonymous mailbox. However, how much or how little information can be provided depends on the specific case and may be limited for reasons of privacy or for efficient processing of the report, etc.

The identity of whistleblowers, if disclosed, as well as other information in a report, may be passed on to relevant public authorities without the whistleblower's consent. However, whistleblowers will be notified prior to such disclosure, unless it is deemed to jeopardize a related investigation or legal proceeding.

Data subjects can exercise their rights in accordance with Chapter III of the Data Protection Regulation, however with the limitations that follow from the legislation, including for example the interest of Team Rynkeby in effectively processing reports, including uncovering and solving criminal matters, cf. the Data Protection Regulation, article 14(5)(b) and the Data Protection Act § 22(1).

We draw particular attention to the fact that whistleblowers are not covered by the Whistleblower Act's protection against reprisals when reporting. Employees of Team Rynkeby Fonden who contribute to the whistleblower scheme by conducting investigations or providing information will, however, be ensured, as far as possible, equivalent protection against reprisals.

Externals who report in good faith are not protected from retaliation. However, we generally treat personal data confidentially, including information about identity if it is known.

If whistleblowers have provided information in bad faith, this may result in a police report, exclusion from the team/Team Rynkeby, as well as negative employment law consequences (for employees at Team Rynkeby Fonden) or contractual consequences for the collaboration (for external partners).

All information will be kept confidential to the greatest extent possible. The whistleblower has the option of remaining anonymous and the dialogue will take place via a secured and anonymous mailbox.

However, we recommend that whistleblowers disclose their identity when reporting, as this gives us the best conditions for investigating the report.

The whistleblower will be informed about the processing of the case and any outcome via the secured and anonymous mailbox. The whistleblower is protected against negative employment law consequences associated with the report if the report is submitted in good faith. If the whistleblower has provided information in bad faith, this may result in a police report, exclusion from the team/Team Rynkeby, as well as negative employment law consequences (for employees) or contractual consequences for the collaboration (for external partners).

to maintain this policy,
to carry out investigations on the basis of reports received
to take necessary measures (including employment law consequences)
to report to relevant authorities in the event of an offence
to use external assistance, if necessary, to ensure anonymity vis-à-vis the reporting party
that the data protection regulation (GDPR) is complied with

You will find the Team Rynkeby Fonden reporting page here:

https://app.sibilum.com/radserver/emsserver.dll/PUBWBsite/Team-Rynkeby