Best Western Plus Hotel Eyde’s subsequent BWPHE whistleblower scheme aims to increase the opportunities for BWPHE employees to express themselves about objectionable conditions in the workplace without fear of negative consequences. The purpose of the whistleblower scheme is thus to ensure openness and transparency in relation to any (law) violations and serious irregularities.
The BWPHE whistleblower scheme should be seen as a supplement to the direct and daily communication in the workplace about errors, unsatisfactory conditions, etc. The scheme also supplements existing opportunities e.g. contacting your immediate manager, director, or union representative.
BWPHE encourages the use of the whistleblower scheme so that any violations can be addressed quickly and effectively. However, the whistleblower is free to choose between submitting a report to the workplace’s whistleblower scheme, an external whistleblower scheme, or the Danish Data Protection Agency’s whistleblower scheme.
The BWPHE whistleblower scheme does not exclude the possibility of reporting via external channels such as supervisory authorities.
Reports to the BWPHE whistleblower scheme are processed by:
Poul Müller, Chairman
E-mail: whistleblower.eyde@gmail.com
Questions about the individual reports or the BWPHE whistleblower scheme, in general, can be directed to:
Poul Müller, Chairman
E-mail: whistleblower.eyde@gmail.com
Depending on the content and nature of the report, the processing of reports can also be carried out with the help of an external party, such as a lawyer or accountant.
The whistleblower scheme can be used to report information about serious breaches or other serious matters that cannot necessarily be attributed to a specific (law) violation. Matters that have taken place or will take place can be reported in BWPHE.
A (law) violation or other circumstance will generally be serious if it is in the public interest to bring it to light. Offences of a trivial nature are not covered.
Reports about the whistleblower’s own employment are generally not covered, unless it is a case of sexual harassment or serious harassment.
Information about other matters, including information about breaches of internal guidelines of a less serious nature, such as rules on sick leave, dress code and information about other staff-related conflicts in the workplace, will generally not be considered serious breaches and should therefore not be reported to the BWPHE whistleblower scheme. Such information may be submitted to the immediate manager, director or union representative in accordance with applicable guidelines.
It is assumed that the whistleblower is in good faith about the accuracy of the information.
Annex 1 lists examples of serious offences, serious matters and information that is not covered by the whistleblower scheme.
Reporting to the BWPHE whistleblower scheme must be made by email, at:
Anonymous reports cannot be made.
BWPHE employees
In connection with receipt of a report, the BWPHE Whistleblower Unit will confirm receipt within seven days by email.
The BWPHE whistleblower unit will then carefully follow up on the report. The content and nature of the report are crucial for how follow-up is to be carried out.
The Whistleblower Unit will initially decide whether the report falls within the scope of the whistleblower scheme. If the report falls outside the scope of the whistleblower scheme or is manifestly unfounded, the report will be rejected. The whistleblower will be notified.
If the report falls within the scope of the whistleblower scheme, the report will be processed. This means, among other things, that the BWPHE whistleblower unit, depending on the content and nature of the report, will obtain additional information internally in the organization. Depending on the circumstances, it may also involve further dialogue with the whistleblower.
Examples of follow-up:
The Whistleblower Unit will provide feedback to the whistleblower within three months of acknowledging receipt of the report. This means that the whistleblower unit, depending on the content and nature of the report, will inform the whistleblower of what measures have been initiated or are intended to be implemented, and why the unit has chosen this follow-up.
If it is not possible to provide feedback within the deadline, the BWPHE whistleblower unit will notify the whistleblower of this and whether any further feedback can be expected. This may be because of an internal investigation has been launched that cannot be completed within the deadline e.g.
The feedback must comply with applicable law, including data protection law. This means, among other things, that there must be a basis for disclosure to be able to disclose sensitive information. It depends on a specific assessment, which information can be provided in the follow-up to the whistleblower.
Employees who are affiliated with the BWPHE whistleblower unit have a special duty of confidentiality in relation to the information included in the reports.
The duty of confidentiality only applies to information that is included in the report. If a report gives rise to the initiation of a case, the other information collected in this connection will not be covered by the duty of confidentiality.
The BWPHE whistleblower unit treats reports confidentially to the greatest extent possible.
Information from a report is processed in accordance with the processing rules in section 22 of the Whistleblower Act and in the General Data Protection Regulation and -Act. Pursuant to section 22 of the Whistleblower Act, the BWPHE Whistleblower Unit may process personal data, including sensitive information and information about criminal offences, if this is necessary in order to process a report received in connection with the BWPHE Whistleblower Scheme.
Information from a report may be disclosed depending on the circumstances, e.g. for the purpose of following up on the reports. The whistleblower will be notified prior to disclosing information about the whistleblower’s identity, unless it would jeopardize a related investigation or legal proceedings. This may be the case, for example, if such notification is specifically assessed to entail a risk that evidence will be hidden or destroyed, that witnesses will be influenced, or if there is a suspicion that the whistleblower has deliberately submitted false reports.
A whistleblower must not be subjected to reprisals, including threats or attempts at reprisals, because he or she has made a report to the BWPHE whistleblower unit or an external whistleblower scheme (the Danish Data Protection Agency). Furthermore, the whistleblower must not be prevented or attempted to be prevented from making reports.
Retaliation is understood as any form of unfavorable treatment or adverse consequence in response to an internal or external report which causes or may cause harm to the whistleblower.
The whistleblower cannot be held liable for reporting confidential information if he or she has reasonable grounds to believe (good faith) that the information in a report is necessary to reveal a serious offence or a serious matter.
Attempts by BWPHE employees or management to prevent a whistleblower from making a report or to exercise reprisals against a whistleblower who has reported in good faith will result in employment law consequences.
The Ministry of Justice has prepared a guide for people who wish to submit or are considering submitting information as a whistleblower. The guidelines provide an overall description of the Whistleblower Act, including descriptions of whistleblower schemes and reporting options. The whistleblower’s rights and protection of whistleblowers. The guidelines can be downloaded from the Ministry of Justice’s website www.jm.dk.
Offences offences that will generally be covered by the scope of the penal code:
Infringements of specific legislation or other legislation that would generally fall within the scope of application:
Harassment
Matters that are generally considered serious:
Examples of information that is not covered by the scope of the Act:
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