THE WHISTLEBLOWER SCHEME

THE WHISTLEBLOWER SCHEME

THE WHISTLEBLOWER SCHEME AT DE 5 STJERNER A/S

THE WHISTLEBLOWER SCHEME AT DE 5 STJERNER A/S

Employees can use the whistleblower scheme at De 5 Stjerner A/S to submit reports on serious breaches of law such as theft, bribery and fraud as well as harassment, violence and other serious matters which you become aware of in connection with your job. You can also report certain breaches of EU law.

You CANNOT submit a report anonymously.

It is important that you are familiar with what is covered by the whistleblower scheme. Read therefore the following before submitting a report or you risk that your report will be rejected by our whistleblower unit.

1. Objective of the whistleblower scheme

The objective of the whistleblower scheme at De 5 Stjerner A/S is to establish a safe framework for our employees. Our employees will be able to use the whistleblower scheme to report unacceptable conditions at the workplace without fear of retaliation or reprisal.

The whistleblower scheme will help identify serious matters in the workplace so we avoid similar serious situations/incidents in the future, as far as possible.

You can use the whistleblower scheme at De 5 Stjerner A/S to report certain breaches of EU law, serious offences and other serious matters that you become aware of in connection with your job.

Reports to the whistleblower scheme at De 5 Stjerner A/S can be submitted digitally by going to “SUBMIT A REPORT” below or click “Submit here” in the headings to the right.

You can also submit a report to the Danish Data Protection Agency’s external whistleblower scheme via their website: www.datatilsynet.dk.

However, we recommend that you primarily use the whistleblower scheme at De 5 Stjerner A/S. Our knowledge of the workplace, local conditions and specific guidelines and instructions means that we will be able to manage reports from our employees and any investigations that need to be launched objectively and effectively.

2. Who can use the whistleblower scheme?

  • Employees at De 5 Stjerner A/S. This includes salaried or unpaid interns, substitutes and volunteers.

3. What is reportable?

The whistleblower scheme at De 5 Stjerner A/S is covered by the Whistleblower Protection Act (Act No. 1436 of 29/06/2021) (whistleblowerloven) and you may therefore only submit reports on the following:

    • Serious breaches and other serious matters
      These breaches and matters include i.a.:

      • Serious breaches of the Criminal Code, for example criminal offences, including the misuse of funds, theft, fraud, embezzlement and corruption.
      • Serious breaches of other legislation, for example breaches of tax legislation, breaches of a duty of confidentiality, any breaches of the Danish Bookkeeping Act and workplace safety and health regulations.
      • Harassment, i.a. sexual harassment (see section 1(4), see subsection (6) of the Act on Equal Treatment of Men and Women) or severe harassment on the grounds of race, gender, language, financial circumstances, nationality or social origin, political or religious beliefs (see section 1 of the Differential Treatment Act) or violence.
      • Other serious conditions, such as breaches of professional standards that could pose a risk to the safety and health of other people, serious errors and serious irregularities connected to IT operations and IT system management, and serious and/or repeated breaches of internal regulations and compliance provisions.

    • Certain breaches of EU law
      These breaches include i.a:

      • Breaches concerning regulations on public procurement, environmental protection, protection of privacy and personal data, as well as the security of network and information systems.

For more information regarding the breaches mentioned above, see Directive (EU) 2019/1937, October 23, 2019, of the European Parliament and of the Council on the protection of persons who report breaches of Union law.

What is NOT reportable?

For example, you cannot report the following:

  • Information of a less serious nature, including information on breaches of internal guidelines on smoking, alcohol, dress, absenteeism due to sickness, and private use of office stationery.
  • Information on the terms and conditions of employment of yourself or others, including conflicts between colleagues, collaboration issues or conditions that fall under the labour legislation system, unless it is a matter of sexual harassment or other form of severe harassment.


Contact your immediate supervisor or the HR department if you experience any of the above.

4. How do you to submit a report via the whistleblower scheme?

You can submit a report digitally by going to “SUBMIT A REPORT” below or click “Submit here” in the headings to the right. Complete the form, including a description of the matter you are reporting, as well as the date(s) and name(s) of the person(s) involved. Then click “Send”.

5. What will happen next?

Reports submitted are encrypted and secure.

Reports are forwarded to our whistleblower unit. The unit is headed by Patricia Schjøth Hansen, human resource manager, psh@de5stjerner.dk, mobile phone: +45 28 51 55 92. Patricia knows the company very well, including its employees, and she will be able to objectively and efficiently follow up on the reports submitted by employees.

Reports that fall outside the scope of the whistleblower scheme will be rejected and a reason for the rejection will be provided. The reporting person will be encouraged to contact either their immediate supervisor or the HR department.

Reports that fall within the whistleblower scheme will be processed by the whistleblower unit, and the unit will launch the necessary investigations.

If the results of the investigations show unacceptable conditions, the whistleblower unit can i.a. do the following:

  • If the report raises a criminal offence, it will be reported to the police, or
  • In the event of serious errors and/or irregularities, the report may have consequences for a person’s employment, including termination or expulsion.

You will receive a confirmation of receipt no later than seven days after your report has been received by the whistleblower unit. The whistleblower unit will generally contact you within three months of receipt to follow up on the case. The whistleblower unit will contact you if processing of your report is expected to take longer than three months and will explain why additional time is required. You will receive follow-up from our whistleblower unit on your report and you will be informed of the outcome no later than six months from the date of receipt. After receipt of your report, communication between you (the whistleblower) and our whistleblower unit can take place in the following ways: Digitally via our Planday message system (secure/encrypted), via post, telephone or in person. If you have a pending report, it is important that you follow up on the matter and regularly check the above lines of communication.

6. What protection does the whistleblower have?

De 5 Stjerner A/S will not accept that any whistleblower acting in good faith is subject to reprisals or attempts at reprisals or is in any way prevented or obstructed from submitting a report. Employees who submit a report to the whistleblower scheme at De 5 Stjerner A/S in good faith are protected against reprisals.

Employees (whistleblowers) who deliberately submit reports to the whistleblower scheme with incorrect or misleading information, and thus in bad faith, may be subject to employment-law consequences.

7. Rights of person(s) affected by the report

If you are named in a report submitted to the whistleblower scheme, and our whistleblower unit assesses that the report is covered by the whistleblower scheme at the De 5 Stjerner A/S, you will generally not be informed immediately.

However, if the whistleblower unit assesses that the reported matter falls outside the whistleblower scheme at De 5 Stjerner A/S, you will be notified of the processing of your personal data in accordance with General Data Protection Regulation and your right to request rectification or erasure of incorrect data.

Personal data received in connection with reports submitted via the whistleblower scheme at De 5 Stjerner A/S is stored and deleted in accordance with the GDPR.

8. Duty of confidentiality and disclosure

The whistleblower unit at De 5 Stjerner A/S and the persons informed of the report and involved in the investigations launched in connection with the report, are subject to a specific duty of confidentiality with regard to the information contained in the report.

9. Processing of personal data – data protection

The personal data received in connection with reports submitted via the whistleblower scheme at De 5 Stjerner A/S will be processed in accordance with section 22 of the Whistleblower Act.

The company’s Privacy Policy for Employees contains information about the processing of personal data in connection with reports submitted via the whistleblower scheme at De 5 Stjerner A/S.

The General Data Protection Regulation and the Data Protection Act also apply to the processing of other personal data in relation to the whistleblower scheme.

De 5 Stjerner A/S, Jernholmen 39-41, 2650 Hvidovre (CVR.no.: 25349997) is the data controller for processing your personal data in relation to the company’s whistleblower scheme.

If you have any questions regarding the whistleblower scheme at De 5 Stjerner A/S, you are welcome to contact the head of our whistleblower unit, Patricia Schjøth Hansen, human resource manager at email: psh@de5stjerner.dk or mobile phone:+ 45 28 51 55 92.

SUBMIT A REPORT – WHISTLEBLOWER SCHEME AT DE 5 STJERNER A/S