Whistleblower scheme

DS Gruppen’s whistleblower scheme is an important element in detecting corrupt, illegal or other unethical conduct. We encourage you to read this before reporting your suspicion or concern.

Who can submit a report?

You can submit a report if you are a current or former employee of DS Gruppen.

What can be reported?

You can make a report through the whistleblower scheme if you have knowledge or suspicion of breaches of applicable laws and regulations and other serious matters, including breaches of EU law as set forth in the Directive of the European Parliament and of the Council on the protection of persons who report breaches of Union law. This includes, but is not limited to, the following:

  • Criminal offences, including fraud, embezzlement, misuse of assets, forgery of documents, accounting manipulation, bribery, corruption, money laundering and terrorist financing
  • Competition law breaches and public procurement law breaches
  • Serious or repeated breaches of occupational health and safety legislation
  • Breaches of environmental regulations and laws on the prevention of the environment pollution
  • Breach of professional secrecy
  • Breach of protection of privacy and personal data
  • Serious breaches of internal rules and guidelines in DS Gruppen (e.g. the employee handbooks of the individual companies under DS Gruppen)
  • Discrimination, severe bullying, severe harassment, physical violence, threats and sexual abuse

The above are only examples. If you are in doubt as to whether or not 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 receive feedback on whether your report is covered by the whistleblower scheme.

Other matters, minor breaches of internal guidelines, complaints about other employees’ behavior or incompetencies, including information on less serious workplace conflicts and disagreements are not covered by the scope of whistleblower scheme. These types of matters must be raised in a dialogue with an immediate manager.

You are encouraged to report any real or suspected breaches of the law through this internal whistleblower scheme. While whistleblowers are encouraged to report through the DS Gruppen whistleblower reporting scheme, they may also decide to use the external whistleblowing reporting schemes set up by the authorities.


If you decide to use DS Gruppen’s whistleblower scheme to report your concern, your report is received by an external third party (PwC Statsautoriseret Revisionspartnerselskab ”PwC”). PwC is an independent audit, tax and advisory firm, which receives reports on behalf of DS Gruppen to ensure an independent channel for you to report your concerns. After a preliminary review, the reports will be forwarded for further processing in DS Gruppen.

PwC initially assesses whether the whistleblower report falls within the scope of the whistleblower scheme. If the whistleblower report does not have a sufficient level of information, PwC will try to obtain more relevant information from the whistleblower, if possible. PwC forwards all whistleblower reports to DS Gruppen after having evaluated who can handle the whistleblower report to ensure that the whistleblower report can be handled by an impartial and competent person, and is not forwarded to a person whom the whistleblower report relates to either directly or indirectly, or where there may be another risk of conflict of interest.

The CFO of DS Gruppen

The CFO of DS Gruppen is the overall responsible for the whistleblower scheme for the entirety of DS Gruppen. The CFO of Gruppen is responsible for proper management of the whistleblower scheme and diligent follow-up on whistleblower reports. The CFO of Gruppen is responsible for deciding whether investigations of whistleblower reports shall be conducted and for ensuring that whistleblower reports are handled in compliance with applicable rules and DS Gruppen’s whistleblower policy. 

Reference is made to our whistleblower policy

Download the policy 

Reference is also made to our overview of roles and responsibilities

Download flow chart


A special duty of confidentiality applies to those who handle and investigate reports. All investigations of whistleblower reports are carried out with due respect for maintaining and ensuring independence, confidentiality, data protection and data security. DS Gruppen and PwC will keep information about the identity of the whistleblower and any persons
mentioned in the whistleblower reports confidential to the greatest possible extent.

Whistleblower protection

DS Gruppen does not tolerate harassment or retaliation against whistleblowers.

No whistleblower will be victimized for raising a matter through the whistleblower scheme as long as the whistleblower has raised a legitimate concern in good faith. Employees who in good faith make a report will not be subject to negative consequences, including consequences of an employment law nature, even if the report proves to be unfounded.

Submit a report

If you make a report from your workplace computer, while you are on our network, or via the above link, you should know that this will be registered as part of the general logging of user activities on our network.

Alternatively, you can use the QR code below to make a report via your phone or tablet. Please note, that you must not be connected to our Wi-Fi network when making your report:

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