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POMPdeLUX's whistleblower policy

According to Danish legislation, it has been decided that private workplaces must introduce whistleblower schemes.

The purpose of POMPdeLUX's whistleblower scheme is to increase the opportunities for POMPdeLUX's employees, customers, and other partners to speak out about critical issues in the workplace without fearing negative consequences.

POMPdeLUX's whistleblower scheme can be used to report information about serious violations or other serious matters that may not necessarily be attributed to a specific legal violation.

The purpose of the whistleblower scheme is thus to ensure openness and transparency regarding any (legal) violations and serious irregularities.

POMPdeLUX's whistleblower scheme should be seen as a supplement to the direct and daily communication in the workplace concerning errors and unsatisfactory conditions, etc., where inquiries can be made to the nearest manager or HR. You are encouraged to address matters that do not involve illegalities or serious irregularities with the person or persons whom you believe are acting incorrectly before escalating a case, which should then be directed to your manager, HR, or employee representative if necessary.

Minor violations are not covered and should instead be discussed with HR or the nearest manager.

Reports regarding the whistleblower's own employment conditions are generally not covered, unless it involves sexual harassment or severe harassment.

Reports can be made about incidents that have occurred or will occur at POMPdeLUX, and it is assumed that the whistleblower is acting in good faith regarding the accuracy of the information.

We encourage anyone with serious concerns they wish to report to use our whistleblower scheme so that any violations can be addressed quickly and effectively internally. However, the whistleblower is free to choose between submitting a report to the workplace's whistleblower scheme or an external whistleblower scheme (Data Protection Agency).

POMPdeLUX's whistleblower scheme does not exclude the possibility of reporting through external channels such as regulatory authorities.

POMPDELUX whistleblower unit
Reports to POMPdeLUX's whistleblower scheme are handled by HR – Lotte Brændstrup. Questions regarding individual reports or POMPdeLUX's whistleblower scheme in general can be directed to the same person.

Reports can be sent to the email address whistleblower@pompdelux.dk

Questions regarding individual reports or POMPdeLUX's whistleblower scheme in general can be directed to:

Lotte Brændstrup, HR, email - Lbr@pompdelux.dk

Gitte Panayotis Diakovasilis, COO, email – gp@pompdelux.dk

The processing of reports may, depending on the content and nature of the report, involve assistance from an external party, such as a lawyer or auditor.

In Appendix 1, examples of serious legal violations, serious matters, and information not covered by the whistleblower scheme are provided.

Reporting violations
Reporting to POMPdeLUX's whistleblower scheme can be done personally as well as in writing (email address whistleblower@pompdelux.dk) to HR or the nearest manager, for example, if the inquiries concern HR. Inquiries can also be made anonymously (use the mailboxes located at the entrance to the toilets).

Person groups eligible to provide information to the whistleblower scheme
All employees, management, suppliers, customers, and other partners can provide information to the whistleblower scheme.

Handling of reports
Upon receiving a report, POMPdeLUX's whistleblower unit will confirm receipt to the respective whistleblower via email (secure mail) within seven days, except for anonymous inquiries.

Subsequently, the whistleblower unit will carefully follow up on the report; its content and nature are crucial for determining the appropriate course of action. Initially, a decision will be made regarding whether the report falls within the scope of the whistleblower scheme. If the report falls outside the scope or is evidently unfounded, it will be rejected, and named whistleblowers will be informed accordingly.

If the report falls within the scope of the law, it will be processed. This may involve, among other things, the whistleblower unit gathering further information internally within the organization, depending on the content and nature of the report. Under certain circumstances, it may also involve further dialogue with the whistleblower.

Examples of follow-up actions include:

  • Initiating an internal investigation within the company.
  • Informing the company's management.
  • Reporting to the police or relevant regulatory authority.
  • Closing a case due to lack of or insufficient evidence.

Within three months of confirming receipt of the report, the whistleblower unit will provide feedback to the whistleblower. This means that depending on the content and nature of the report, the whistleblower unit will inform the whistleblower about the measures that have been taken or are planned to be taken and why the unit has chosen this follow-up.

If it is not possible to provide feedback within the deadline, POMPdeLUX's whistleblower unit will notify the whistleblower accordingly and whether further feedback can be expected. This may be due, for example, to the initiation of an internal investigation that cannot be completed within the deadline.

The feedback must comply with applicable laws, including data protection legislation. This means, among other things, that there must be a legal basis for disclosing sensitive information. The specific information that can be provided in the follow-up to the whistleblower depends on a concrete assessment.

Confidentiality and handling of information
Employees associated with POMPdeLUX's whistleblower unit are subject to a special duty of confidentiality regarding the information included in the reports. This duty of confidentiality solely pertains to the information contained in the reports. If a report leads to the initiation of a case, the other information collected in connection with it will not be subject to the duty of confidentiality. POMPdeLUX's whistleblower unit handles reports as confidentially as possible. Information from a report is processed in accordance with the processing rules of § 22 of the Whistleblower Act and the Data Protection Regulation and Law. According to § 22 of the Whistleblower Act, POMPdeLUX's whistleblower unit may process personal data, including sensitive information and information about criminal offenses, if necessary to process a report received in connection with POMPdeLUX's whistleblower scheme.

Information from a report may, under certain circumstances, be disclosed, for example, for the purpose of following up on the reports. The whistleblower will be notified in advance of the disclosure of information about the whistleblower's identity, unless it would endanger a related investigation or legal proceedings. For instance, this might be the case if such notification is deemed to pose a risk of evidence being hidden or destroyed, witnesses being influenced, or if there is suspicion that the whistleblower knowingly submitted a false report.

Protection of whistleblowers
A whistleblower must not be subjected to reprisals, including threats of or attempts at reprisals, because they have made a report to POMPdeLUX's whistleblower unit or an external whistleblower scheme (Data Protection Agency). Furthermore, the whistleblower must not be hindered or attempted to be hindered from making reports. Reprisals are understood as any form of unfavourable treatment or consequence in response to an internal or external report that causes or could cause harm to the whistleblower. The whistleblower cannot be held responsible for reporting confidential information if they have reasonable grounds to believe (in good faith) that the information in a report is necessary to reveal a serious legal violation or a serious matter.

Attempts by POMPdeLUX employees or management to prevent a whistleblower from making a report or to retaliate against a whistleblower who has made a report in good faith will result in employment consequences.

Additional information
The Ministry of Justice has prepared a guide for individuals who wish to submit or are considering submitting information as whistleblowers. The guide provides a general description of the Whistleblower Act, including descriptions of whistleblower schemes, reporting options, the rights of whistleblowers, and whistleblower protection. The guide can be obtained from the Ministry of Justice's website www.jm.dk

POMPdeLUX's whistleblower policy
Appendix 1.

Examples of serious violations of the law
Violations of the Criminal Code, which generally fall within the scope:

  • Bribery, cf. Criminal Code § 144.
  • Forgery of documents, cf. Criminal Code § 171.
  • Hacking, interception, recording of conversations with others, etc., cf. Criminal Code § 263.
  • Theft, cf. Criminal Code § 276.
  • Embezzlement, cf. Criminal Code § 278.
  • Fraud, cf. Criminal Code § 279.
  • Data fraud, cf. Criminal Code § 279a.
  • Abuse of mandate, cf. Criminal Code § 280.
  • Extortion, cf. Criminal Code § 281.

Violations of special legislation or other legislation, which generally fall within the scope:

  • Violations of tax legislation.
  • Breach of confidentiality obligations.
  • Violations of the Accounting Act.
  • Violations of the Road Haulage Act, cf. sections 17-17 b of the Road Haulage Act.
  • Violations of the Aviation Act, cf. section 149 of the Aviation Act.
  • Failure to comply with a legally mandated duty of action.
  • Violation of rules on the use of force.
  • Serious or repeated violations of administrative law principles, including the principle of investigation, the requirement of objectivity, the principle of non-misuse of power, and proportionality (however, see below for minor violations).
  • Deliberate misleading of citizens and partners.


  • Sexual harassment, cf. the Equal Treatment Act § 1, para. 4, cf. para. 6.
  • Severe harassment, e.g., based on race, gender, colour, national or social origin, political or religious affiliation.

Examples of serious matters
Matters generally considered serious:

  • Disregard for professional standards that could, for example, pose a risk to people's safety and health.
  • Serious or repeated violations of the workplace's internal guidelines concerning, for example, business trips, gifts, or accounting practices (however, see below for minor violations).
  • Serious errors and serious irregularities related to IT operations or IT system management.
  • Special cases where minor cooperation difficulties entail significant risks and thus constitute a serious matter.

Examples of information not covered by the scope of the law

  • Information of a trivial nature, information about other matters, including information about violations of internal guidelines on sick leave, smoking, attire, or accessory provisions such as failure to comply with documentation requirements.
  • Information about the whistleblower's own employment relationship, including conflicts between employees, cooperation difficulties, or matters falling under the labor law system, unless it involves sexual harassment or other forms of severe harassment.