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Whistleblower Policy


Sophie Bille Brahe (SBB) is committed to conduct business with integrity and to ensure that we live up to our standards and address any breaches that may happen through our organisation. We want to promote an open organisational culture, where it is safe to report serious offences or suspicion of serious irregularities. We strive to identify all potential issues that need to be addressed and all reports of possible misconduct are taken seriously, and the matter investigated confidentially.

This policy sets out how SBB will support anyone who wants to express their concerns, knowledge on who to contact, and to find the proper reporting channel. In case of a suspected or known breach or other misconduct related to SBB, this is to give information on how to make a report and the protections that are available.

SBB encourages the use of the whistleblower scheme for any possible violations. The whistleblower is free to report through the Data Protection Authority's general, external whistleblower scheme instead of the SBB’s scheme.


The purpose of the whistleblower scheme is to ensure openness and transparency in relation to possible violations and serious irregularities. 

The purpose is:

  • To prevent and investigate any suspected illegal actions and any clear and serious violations of internal guidelines or policies of SBB.
  • To provide the opportunity for SBB employees, suppliers and business partners and other stakeholders to speak out about impermissible circumstances in the SBB without a fear of negative consequences.
  • To provide a formal and secure procedure for protecting stakeholders that choose to come forward under the Whistleblower Policy.
  • To protect the persons who report information through the whistleblower scheme

The rights as a whistleblower

  • Reports can be summited anonymously.
  • Filing a report in good faith will not have any adverse employment consequences.
  • All information will be confidential.

Everyone can use the whistleblower form

SBB’s whistleblower scheme aims to increase the opportunities for employees, suppliers and business partners and other stakeholders to report any serious and sensitive concerns without fear of negative consequences.

In case of an unethical situation or a breach, employees, members of the boards, business partners or other stakeholders can report the incident(s) via the following process, which indicates a top-down order of escalation.

For internal reports:

  1. Direct manager
  2. Management
  3. CSR team
  4. Whistleblower scheme

For external reports:

  1. Direct point of contact
  2. Whistleblower form

Reporting of breaches

Reporting to SBB’s whistleblower scheme must be made on our whistleblower form.

Information that can be reported

The SBB whistleblower scheme can only be used to report serious offences or suspicion of serious offences of importance to the SBB’s performance and interactions.

Examples of Reportable Conduct includes violation for all human rights but are not limited to:

  • Illegal conduct, such as theft, violence or threatened violence, and criminal damage against property, fraud, money laundering or misappropriation of funds.
  • Offering or accepting a bribe.
  • Financial irregularities.
  • Failure to comply with, or breach of, legal or regulatory requirements.
  • Criminal activity or violation of any applicable law or regulation.
  • Theft or fraud against or by SBB including falsification of contracts, reports, or records.
  • Purposeful misinformation or false statements.
  • Inappropriate accounting practices, internal accounting controls or audit matters.
  • Abuse of authority, including instructions not to report breaches to higher management or to the Ethic & Compliance Committee.
  • Child labour forced labour and other violations of fundamental human
  • Significant adverse environmental impact.
  • Sexual harassment.
  • Serious harassment, e.g., on grounds of race, sex, colour, national or social origin, political or religious affiliation.

Processing of reports & data

Information submitted through the whistleblower scheme will initially be received and read by the SBB whistleblower unit. Through an initial screening the gatekeepers will ensure that the information submitted is not clearly unfounded and that the information is not clearly outside the scope of the Whistleblower Policy. Upon having made this review and assessment, any information which is eligible for processing under the Whistleblower Policy will be reported to the CEO of Sophie Bille Brahe ApS and the Chair of the Board of Directors of Sophie Bille Brahe ApS.

The investigation process outlined in this Policy is also designed to allow fair treatment of any individuals mentioned in the disclosure, including:

  • Disclosures will be handled confidentially.
  • Matters reported will be assessed and may be subject to an investigation.
  • There will be a presumption of innocence until the outcome of the investigation is determined; and
  • The purpose of the investigation is to determine whether there is enough evidence to substantiate the matters reported.

While the circumstances of each whistleblower report may require different investigation steps, all investigations will:

  • Follow a fair process.
  • Be conducted as quickly and efficiently as the circumstances permit.
  • Determine whether there is enough evidence to substantiate the matters reported; and
  • Be independent of the person(s) concerned with the allegations.

Protection of the whistleblower

A whistleblower will not be subjected to reprisals, including threats of or attempted reprisals, because the person in question has made a report to the SBB whistleblower scheme or an external whistleblower scheme (the Danish Data Protection Authority). The whistleblower must not be prevented or attempted to be prevented from making reports.

Confidentiality and processing of information

Employees who are affiliated with Sophie Bille Brahe’s whistleblower unit have a special duty of confidentiality in relation to the information included in the reports.

The obligation of professional secrecy shall apply only to information included in the reporting. If a report gives rise to the opening of proceedings, the other information collected in this context will not be covered by the obligation of professional secrecy. 

Retention of data

The information received under the Whistleblower Policy will be retained by SBB only for such period of time which is required by regulation and for SBB’s processing of the data in question. If the information is dismissed as being unfounded or outside the scope of the Whistleblower Policy, the information will be deleted.

For any questions about the whistleblower process, please find all relevant contact information below:

Internal Audit Team

CSR team

This policy is adopted in Copenhagen on  23 March 2023

The Whistleblower Policy is annually reviewed to ensure that Sophie Bille Brahe ApS is aligned with current good practices.

Sophie Bille Brahe