K2 item: Christian Steen Laursen

GALST is, in collaboration with Whistleblower Software Aps, offering one technical and legal whistleblower solution with an easily accessible implementation process. Our solution is adapted to the specific company and consist of a legal and organizational implementation, the required written policies, and procedures as well as an online reporting channel through our whistleblower software. 

What is a Whistleblowing System?

A whistleblowing system is a tool that ensures that your employees and partners can report potential unlawful practices. It helps companies to prevent and expose serious practices, which could be of economic or criminal character. At the same time, it ensures that the applicable law is being complied to. It creates safety and trustworthiness towards employees, partners, and others, since your company takes the reports seriously and ensure a safe work environment for everyone. 


What is included in the requirement for a whistleblowing system?

All companies with between 50 to 249 employees, must establish a whistleblowing system no later than on the 17th of December 2023 and if the company consists of more than 249 employees, it must be established on the 17th of December 2021, at the latest.   

The employees can then report practices, covered in the whistleblowing law. The system makes it possible to establish a shared whistleblowing system between the parent company and subsidiaries, regardless the size of the companies. 

Who manages and implements the whistleblowing system?

In terms of the implementation and managing of the whistleblowing system, the employer can choose to either handle it internally or outsource it. When choosing to handle it internally, an independent person in the company (or a department), receives the reports and manage the communication with the whistleblower. If a company choose to outsource it to someone outside the company, the natural choice will often be a law firm that specializes in GDPR and employment law. A lot of companies choose an external whistleblowing system to, for example, avoid potential whistleblowers to feel insecure about reporting internally. 

Which practices can be reported?

The practices concerned in the new whistleblowing law, is indictable practices such as exploitation of finances, theft, confidentiality breaches, fraud, embezzlement, and bribery. Including other serious or repeated violations of other legislations. 

The practices concerned with the employees own conditions of employment, like violations of internal guidelines, as absence due to illness, clothing, and intake of alcohol, will generally not be included in the whistleblowing law. In these cases, the closest boss, contact person or the HR department should be contacted. Is the practice a more severe breach of the law or serious circumstances within the workplace, like sexual harassment and other coarse conflicts related to people in the office, it is included in the whistleblowing law. Some companies choose to have a broader whistleblowing system, so a broader range of rapports can be made, that are not necessarily a part of the law. 

Who can report? 

If the company is affected by the law, the employer is legally bound to implement a whistleblowing system for their employees. However, it is also a possibility to provide access to the whistleblowing system to people who are not employed in the company but have a relationship with the company. This could for instance be shareholders, volunteers, interns, self-employed people, suppliers, and sub-suppliers.  


How is the whistleblower protected against reprisals?

The whistleblower law involves a complete prohibition against reprisals. A report must not cause unfavorable treatment or reaction towards the whistleblower. Neither the whistleblower or other people included in the conditions of the law, can be exposed to reprisals, attempts to, or threats in this regard.     

If whistleblowers are subject to reprisals in relation to a report, they have a right for compensation for non-financial damage. Additionally, they have a right for compensation if they experience reprisals in relation to acquisition of documentation or attempts to acquire documentation for information about violations. 

Which documents must be filed?

As a minimum, the employer is required to prepare a whistleblower policy as well as a written procedure, stating how the reports are being handled. The employer is furthermore required to keep written documentation for the establishment of the whistleblowing system and the included procedures. If the employer chooses an external contractor to manage the whistleblowing system, it needs to be ensured that the contractor measures the whistleblowing law. Here you can secure a written guarantee, from the external contractor, for example through a data processing agreement between the two parts. 

Get a full-service solution at GALST 

We use Whistleblower Software, which is built professionally by Whistleblower Software Aps, to support a transparent and secure solution, designed by specialists with input from international experts within whistleblowing. 

The solution consists of:

  • An encrypted and safe solution with a two-factor authentication method
  • Whistleblower can report anonymously
  • An ISAE 3000 declaration on the IT-platform
  • Communication will take place in a closed portal, which is placed in a ISO 27001 certificated datacenter
  • Full logging of practices in the portal
  • A number of formalized procedures for establishment, changes and closure of user access
  • End-to-end encrypted reporting



  • Fixed price for implementing the whistleblowing system at DKK 10.000 for all companies.

License for whistleblower software:

  • Fixed license price to Whistleblower Software Aps at DKK 520 ex moms monthly for companies with 0-49 employees.
  • Fixed license price to Whistleblower Software Aps at DKK 600 ex moms monthly for companies with 50-249 employees.
  • Fixed license price to Whistleblower Software Aps at DKK 1000 ex moms monthly for companies with 250-500 employees.
  • +500 employees, DKK 1.600-2.600 ex moms monthly.

Add-on options:

  • Outsourcing of the whistleblowing system to GALST: DKK 5.000 ex moms yearly and DKK 1.000 ex moms for each screening.
  • Investigation process as well as advising in employment law and data protection law, from our specialized lawyers in relation to the reports through the whistleblowing system is agreed specifically.
  • A course for related contact people at the company DKK 3.000 ex moms.

Further information

Download a price overview or fill out the contact box, if you want help from our lawyers.

For more information, you can also contact lawyer Josephine Wing or lawyer (L) and partner Christian Steen Laursen

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