Whistleblower scheme

Who can submit a report?
You can submit a report through the whistleblower scheme if you are a former or current employee, project partner or other external party of the Ramboll Foundation.

Please note that reports regarding the Ramboll Group should be submitted through the Ramboll Group whistleblower function available at www.ramboll.com.

What can be reported?
You can make a report through the whistleblower scheme if you have knowledge or reasonable suspicion of serious breaches of applicable laws and regulations and other serious matters, as well as 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:

• 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 environmental pollution
• Breach of professional secrecy
• Breaches of protection of privacy and personal data
• Serious breaches of internal rules and guidelines in the Ramboll Foundation (e.g. the Ramboll Foundation code of conduct)
• 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, including HR matters such as dissatisfaction with terms of employment, office rules, complaints about other employees’ behaviour or incompetencies, including information on less serious workplace conflicts and disagreements, and disagreement on professional solutions and minor breaches of the Ramboll Foundation’s internal guidelines are not covered by the scope of the whistleblower scheme. These types of matters must be reported to the management.

Do not submit reports through the whistleblower scheme about matters that pose an immediate threat to life or property. If you need emergency assistance, you must contact the emergency services.

We encourage you to report concerns or suspicions about serious matters through our whistleblower scheme.

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

​​PwC ​will ​initially assess​​ whether the whistleblower report falls within the scope of the whistleblower scheme. If the whistleblower report does not have a sufficient level of information​ or gives rise to additional questions​, PwC will try to obtain more relevant information from the whistleblower​, if possible.

PwC ​will subsequently conduct an impartiality assessment ​​to uncover ​who can handle the whistleblower report in the Ramboll Foundation​ ​and​​​ ensure that the whistleblower report ​​​is​ ​processed​​​ by an impartial and competent person​ in the Ramboll Foundation​​ 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 Managing Director of the Ramboll Foundation
The Managing Director of the Ramboll Foundation is responsible for the whistleblower scheme in the Ramboll Foundation. The Managing Director is competent and independent, and responsible for ensuring diligent follow-up on whistleblower reports. Similarly, the Managing Director is responsible for deciding whether an investigation should be conducted based on your whistleblower report.

You can read more about our whistleblower scheme in our whistleblower policy.

You can read more about roles and responsibilities in this flowchart.

Confidentiality, objectivity and anonymity
Whistleblowers have the right to submit reports anonymously.

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.

The Ramboll Foundation and PwC will keep information about the identity of the whistleblower and any persons mentioned in the whistleblower report confidential to the greatest possible extent.

Whistleblower protection
The Ramboll Foundation does not tolerate harassment or retaliation against whistleblowers.

A whistleblower who raises a legitimate suspicion or concern in good faith will not be subject to retaliation or any other negative consequences, including consequences of an employment law nature, even if it is later concluded that the concern is unfounded.