Whistleblower Policy

At EMD International A/S, we wish to have an open corporate culture where everyone has the opportunity to come forward and report suspected irregularities or illegalities, whether it concerns employees, management, customers, suppliers or products

The scheme means that employees can make an anonymous report in case of reasonable suspicion of serious and objectionable facts and illegalities. The scheme ensures that such reports are treated seriously and appropriately and provides reassurance that any person acting in good faith reports a serious suspicion, will be protected from retaliation and the like. Below is a general description of the conditions that can be reported via the portal.

The full policy can be read inside the portal itself.

Which conditions can be reported?

The whistleblower scheme can only be used to report serious irregularities or unethical behavior in connection with matters that may affect EMD International A/S as a whole or the life and health of individuals.
There must be reasonable suspicion of violation of legislation or internal policies and guidelines at EMD International A/S.

Matters that can be reported via the whistleblower scheme may, for example, be reasonable suspicion of:

Fraud/financial crime

• Financial crime such as embezzlement, bribery, fraud, document forgery and theft of goods and inventory, etc.
• Accounting and audit irregularities.
• Violation of competition law (e.g. price fixing, exchange of price-sensitive information).

Production, general

• Providing false or misleading information to public authorities.
• Serious threats to the environment and safety.


• Physical violence, sexual violations and health.

If you are in doubt about whether your observation should be reported or not, you are encouraged to do so. To the extent possible, the report shall be documented by attaching relevant documentation in digital form.
All reports via the whistleblower scheme are taken seriously and will be answered.

Matters that do NOT concern violations of legislation or internal policies and guidelines at EMD International A/S must not be reported via the whistleblower scheme. This applies, for example, to dissatisfaction with pay, cooperation difficulties, conflicts between colleagues and bosses, etc.

How is a report made via the whistleblower scheme?

Reports can only be made electronically (in Danish as well as in English) by completing and sending an online questionnaire, which can be accessed here.

Reports made in bad faith via the whistleblower scheme, e.g. with the intentions to harassing or harming other employees, will be subject to sanctions and may be met with employment law consequences.

How are reports handled?

All information is treated confidentially and with discretion.

BDO Statsautoriseret Revisionsaktieselskab (State-authorised public accountancy company) is engaged by EMD International A/S as data processor. BDO delivers and administers the technical solution of the whistleblower scheme.

The reports submitted via the whistleblower portal are accessed by a few trusted employees at BDO, who receive and register the reports and forward them to EMD International A/S’s management. If the report concerns EMD International A/S’s management, the report will be forwarded to EMD International A/S’s Chairman of the Board.

How are reported cases handled?

It is possible to report anonymously – and at the same time follow the case via a 16-digit key code, which is displayed after the submission of the report via the whistleblower portal.
It is possible to subsequently communicate anonymously using the 16-digit key code.

The communication channel will also be used to communicate any conclusion of the case to the reporter in case he or she is anonymous. In cases where the reporter is anonymous, the following deadlines apply in the whistleblower portal:

• Within seven days, acknowledge receipt of the report.
• The case is processed as quickly as possible, and the aim is that the case processing does not exceed three months.
• A conclusion of the case is communicated to the reporter via the anonymous communication channel.
• As a general rule, all cases are deleted from the whistleblower portal within 90 days of the reporting date, unless the deadline is manually extended by the recipient.
• The reporter has access to the case via the whistleblower portal and the 16-digit key code until the case is deleted herein. However, the reporter has access to the file for a maximum of one year from the time of reporting.

Does the person get the information reported?

Unless special substantial and justified investigative considerations apply, the person to whom the reported information relates will be informed of the handling of the case when the report has been received and an investigation has been initiated.

Whistleblower portal

Click here to go to whistleblower portal.