If you face information that shows malpractice or wrongdoing within the organisation, this information should be disclosed through our complaints handling mechanism. Our whistleblower secretariat will handle the information in a responsible and professional manner.
DiH is committed to preserve the anonymity of the whistleblower, to support those affected by the wrongdoing in a reliable manner and to take necessary actions as soon as it is reasonable possible. The organisation will, by having a culture of accountability and openness, do whatever is needed to prevent blameworthy situations to happen.
Being a Norwegian NGO, DiH follows legislation from the Norwegian working environment act, hereunder the regulations regarding whistleblowing noted in § 2A. DiH will make sure that the EU General Data Protection Regulation (GDPR) effective from July 2018 will be covered in this complaints handling mechanism, especially when it comes to the protection of the whistleblower.
Anonymity and confidentiality
The complaints handling mechanism is safe for everyone who wants to make a complaint and there are measures in place to ensure the protection for the complainant.
There are two options when raising concerns:
- make your identity known to the organisation.
- blow the whistle anonymously.
When making a disclosure, you are encouraged to sign with your name. Giving your name to the whistleblowing secretariat, makes it possible for the secretariat to retrieve additional information.
However, all complaints can be made anonymously through the online system, and DiH guarantees the anonymity of the whistleblower.
If your identity is known, but you want to raise a concern confidentially (without being identified towards involved parties), DiH will keep your identity a secret. If it is necessary for anyone investigating the concern to know the identity, this will be discussed in advance with the whistleblower, given the identity is known. In such matters, the whistleblower will be protected from reprisals.
The person being notified against have the right to be informed and to have access to notification, provided that the whistleblower remains anonymous.
What should be reported?
DiH is interested in receiving information that can expose potential criminal offenses or unacceptable behaviour by representatives of the organisation or the organisation itself.
You can make complaints about criminal offenses, breach of guidelines or commonly accepted norms. Such actions could be described as (but not be limited to):
- Failure to comply with a legal obligation or internal DiH statutes, codes of conduct and guidelines
- Financial malpractice, corruption, fraud or theft
- Criminal activity
- Breach of safety rules related to DiH operations affecting Health, Safety and the Environment
- Bullying and harassment
- Misuse of power
- Breach of confidentiality
- Improper conduct or unethical behaviour
- Conduct likely to damage DiH reputation
- Attempts to conceal any of these
You cannot make a complaint about political disagreement with DiH or its representatives, or disagreement regarding agreed rules of the organisation.
Making a disclosure
Complaints should be made through this form, or e-mail to email@example.com.
The complaint is sent to the DiH whistleblowing secretariat. However, should the complaint relate to persons in the administration or have a profoundly serious nature, the complaint can also be directed to members of the board.
If your identity is known, you will receive feedback within 14 days, to be informed on how the secretariat will proceed with issue. Every complaint is given high priority and should be closed/resolved within two months.
Procedures for handling complaints
The DiH whistleblowing secretariat is responsible for receipt of disclosures and taking actions according to the organisation´s mechanism. The secretariat consists of three members: one representative from the board, the Secretary General and one employee.
All notifications will be taken seriously, and will be handled immediately. The mentioned ways of notifying will be handled on equal terms. All notifications are treated with confidentiality, and notifications should be done without fear of consequences.
No one (employees, volunteers, directors or collaborators) must threaten or retaliate against whistleblowers. Those involved in such conduct will be subject to disciplinary actions.
The DiH whistleblowing secretariat will assess the situation and determine how to proceed. How the complaint is followed up will vary depending on the matter of the complaint. You will receive information regarding the follow-up process of the complaint, such as the progress plan or monitoring measures. DiH will always assess the nature of each complaint and evaluate whether there is a need to contact legal and experts to assist in handling the complaint.
The complaints handling mechanism protects the person the complaint is directed to, equally to protecting the whistleblower. When the DiH whistleblowing secretariat chooses to pursue the complaint, the subject of the complaint should be notified that a complaint has been made against him/her and the contents of the complaint. This gives the person the opportunity to give their side of the story. When the complaint has been assessed and the process is finished, the subject of the complaint will be notified immediately, regardless of the outcome.
All complaints are entered into records and are exempt for the public.