Topdanmark’s whistle-blower scheme

Transparency and integrity are very important to Topdanmark. Therefore, we have established a whistle-blower scheme which is intended to handle criminal or other very serious matters related to Topdanmark.

Transparency and integrity are very important to Topdanmark. Therefore, we have established a whistle-blower scheme which is intended to handle criminal or other very serious matters related to Topdanmark.

Conditions that can be reported

The scheme is intended to offer Topdanmark’s employees and others connected with Topdanmark, for example existing and previous alliance partners and previous employees, the opportunity to report matters which could be in conflict with Topdanmark’s policies or relevant legislation.

 

It could be, for example: 

  • Criminal matters such as overcharging, fraud, bribery, deception, forgery and the like
  • Matters relating to accounting, internal control and corruption
  • Matters of serious breach of occupational safety
  • Matters of importance to the Group as a whole
  • Matters that could be decisive for individuals’ lives and / or health

Topdanmark’s whistle-blower scheme has been approved by the Danish Data Protection Agency.




Limitations of the scheme

The whistle-blower scheme is not intended for matters relating to breach of internal rules, manners, code of conduct etc. For Topdanmark’s employees such matters are handled by the HR department and the staff organisations. Nor can the scheme be used to handle claims from customers.




Information to be reported

In order to handle your report properly and correctly it is important for us to receive all the information you hold.

 

It could be, for example:

  • What your report deals with 
  • Who is involved in the actions concerned 
  • Where the actions concerned take place / have taken place
  • Your knowledge of the size of the values involved in the actions
  • How you have come into possession of the information

Even though you have not got all the information, it is important that you do not go more closely into the question yourself. You should rather report through the whistle-blower scheme on a less certain basis than destroy any evidence. 

> Link to reporting form
 

Report by phone +45 44 74 48 00

The telephone is an answering machine allowing us to replay the reported message. We check the answering machine daily.

 

Report by letter

Send the report by letter to:
Topdanmark Forsikring A/S
Borupvang 4, 2750 Ballerup
Marked: ACA confidential

 

Report by email

Send an email with your report to whistleblower@topdanmark.dk
 

Recipients of the report 

At Topdanmark, the whistleblower scheme is placed with Group Compliance and Internal Audit, and the Head of Group Compliance and the Head for Internal Audit are the direct recipients of the whistleblower reports. If the report concerns either the Head of Group Compliance or the Head of Internal Audit, direct your report to the person whom the report does not concern. If the report concerns both the Head of Group Compliance and the Head of Internal Audit, you can direct your report directly to the chairman of the Audit Committee.




Questions and answers about the scheme

Matters to be reported through the whistle-blower scheme 

A whistle-blower scheme is intended to handle criminal or very serious matters relating to Topdanmark. Find specific examples at the top of this site.
 

Matters not related to the whistle-blower scheme 

The whistle-blower scheme is only intended to handle serious matters. Therefore, you cannot report a number of situations even though it could be breach of internal rules, manners, code of conduct etc.  

 

It could be, but not exclusively:

  • Bullying
  • Lack of co-operation
  • Incompetence
  • Absenteeism
  • Violation of guidelines for dresscode, smoking, alcohol, use of e-mail and internet

If, as an external business partner, you have been in situations as described above, we recommend you to contact your counterpart in Topdanmark or his / hers intermediate superior in the company. Such matters cannot be handled by the whistle-blower system, according to law. Therefore, reports received on these subjects will be deleted immediately.

 

You have the opportunity to report anonymously 

It is possible to report anonymously but we prefer that you tell us your name and other contact details. If you have told us who you are, it will be possible for us to come back to you with detailed questions if necessary.

Topdanmark protects persons who make us of the scheme, and if people are subject to reprisal because they make use of the whistle-blower scheme, this will be reported to HR. 

 

We are not always able to give you feedback on your report 

As reports often relate to personally sensitive information and may involve individuals on whom we are not allowed to pass on information, we are not able to able to give you individual feedback on your report. This is irrespective of you being anonymous or not. Of course, you can be sure that we will take your report seriously and check it thoroughly within the statutory limits of the whistle-blower scheme.

 

The whistle-blower scheme has been approved by the Danish Data Protection Agency 

Topdanmark’s whistle-blower scheme has been presented to and approved by the Danish Data Protection Agency. It is absolutely top priority that all those who use the whistle-blower scheme may rely on all communications being treated as confidential and stored and investigated in a confidential and adequate manner.




Contact

Pernille Fogh Christensen
Senior Sustainability Consultant
Marie Uldall Thomsen
Sustainability Consultant