Frequently Asked Questions about the COWI Whistleblower

Please find answers to the most frequently asked questions about the COWI Whistleblower below.
  • Why should I use the COWI Whistleblower? 
  • Who can use the COWI Whistleblower?
  • What can I report through the COWI Whistleblower? 
  • Should I use the COWI Whistleblower or ask a COWI manager?
  • Can I report anonymously?
  • What if I am in a dangerous situation or emergency? 
  • Why is COWI using LRN / Ethics Points?
  • Are translation services provided?
  • Can I monitor progress on the investigation related to my report?
  • How does COWI investigate my concern?
  • How is my report kept confidential?
  • Do I risk facing retaliation?
  • How am I protected, if affected by a report?

Why should I use the COWI Whistleblower?

Employees are normally the first to know if there is somthing wrong. Hearing about employees' concerns will help COWI prevent violations of laws, regulation and internal procedures.

If you think that something is wrong in COWI you should primarily contact your line management. However, if you for some reason you feel uncomfortable doing so, please let us know through this homepage or by telephone.

Who can use the COWI Whistleblower

The COWI Whistleblower is primarily set up for employees in the COWI Group.

What can I report through the COWI Whistleblower?

To make it easier to know what the hotline normally is made for, COWI has listed a number of examples that can be reported. In general terms, these include: 
  • Accounting and auditing matters:
    The recording and analysis of business and financial transactions that appear unethical or deviate from generally accepted accounting practices (Examples include: misstatement of revenues, misstatement of expenses, misstatement of assets, misapplications of GAAP principles, wrongful transactions).
  • Conflict of interest:
    A conflict of interest is defined as a situation in which a person, such as a public official, an employee, or a professional, has a private or personal interest sufficient to appear to influence the objective exercise of his or her official duties. (Examples include: inappropriate vendor relations, bribery, misuse of confidential information, inappropriate customer relations)
  • Disclosure of confidential information:
    Unauthorised and unlawful disclosure of corporately owned intellectual property or trade secrets, as well as employee, customer or consumer information, marketing and other corporate databases, marketing plans, business proposals and strategies.
  • Discrimination and harassment:
    Uninvited and unwelcome verbal or physical conduct directed at an employee because of his or her sex, religion, ethnicity, or beliefs (Examples include: bias in hiring, bias in assignments, wrongful termination, bias in promotions, bias in educational decisions, unfair compensation, inappropriate language).
  • Environmental protection, health and safety laws:
    Violation of any environmental law, regulation, corporate policy or procedure with respect to the handling and disposal of hazardous materials or the health and safety of individuals.
  • Fraud:
    Improper, misleading or deceptive actions taken, falsification of records, or misrepresentation of physical conditions.
  • Improper giving or receiving gifts The giving, receiving or solicitation of items which could be reasonably interpreted as an effort to influence a business relationship or decision; items given, received or solicited for the benefit of an individual or an individual's family or friends; items given, received or solicited during or in connection with contract negotiations; the acceptance of cash, checks, money orders, vouchers, gift certificates, loans, stocks or stock options
  • Misconduct or inappropriate behavior Intentional wrongdoing, specifically the deliberate violation of a law or standard.
  • Scientific misconduct Fabrication, falsification, plagiarism, or other practices that seriously deviate from those that are commonly accepted within the scientific community for proposing, conducting, or reporting research. Fabrication is making up data or results and recording or reprinting them. Falsification is manipulating research materials, equipment or processes, or changing or omitting data or results, such that the research is not accurately reported in the research record. Plagiarism is the appropriation of another person's ideas, processes, results, or words without giving appropriate credit.
  • Theft The act of stealing, specifically the felonious taking and removing of personal property with intent to deprive the rightful owner of it.
  • Unfair bidding practices Engagement in action amongst bidders designed to influence the bidding process and prevent the client from conducting an open process.
  • Unsafe working conditions Failure of meeting requirements needed to perform all duties in a secure environment. Potential areas of harm(Examples include: environmental damage, OSHA, EPA, supervisor directive, poor housekeeping)
  • Policy violations Actions committed either knowingly or unintentionally which are in direct violation of company policy, procedures, code of conduct, and/or implied contractual responsibilities (Examples include: non-disclosure agreements, hiring standards, safety, Internet usage, corporate guidelines).
  • Any other item If you feel that the definitions above do not describe the event, action or situation you are looking to report about, please use this category.

In some countries the scope of the COWI Whistleblower is limited due to protection laws. If you would like to report on a matter, which cannot be received by the hotline, please contact the managing director.

Should I use the COWI Whistleblower or ask a COWI manager?
COWI encourages employees to use the standard channels of communication, which initially is your line management or another member of the management. However, if for some reason you feel uncomfortable doing so, you can file a report through the homepage or by telephone.

Can I report anonymously?

We encourage you to provide your name and contact details, as this will make it easier for us to address your concern. However, if you feel uncomfortable providing contact details you can also submit your report anonymously. All users can track their reports and responses online via the Internet site, using their personal access code.

It is particularly important for anonymous users to log on to the website and check their reports as this will be the only channel available for COWI to ask for additional information.

What if I am in a dangerous situation or an emergency? The COWI Whistleblower should not be used for emergency cases. If you face an emergency, please contact the managing director, another member of the management or call the Group Compliance Manager, John De Meza Espersen, directly at: +45 5640 3912 or Julie Ramhøj Meisner, Group General Counsel at +45 5640 2002.

Why is COWI using Ethics Points?

To ensure the highest level of data security and confidentiality for the users and the accused, this homepage and phone line is set up by an independent, professional, third party: Ethics Point.

Ethics Points is available 24 hours a days, seven days a week and provides translation services for telephone and web reporting in different languages.

Is translation provided?

You can file a report in one of the languages made available on the web site. If you do not feel comfortable writing your concern in one of the languagesm, you can call the Ethics Points Phone service, which provides translation services.

Can I monitor progress on the investigation related to my report? Once you file a report online or on the phone, you will be provided with a log-in key and a personal password. You are strongly encouraged to log-on to the whistleblower website to follow-up on your report in a secure and confidential manner.

The Compliance Team will use the whistleblower secure homepage to ask additional questions and answer all relevant questions. All correspondence on the website remains confidential.

How does COWI investigate my concern?
Your report will be received by Ethics Point, which is a professional third-party service provider. Ethics Point will screen incoming submissions and forward them to COWI's Compliance Team, which consists of COWI's Group Compliance Manager (GCM), John De Meza Espersen, and COWI's Group General Counsel, Julie Ramhøj Meisner. They are the only ones that are allowed to read your report.

The Compliance Team will deal with the submissions and if necessary involve experts and regional representatives to ensure that the necessary skills and local expertise are present to conduct an independent, professional and objective investigation. All submissions will be considered carefully.

Please rest assure that your report is only shared with the necessary staff and is handled with extreme discretion.

Should one of members of the Compliance Team be mentioned in your report, Ethics Points will ensure that this person cannot access the report and will notify the Chairman of the Board of the need for investigation.

How is my report kept confidential?
Ethics Points does not capture the Internet Protocol (IP) address or the phone number of the reporter. In addition, reports are housed on a secure and encrypted server.

Within COWI only the Compliance Team will have access to your report and they will conduct a potential investigation in a confidential manner to the maximum extent consistent with a thorough and complete investigation.

Do I risk facing retaliation?
COWI will not discharge, demote, suspend, threaten, harass or in any manner discriminate against any person provided with respect to good faith reporting of concerns, complaints or reports of violations or suspected violations.

If any user of the COWI Whistleblower believes that he/she has been retaliated against for reporting or participating in an investigation, he/she should immediately report such perceived retaliation to the Group Compliance Manager John De Meza Espersen, directly at jdme@cowi.com or call +45 5640 3912. All such reports will also be investigated confidentially to the extent possible.

How am I protected, if affected by a report?

If your name is mentioned in one of the reports, you will be informed as soon as possible and given an opportunity to explain your view of the case. During this meeting you will always have the option to be accompanied by your HR partner or employee representative.

As COWI wishes to encourage good faith reporting while avoiding damage to the reputation of innocent persons initially suspected of wrongful misconduct, the in-vestigation will be conducted in a confidential manner to the maximum extent con-sistent with a thorough and complete investigation.

LAST UPDATED: 21.07.2017