Investigation of COWI's role in connection with 'The Black Swan' finalised

24 September 2024

At COWI, we are shocked by the activities uncovered by 'The Black Swan'. The documentary is a well-documented and important contribution to the public debate by exposing a side of Denmark that very few of us knew about before the documentary was broadcast. The willingness to take unethical and even illegal action in parts of the business community is shocking.

In May 2024, TV2 informed us about irregularities that, apparently, had facilitated deliberate illegal disposal of contaminated soil in connection with a construction project in Vallensbæk, which was later mentioned in the documentary 'The Black Swan'. COWI's services on this project included, e.g., site supervision of a soil contractor's excavation of contaminated soil on behalf of a client. 

Immediately after learning about TV2's documentation of these circumstances, COWI terminated all collaboration with the client in question and launched a thorough investigation into the process with external assistance from law firm Kromann Reumert and auditing firm PwC. The investigation has now been finalised, and we are able to share the findings. 

The findings of the investigation
We can confirm that the investigation did not uncover any type of financial fraud, improper enrichment or other circumstances that could indicate deliberate dishonesty, positive knowledge of or involvement by COWI employees in the client's and the client's soil contractor's allegedly illegal disposal of contaminated soil. 

On the contrary, the investigation found that, apparently, our client and the client's soil contractor deliberately circumvented the issued environmental permits, thereby misleading not only the relevant authorities but also COWI. 

The investigation also found that, on the specific project, COWI's site supervision of the soil excavation did not meet the requirements of the environmental permit. The supervisory services were insufficient and did not meet the desired professional standard. The same goes for COWI's subsequent reporting to the relevant supervisory authority on the specific project. The reporting was insufficient and did not provide an entirely true and fair presentation. 

These conclusions led COWI's management to decide to expand the investigation to also include an in-depth internal audit of other ongoing projects and projects concluded within the past five years that also included supervision of contaminated soil and subsequent reporting to the relevant supervisory authority. The review of these projects has not uncovered conditions that give rise to further remarks or corrective measures.

Follow-up on the findings of the investigation
We are intent on learning from the mistakes we made on this project and on preventing entering into future collaborations with customers who do not share our values. 

Therefore, we are introducing a range of measures to strengthen our quality management processes. These include improved supervision tools as well as stricter requirements for detailed supervision plans and documentation of supervision and inspection activities in connection with the excavation and handling of contaminated soil. 

Moreover, we have started implementing a long-term plan that focuses on ensuring the quality level of all supervision tasks, among other things through training activities targeting project managers and discipline specialists. Through our project audits, we will ensure the anchoring of the strengthened quality assurance procedures and tools and continuously assess the potential for improvement.

Two employees who were suspended during the investigations have left COWI, by mutual agreement. 

Executive Vice President of COWI in Denmark, Henrik Winther, says: 
“We take this matter extremely seriously and regret the consequences of the case. It is our aim and ambition to always meet the highest professional and ethical standards, and any behaviour conflicting with our values is entirely unacceptable. As consultants, trust and credibility are paramount – both to our customers, to society and to our colleagues."

He continues: ”We treat the mistakes made in connection with our supervision on the mentioned project as a very serious matter. As a direct consequence, we have already strengthened our quality assurance procedures, and we are working on additional measures to prevent a similar situation from happening in the future."