Module Learning Objective

recognise warning signs of corruption without confusing suspicions with findings

1. Regulatory Concept & Core Standards

In this video we will work through a concrete decision: recognise warning signs of corruption without confusing suspicions with findings. The aim is to explain the criterion used and apply it to a workplace situation. We will start with the concept, move to the procedure and finish with a case to solve. An integrity programme connects risks, behaviour, controls and reporting channels. The obligation to protect whistleblowers must be assessed under national law. The prevention measures used in the examples are good practice unless identified as a specific legal obligation applicable to the organisation.

Corruption may involve offering, requesting or accepting an advantage to improperly influence a decision. The advantage may be money, a favour or another benefit. The elements of each offence depend on national law. A warning sign calls for verification and prevention; it does not establish a person's guilt. Identify the decision, the interest involved and any potential breach of duty.

Apply the following rule: The Act covers specified breaches of EU law and other serious offences or serious matters. An ordinary workplace disagreement is not automatically covered. Assess seriousness and the exclusions in section 1. Protection requires, among other conditions, reasonable grounds to believe the information was correct and within scope when reported.

2. Practical Implementation & Procedure

Look at three elements: who makes the decision, what benefit is offered and which rule might be compromised. Then identify the existing control, such as a second approval or a declaration of interests. If you encounter a suspicious situation, describe the facts and follow the appropriate procedure. Avoid premature confrontations, investigations on your own initiative or circulating accusations among colleagues. Before moving on, turn this procedure into a sequence you could explain to a colleague. Identify the first check, the action that depends on its outcome and the record that allows the decision to be reconstructed. Follow the sequence on screen and identify the point where an error would change the result.

3. Case Study & Compliance Action

At a fictional company, a supplier offers a trip to the employee assessing bids. The trip coincides with the decision-making stage. We know that an offer has been made and a decision is pending; we do not yet know whether the offer was accepted or influenced the selection. The first step is to address the conflict and preserve the relevant material. Now read the case carefully. Separate established facts from information you would still need to confirm. Do not add motives or events that have not been described. This distinction matters when choosing a response proportionate to the information available.

The exercise is as follows: Does the trip automatically prove corruption? Which two elements should be checked first? Choose an answer and write one sentence explaining it. During the pause, compare your choice with the criteria we have just considered. Also think about the material you would retain to explain the decision later.

The trip does not automatically establish corruption. Assess its connection with the decision, the relevant duties and the actual circumstances. Internal approval does not legalise an unlawful advantage. Keep suspicion, evidence and legal classification separate. Danish Criminal Code sections 122, 144 and 299(2) address different public and private bribery situations.

One mistake to avoid is: presenting all unethical behaviour as proven criminal conduct.

Now apply the national rule to a second decision. A report is automatically classified as protected because it contains the word corruption. What check is missing?

Read the facts and apply the national scope, context and conditions for protection. A form label helps organise information but does not determine the legal framework. If the case falls outside the regime, identify an appropriate route without unnecessarily disclosing information.

National Legal Framework: Lov om beskyttelse af whistleblowere, transposing Directive (EU) 2019/1937 of the European Parliament and of the Council on the protection of persons who report breaches of Union law.