Billund Aquaculture A/S´s Whistleblower Scheme



The purpose of this whistleblower scheme is to inform and explain how Billund Aquaculture´s whistleblower scheme works, and to avoid any potential important knowledge not getting reported.


Extent of the whistleblower scheme:

Billund Aquaculture is a responsible company with an open corporate culture, where everyone can feel safe and speak up if you experience violations of any law. We encourage all our employees speak to their immediate manager or a member of management in these situations. It is also possible to use the whistleblower scheme.


Employees and other stakeholders can make an anonymous or confidential report about their suspicions for potential violations of the law. This also includes matters that may cause Billund Aquaculture a financial loss or damage of reputation.


The whistleblower schemes scope of work is e.g.:

  • Embezzlement, theft, corruption, bribery, fraud, fraud, forgery, extortion, and misappropriation of trade secrets.
  • Financial manipulation.
  • Submission of incorrect or misleading information to public authorities.
  • Harassment, violence, or sexual harassment.
  • Serious violations of occupational safety regulations.
  • Repetitive and serious overrides of internal procedures.
  • Violations of the competition rules.

This list is not exhaustive. If you have any doubts whether your observations fall within the scope, we encourage you to use the whistleblower scheme. All reports are treated and answered.


All reports must be submitting in good faith. It is very important that the whistleblower scheme is not used as means for insubstantial accusations with the purpose of raising suspicions against innocent people.


Other situations must be reported to your nearest manager or at our People & culture- department (HR). This could be information's of a less serious matter e.g., absence, trouble with a colleague, or disagreements with your manager.


Roles and responsibilities:

The whistleblower scheme is handled in collaboration with PwC.


The whistleblower policy is managed by Mattis Sørensen at Billund Aquaculture, who is responsible for the correct administration and operation of the whistleblower scheme. Together with the rest of the management, Mattis Sørensen is responsible for deciding whether an actual investigation of reports should be carried out and whether they require the involvement of internal or external assistance.


Mattis Sørensen bears the overall responsibility for the maintenance of the guidelines, keeping an overview of reports received and reporting the consequences of reports to the board.


Within Billund Aquaculture a whistleblower unit is appointed. Their job is to handle the reports after PwC has received and done the initial screening. The whistleblower unit consists of:

1. Legal & contract manager, Sara Schmidt Sørensen, DK

2. People & culture (HR), Elisabeth Charlotte Mørch, DK


Handling of the reports:

All reports under Billund Aquaculture and PwC are, at the best of our abilities, treated confidential. The whistleblower scheme also allows you to be anonymous.  

When a report is submitted, the whistleblower receives a confirmation of receipt within 7 days. When submission of a report, you must save a link. You can use the link to log on the system and see if there are any further questions, need for documentation or just check the status. The following dialogue is solely based upon the willingness of the whistleblowers to log on and answer such questions.


The whistleblower will receive feedback within 3 months after the confirmation of receipt. If it is not possible to give feedback within the 3 months, the unit will inform of the expected timeframe for feedback.


The feedback is construed to comply with legislation, including the personal data regulation. In order to pass on such information, there must be basis for disclosure. It is always an assessment of the specific circumstances on which information the unit is able to disclose to the whistleblower.


The whistleblower will receive additional information about the progress and outcome of the investigation, if possible, under applicable law.


The rights of those involved:

Anyone, who submits a report in good faith is protected against any form of harm or damages.


The platform is operated by Whistleblower Software ApS in cooperation with PwC, which is an independent company and guarantees the security and compliance with the personal data regulation (GDPR) within the system.

It is only the appointed member of the whistleblower unit who has access to the report in the system.


The recipient of the report is obliged to notify the person who is the subject of the report and the nature of the report. In each case an individual evaluation is made in order to establish when the notification can take place to secure the investigation of the reported and potential evidence.

There will be given no information on who submitted the report, even if the whistleblower has revealed his/her identity.


Billund Aquaculture does not allow any form of harm or harassment against whistleblowers who report in good faith via the whistleblower scheme.


The national whistleblower scheme:

It is also possible to make a report outside of Billund Aquaculture's whistleblower scheme via the National Whistleblower Scheme at



In case of serious law violations, the report is handed over to the police, and sanctions are imposed according to the legislation.


False or misleading information must not be knowingly submitted through the whistleblower scheme. If an employee intentionally makes a false report, this may have consequences of the employment. Whistleblowers who report in good faith will not be subject to consequences on their employment, even if the subject of the report turns out to be unfounded.