Reporting corruption, irregularities, and other wrongdoings

What is whistleblowing?

The whistleblowing system is designed to make it easy and safe to report corruption, irregularities and other wrongdoings committed within or against the City of Oslo. The whistleblowing channel allows you to speak out if you suspect or have knowledge of issues of concern or wrongdoings.

Whistleblowing involves reporting issues of concern that violate rules of law, ethical guidelines, or generally accepted societal norms, to someone who can take appropriate action. The right to report issues of concern is established by law.

What can you report?

Everyone is encouraged to report or disclose knowledge of violations of laws and regulations involving or relating to:

• danger to life and safety
• unacceptable working environment
• corruption, fraud or other financial irregularities
• violations of public procurement regulations
• a risk or damage to the climate or environment
• breach of privacy and data security
• abuse of authority

What does not count as whistleblowing

• Matters that only relate to employee’s work situation. This includes dissatisfaction with issues such as salary, staff disputes, or distribution of work tasks.
• Expressions of professional or political disagreement
• Complaints or appeals against individual decisions Such concerns must be addressed to the authority that made the decision. They can help you formulate your complaint or appeal. Complaints or appeals against services are dealt with by the respective appeal body (for example the County Governor).
• Reporting issues of concern outside the municipality’s area of responsibility

Who can report issues of concern?

• employees and temporary employees and third parties (suppliers, residents of the municipality)
• others who carry out work in a municipal enterprise, for example, apprentices or individuals who participate in labour market measures without being employed

Where to report issues of concern

The municipality’s whistleblowing scheme has two channels: a local whistleblowing channel at enterprise level, and a central whistleblowing channel organised by the Office of the Governing Mayor. The scheme adopts the principle that reports should be resolved at the lowest possible level.

As a general rule, all employees and temporary personnel should use the company’s local whistleblowing channel. Employers have a duty to accept, process, resolve and follow up reports.

The central whistleblowing channel should be used if:

• the case involves corruption or serious financial irregularities
• the report relates to an executive (Agency Director, District Director or Managing Director in a municipal enterprise or Director General in a Department)
• your case had not been handled correctly at the local level or have other specific reasons
• you are not employed by the City of Oslo, which makes you an external whistleblower

Please note that even if your report is submitted to the central whistleblowing channel, the content of the report will determine how it is followed up. Following an assessment, the
report can be forwarded to the relevant department which then decides on further processing – for example, whether the employer should follow up the report through its local whistleblowing channel.

Anonymity and access to case information

You can choose to report anonymously. Regardless of whether you provide your name, the report will be handled in accordance with laws and regulations for public case proceedings. If you choose to report anonymously, this can limit our ability to investigate the matter.

Access to whistleblowing cases and publicity

Documents in whistleblowing cases are subject to the same legal framework regarding confidentiality and public access as other documents. Confidential information will always be exempt from public disclosure. As a general rule, the whistleblower’s identity, and information likely to identify the whistleblower will be protected.

In order to meet and respond to the claim, the person whom the allegations are made against is entitled to the case documents. If individuals cannot be identified, or if the report does not involve any confidential matters, the whistleblower’s report can also be made public following a request for access (see section below).

However, information not covered by the exemptions outlined in the Norwegian Freedom of Information Act can be disclosed or made available following a request for access or a decision by the County Governor.

The City of Oslo is committed to ensuring that its whistleblowing system is safe for all whistleblowers, and protecting the rights of the implicated individuals will be prioritised in the assessment. You can read more about confidentiality and the right to access on the Norwegian Labour Inspection Authority’s website.

How to report issues of concern

You can report issues of concern orally or written, and there are no formal requirements
regarding the content of your report. However, the report must have a clear description of
the issues, and should include:

• the name of the organisation and department or division
• specific information about the subject of the report
• the time and place
• details of individuals with knowledge of the matter

Please submit documentation to support your claims when possible.

If your report lacks sufficient information and obtaining additional details is not feasible (in
cases where anonymity is maintained), we will not be able to conduct a substantive review,
and the case will be closed.

If you need assistance in formulating your report, you can contact the whistleblowing
hotline on 800 82 775.

You can report via online form or phone, in person, or by post

Online form

Online registration form (in Norwegian)

You will receive a reference number after submitting your report. Please keep it safe. If you have
additional information after the report is submitted, please call the whistleblowing hotline. Make
sure to have your reference number ready.

By phone or in person

• Whistleblowing hotline: 800 82 775.
• The whistleblowing hotline is open on Mondays to Fridays from 09:00 to 15:30.
• The caller’s phone number is not visible to the call recipient.
• You can also arrange to visit the external whistleblowing unit in person, located in
  BDO’s offices in Vika Atrium.

If you report via phone or in person, you will receive a reference number from the
whistleblowing unit.

Post

If you make an anonymous report by letter, we cannot provide you with feedback.
Send your letter to:

Whistleblowing unit, City of Oslo
v/BDO AS, Forensic Services
Munkedamsveien 45
PO Box 1704 Vika
0121 Oslo
For security reasons, it is not possible to report issues of concern by email.

What to expect

After receiving the report, the whistleblowing secretariat will review the allegations and decide whether the report should be processed by the central whistleblowing council or forwarded to the relevant department. The decision will be based on the criteria mentioned above. Named whistleblowers will receive confirmation that their report has been received and where it will be processed. Anonymous whistleblowers must contact the BDO whistleblowing unit to obtain this information.

If the report is forwarded to the relevant department, the department will assess how to handle the report and whether any follow-up is required.

Regardless of whether the report is processed by the central whistleblowing council or one of the departments, the following principles apply:

• The employer is obligated to investigate and resolve the issues in a timely manner.
• The employer must obtain a factual account of the reported issues.
• The employer needs to determine if there are issues of concern, assess if the case can be closed, or decide if additional measures are required.
• The employer is responsible for ensuring that the legal rights of both parties (the whistleblower and the subject of the report) are maintained. The whistleblower’s identity must be treated confidentially and only be disclosed to those investigating the case. The subject of the complaint is entitled to present his or her side of the case.
• Both parties should receive information about the outcome from the employer once the case has been investigated and can be closed. Due to privacy reasons, the employer’s ability to share information with the whistleblower is limited, unless the whistleblower is entitled to party disclosure under the Norwegian Public Administration Act. Anonymous whistleblowers can contact BDO to enquire about the status of their case.

Decisions regarding whistleblowing cases, made by the central whistleblowing council or specialised department are not individual decisions and can therefore not be appealed.

Retaliation

Employers are responsible for ensuring that permanent or temporary employees are not subjected to retaliation as a result of whistleblowing.

Disputes regarding violations of the prohibition against retaliation can be brought before the Norwegian Anti-Discrimination Tribunal. Please note that this does not apply to cases involving dismissal or termination.

You can read more about the role and function of the Norwegian Anti-Discrimination Tribunal here