Whistleblowing & grievance system

Impact Fund Denmark encourages an open dialogue on all issues related to Impact Fund Denmark and its investments, including when concerns may arise. This is why we make a grievance mechanism available to stakeholders (the “Grievance Mechanism”).

The Grievance Mechanism enables our employees, employees in projects financed by Impact Fund Denmark (“Impact Fund Denmark Investees”), as well as other external stakeholders to raise a grievance if they identify irregularities with Impact Fund Denmark’s commitments, policies and procedures, or any other legal misconduct, including concerns about impacts on human rights under the United Nations Guiding Principles on Business and Human Rights.

Impact Fund Denmark encourages employees and Impact Fund Denmark Investees to discuss concerns with their immediate superior, another manager, or their human resources function. However, if this is not possible, or if you have done so and you believe that your concern has not been handled correctly, you may report the issue according to the Impact Fund Denmark Whistleblower Policy, using the Grievance Mechanism.

Who can report and where?

Impact Fund Denmark’s employees, employees in projects financed by Impact Fund Denmark, other Impact Fund Denmark stakeholders, third parties with a business relations to Impact Fund Denmark and our projects, and other parties affected by our activities may make reports governed by the Whistleblower Policy.

Anonymous report

Reports can be made through:

What to report

The Grievance Mechanism can be used to report concerns that are covered by the Impact Fund Denmark Whistleblower Policy. In particular, the Grievance Mechanism can be used to report concerns about adverse impacts on individuals or communities by activities carried out by Impact Fund Denmark or our investees.

The Grievance Mechanism can be used for reporting violations comprised by the Danish Whistleblower Protection Act, and thus you may file a report regarding

  • violations of specific areas of EU law
  • serious offences and other serious matters
Protection of the identity of reporters/whistleblowers and witnesses

Impact Fund Denmark does not tolerate harassment, vengeful actions, or other types of sanctions against any person who in good faith files a report or who assists Impact Fund Denmark in connection with the processing and investigation of a case.

The identity of the reporter/whistleblower will be kept confidential to the extent possible, considering Impact Fund Denmark needs to make a thorough investigation. However, it may be necessary to disclose information about identity if the issue is reported to the police or if the case is taken to court.

Persons who report in bad faith are not protected by the Whistleblower Policy and may be subject to civil, criminal and employment law sanctions, including possible dismissal.

Deletion of data

Impact Fund Denmark is the data controller of the Grievance Mechanism. Personal data processed in connection with Impact Fund Denmark’s Grievance Mechanism are kept for as long as deemed necessary for the purpose for which the data were collected.

If the result of a specific case presents no evidence of any irregularity, the personal data will be deleted immediately and as a main rule by two months after closing the case.

If evidence of irregularities is found, various storage periods apply, depending on factors such as whether legal action or disciplinary steps are taken against the reported person or against the person who filed the report, in cases where the report is filed in bad faith.

Data may also be stored if they are anonymised.

Please see Impact Fund Denmark’s Whistleblower Policy for further information on your rights as a whistleblower/reporter, what and how to report and how Impact Fund Denmark processes your report and personal data. We also refer to the Whistleblower Unit Disclosure 2024.