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?

IFDK employees, employees of investment projects financed by IFDK, third parties with a business relationship to IFDK, and third parties with concerns about adverse impacts of IFDK’s activities or the projects financed by IFDK may report their concerns into the channels established for reporting misconduct. Reports of misconduct can be sent to the IFDK Whistleblower Unit through the following channels:

Reports of misconduct related to IFDK projects may be sent to the channels above or reported directly to the IFDK employees who are connected to the project. The Whistleblower Unit’s screening and investigation of whistleblower reports is independent from IFDK’s executive management.

Reports of misconduct may also be sent to the external Danish national whistleblower scheme at https://whistleblower.dk. However, IFDK encourages the use of its internal whistleblowing channels in the first instance when reporting a concern that can be effectively handled by IFDK.

What can be reported?

Reports of actual or suspected misconduct in scope of this Policy include concerns about:

  • Serious breaches by employees of IFDK ethics guidelines and other IFDK policies or binding guidelines
  • Breaches of applicable laws and regulations and other material concerns, including bribery and corruption, fraud, theft, embezzlement, money-laundering, sanctions violations, harassment, and bullying  

Cooperation difficulties at the workplace, routine employment issues (such as vacation time, office climate, etc.), commercial inquiries, questions related to applications for employment, minor breaches of IFDK’s policies and binding guidelines, and other general questions are not within the scope of this Policy. These matters should be raised in a dialogue with an immediate manager or the People and Culture department.

Protection for whistleblowers

Whistleblowers who make reports in good faith are protected against retaliation that is motivated by their whistleblower report. Individuals who make reports in bad faith or otherwise misuse the procedures may be excluded from the protections, restricted in their use of the procedures, and subject to civil, criminal and employment law sanctions. Please see Impact Fund Denmark’s Whistleblower Policy. We also refer to the Whistleblower Unit Disclosure 2024.