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Whistleblowing - when you suspect or have information about misconduct

The university's whistleblower function is a special channel set up to facilitate reporting of suspicions of malpractice at Luleå University of Technology.

The Whistleblower Act

Sweden has a law that protects you who report misconduct, commonly known as the Whistleblower Act. It applies from 17 December 2021. The law briefly means:

  • that you must not be hindered or punished for whistling,
  • that you may sometimes circumvent your duty of confidentiality,
  • that more people than before can whistle.

The Whistleblower Act also requires that authorities, such as Luleå University of Technology, must ensure that you as an employee can whistle and that your identity is protected by confidentiality. In order for your whistleblowing to be covered by the law, it is required that you are part of the circle of those who can report, what the misconduct refers to and that you report on the misconduct in the ways that the university directs.

When should the whistleblower function be used?

The whistleblower function should be used when you have information about misconduct at Luleå University of Technology that affects the public negatively if they are not found and remedied, or when you suspect that the university is violating certain EU legislation. 1

When should the function not be used?

Reporting of personal misconduct that exclusively affects the reporting person or their own work situation, such as conflicts between the reporting person and another employee, wage setting or equivalent, is generally not considered to be in the public interest and is not covered by the Whistleblower Act and should therefore not be reported to the whistleblower function.

1 The Whistleblower Act is relevant if you suspect that the university is violating EU rules within; public procurement, financial services, products and markets and the prevention of money laundering and terrorist financing, product safety and conformity, transport safety, environmental protection, radiation and nuclear safety, food and feed safety and animal health and welfare, public health, consumer protection and privacy, privacy security in network and information systems.

Here's how to report malpractice

There are four ways to report: by letter, email, phone or personal meeting.

1. By letter

You send the letter to:

Luleå University of Technology
The whistleblower function
971 87 Luleå

Mark the envelope with "Whistleblowing". This means that your letter is handled correctly and is only opened by authorized employees. You will receive a confirmation that the university has received your letter and feedback on what the investigation of your report leads to. You can indicate whether you do not want confirmation or feedback. Please write your telephone number or residential address in your letter.

If you would like confirmation that the University has received your letter, you should receive it within seven (7) working days. Feedback on the case is given within three months.

2. By telephone

You can call the university's switchboard on 0920-49 10 00 and ask to be connected to the head of security.

3. Via e-mail

You can email your report to visselblasare@ltu.se

4. Personal meeting

Contact the security manager.

Is it possible to report anonymously?

You can report misconduct anonymously, but then your reporting does not count as whistleblowing under the Whistleblower Act. An investigation can be based on anonymous information, but as additional information is usually required to be able to conduct an investigation, the possibilities to carry it out are significantly hindered if contact information is missing.

What does the report need to contain?

  • Make as clear a description of what your suspicions or your information is about.
  • Tell who or which persons it applies to.
  • If you have documents, pictures, e-mails or other things, please include them in the report
  • If there is anyone else who can also contribute with information, please attach their contact details
  • Contact details are recommended

The reporting person does not have to have proof, but it is required that the reporting person had "reasonable reason" to believe that the information reported was true. Anyone who intentionally provides incorrect information may themselves be guilty of a criminal act.

What happens after the report is sent?

The report, or the so-called "whistle", is received by the head of security, or if he is prevented, by an appointed lawyer.

The security manager contacts the appointed lawyer and accounting manager to assist in the investigation. If additional information is needed, the security manager may contact you during the investigation. The investigation may lead to the conclusion that there is no reason to take measures. The case is then closed. The investigation may also need to be handed over to another function within the university or to another authority for further investigation or action.

If you have chosen to receive feedback on your whistleblowing, you will receive information about the investigation within three months. The information briefly describes the investigation and the conclusions drawn. You can choose to refrain from feedback. The head of security reports to the university director who, if necessary, reports to the vice-chancellor, or in cases where it is deemed inappropriate to report to the vice-chancellor, to the chairman of the university board.

Personal data and anonymity

The whistleblower function may process personal data in order to be able to carry out its mission. In addition, the function may process personal data for the purpose of distributing incoming reports that are not to be investigated by the whistleblower function within the organization. In doing so, the function shall not process personal data to a greater extent than is necessary to determine which function or executive shall handle the matter.

Notifications from persons outside the authority are always received documents that must be kept in a diary or otherwise kept in order, in accordance with the provisions of the Publicity and Secrecy Act and the Freedom of the Press Ordinance. Such documents immediately become public documents. Notifications from the authority's employees are considered a case with the authority and must be entered in a diary or kept organized in another way. The starting point is that the notification should be seen as a public document.

As the university is an authority and thus covered by the principle of public disclosure, anonymity cannot be guaranteed if the identity of the notifier is apparent from a document submitted to the function. Actions of the whistleblower function may, depending on the content, be protected by confidentiality. However, this does not apply to all documents, and in addition, confidentiality ceases to apply after a period of time. Those who wish to remain anonymous therefore need to make their report in such a way that the identity of the reporter is not apparent from any document

Who is protected by the Whistleblower Act?

To be protected by the Whistleblower Act you are

  • employee,
  • looking for work,
  • looking for or carrying out internships or volunteer work,
  • self-employed persons seeking or carrying out assignments,
  • temporary worker,
  • a person who is part of the university's administrative, management or supervisory body.

The protection also applies when you have left Luleå University of Technology.

Sometimes the whistleblower law does not apply

In a couple of different cases, the whistleblower law does not apply. For example:

  • when you who report do so as a student, patient or citizen of society.
  • if what you report is not of public interest or does not constitute a violation of specified laws
  • if what you report only concerns your own working or employment conditions and does not involve corrupt practices
  • if you knowingly report false information or commit a crime by reporting it
  • if what you are reporting concerns security classified information under the Security Protection Act or information relating to the security of the nation
  • if you report anonymously

This is how you are protected as a whistleblower

The law means that you may not be prevented or punished for blowing the whistle, that you may sometimes circumvent your duty of confidentiality, that you may not be punished for producing information about people related to your whistle-blowing, and that you do not have the right to hand over documents that contains confidential information.

If your colleagues subject you to offensive discrimination, it is a matter that is handled according to the rules that exist at the university, for example work environment rules. The duty of confidentiality and certain exceptions If you have reason to blow the whistle, you may not be punished or held responsible for having broken a duty of confidentiality. Exceptions apply to qualified confidentiality and confidentiality under the Defense Inventions Act.

Read more about the law - Government information

Protection for you as a whistleblower with support from other laws


Freedom of communication

Freedom of information means that all employees in public activities can submit information to mass media for publication without risk of penalties. This also applies to a certain extent to classified information. If, for example, the secrecy applies to the protection of national security, there are exceptions to the freedom of communication.

Freedom of information also means that it is forbidden to try to investigate sources. Freedom of communication does not imply any right to disclose documents containing classified information.

Freedom of purchase

With freedom of acquisition, you get the right according to the Freedom of the Press Ordinance and the Freedom of Expression Act to acquire information with the aim of having the information published. The freedom of procurement can be seen as an extension of the freedom of communication.

Prohibition of research

Prohibition of investigation means that authorities or other public bodies may not investigate who has submitted a message in support of the freedom to communicate. Anyone who has received information submitted for publication has a duty of confidentiality regarding the identity of the informant.