The Whistleblowing Act

Sweden has a law protecting those who report wrongdoings and irregularities. This law is referred to as the Whistleblowing Act, it came into force on 17 December 2021, and means:

  • that you should not be prevented from, or punished for reporting wrongdoings
  • that sometimes you may circumvent confidentiality obligations
  • that more people may now report wrongdoings

The Whistleblowing Act also sets requirements on government agencies, such as Stockholm University, to ensure that staff can blow the whistle and that whistleblowers’ personal data is protected.

Read more (note! in swedish) about the Whistleblowing Act (Visselblåsarlagen) at the Government Offices of Sweden website

Who is covered by law 

To be protected by the Whistleblowing Act, you need to be:

  • an employee
  • applying for a job
  • applying for or undertaking internship or voluntary work
  • self-employed applying for or conducting work
  • rented labour
  • a member of an administrative, managerial or supervisory body at the University

The protection also applies after you have left Stockholm University.

As a whistleblower you are protected

The Whistleblowing Act means that you may not be prevented from, or punished for, reporting wrongdoings. You are covered by the Act even if you do not know for sure that the wrongdoing you report is illegal. It is enough that you have reason to suspect that it is illegal.

Report wrongdoings – Whistleblowing

There are two ways of reporting a wrongdoing (whistleblow) – via an electronic web form (SU:s whistleblower function) or by telephone. By the whistleblower function or answering machine, you can also request to report at a physical meeting. Your report will be handled by an external provider (KPMG) and you decide if you want to remain anonymous.

If you wish to continue the dialogue and/or follow the case status, you will be assigned a unique case number and password to be able to follow the case in the SU Whistleblower function. You need to save the information securely. KPMG receives the case (and send a confirmation if the reporting person has created an account for further contact, or provided contact information in another way). KPMG then makes an initial assessment of the case.

The report and the initial assessment are forwarded to the pre-determined contact persons within Stockholm University for further handling and action planning. KPMG ensures that a report is not forwarded to anyone within Stockholm University who is affected by the report. Stockholm University decides on possible measures.

Feedback is provided to the person who reported, if the person has created an account or provided contact information in another way.

Confirmation and feedback

You will receive a confirmation, from KPMG that the report has been received within seven days, unless that you have not waived this confirmation or if there is reason to believe that a confirmation would reveal your identity. KPMG provides reasonable feedback to the person reporting on what action has been taken, and why, within three months of receipt of a report (or if no acknowledgment of receipt has been provided, seven days after receipt of the report).

Rules and procedure for handling suspected irregularities and crime (Governing Documents at Stockholm University – Rules & Regulations) 

When the law does not apply

There are times when the law does not apply, for example:

  • if a whistleblower files a report in their role as a student, patient or citizen
  • if what you are reporting is not of public interest or does not constitute a crime against the regulations referred to
  • if what you are reporting only concerns your own work or employment situation and it does not involve corruption
  • if you deliberately report false information or commit an offence by making a report
  • if what you are reporting concerns security-protected information pursuant to the Protective Security Act, or information affecting national security
  • if you are filing a report anonymously

Reporting incorrect information

If information that you reported turns out to be incorrect, but you had what the law says ”reasonable reason” to assume that the information you provided was true, then there is a possibility to still be covered by the Whistleblowing Act.

On the other hand, a person who intentionally and knowingly reports information that turns out to be incorrect or misleading is not protected by the Whistleblowing Act. A person that intentionally and knowingly reports incorrect information may be subject to sanction in various areas.

Public interest requirement

The Whistleblowing Act is not relevant if reporting concerns your own work or your own employment. For this type of private concern, use other channels for reporting, for example the incident reporting system for work environment-related incidents, or turn to the responsible personnel manager for questions about psychosocial work environment.

As a general rule, your disclosure should be in the public interest that the wrongdoing ceases. It may concern wrongdoing that constitutes an imminent or obvious danger to life, health, safety or risk of extensive damage to the environment or something else where there is a justifiable reason to report to the authority, e.g. financial irregularities.

Freedom to communicate information

Freedom to communicate information means that all employees of a government agency may share information with the media to be published without the risk of punishment. To a certain degree, this also covers confidential information. However, freedom to communicate information does not apply regarding confidentiality to protect national security. Freedom to communicate information means that no one may inquire into the source of the information.

This freedom does not provide the right to disclose documents containing confidential data.

Other report channels

Reporting of accidents, incidents and safety deviations, crimes, incidents, occupational injuries, occupational diseases and environmental deviations should be reported via the IA system:

Reporting/commenting about your own work environment must be handled according to:

Reporting/commenting about animal protection and animal welfare are sent to (e-mail): tillstandshavarkansliet.mbw@su.se

Reporting of security protection classified information or other information concerning Sweden’s security is done according to säkerhetsskyddslagen (2018:585).

Information regarding a so-called qualified duty of confidentiality. This may be, for example, information concerning Sweden’s relationship with foreign powers where the nation’s security is in danger (15 kap. 6 § OSL), or or certain secrecy within the authorities’ personnel administration (39 kap. 6 § OSL).