Whistleblowing in FRI – The Norwegian Organization for Sexual and Gender Diversity

We encourage you to submit reports by clicking the whistleblowing button. When you click the whistleblowing button, you will be taken to an encrypted reporting form, which means it is extra secure to send information to the Whistleblowing Committee through the form. Reports may contain highly sensitive information and should therefore not be sent by email or text message.

You may choose to report anonymously. An anonymous report can be more difficult to follow up, because the Whistleblowing Committee cannot contact the reporter regarding the report. However, you are fully entitled to report anonymously.

For privacy reasons, you will not receive a copy of your submission by email. Therefore, please take extra care to ensure that the email address and phone number you provide are correct, so that the Whistleblowing Committee can contact you. It may be a good idea to copy what you have written onto your mobile phone or computer to save it locally.

You can also file a report by calling the Secretary General on +47 48 11 84 56, by writing to us by letter, or by requesting an in-person meeting.

Whistleblowing Procedures

Guidelines for the receipt and handling of whistleblowing reports in FRI, adopted by FRI’s National Board on 14 May 2023 and most recently revised at the National Board meeting 19–21 September 2025.

1. Purpose – whistleblowing procedures

FRI’s whistleblowing procedures provide guidelines for the submission, receipt, and handling of reports concerning matters that conflict with FRI’s statutes, guidelines, or Norwegian law.

2. Who can report?

Everyone affiliated with the organization or participating in any of FRI’s events (partners, volunteers, members, etc.) has the right to, and is encouraged to, report matters within FRI that may conflict with FRI’s statutes, guidelines, or Norwegian law. Such matters are referred to in these procedures as wrongful conduct.

3. What can be reported?

You may report cases that are considered, or suspected to be, wrongful conduct in FRI’s activities or operations. This may involve something you have experienced yourself, something you have observed, or something you have been told by others that you believe constitutes wrongful conduct. Reports may concern matters of lesser or greater seriousness. Examples include bullying, harassment, unwanted sexual attention, discrimination, racism, drug or alcohol use that prevents the performance of duties on behalf of FRI, circumstances that threaten life or health, dangerous products, corruption, embezzlement or theft, or other fraud or financial misconduct in the course of service.

FRI strongly recommends that suspected criminal offences be reported to the police. The Whistleblowing Committee may be contacted for a conversation about this.

If you are unsure whether what you have experienced, observed, or been told should be reported, you may contact the Secretary General or the president of FRI to discuss it.

If what you have experienced or observed concerns gaps in addressing misconduct in the organisational culture in one or more parts of FRI, it is recommended that this be raised as a matter for either the regional board or the national board.

4. How do you report?

Reports in FRI are, as a rule, received and handled by FRI’s Whistleblowing Committee; see further details about the committee under section 6. If the matter being reported occurred in a regional chapter, the reporter may choose to report to the regional chapter leader. If the regional chapter leader is unable or unwilling to follow up the case, or is disqualified due to a conflict of interest (see section 7), the case must be handled by the Whistleblowing Committee.

A report may be submitted through the whistleblowing form, by telephone, by in-person attendance, or by regular mail. The members of the Whistleblowing Committee shall always be listed at the top of FRI’s whistleblowing page. Reports to the Whistleblowing Committee are, as a rule, sent to the Secretary General. If the reporter does not wish to report to the Secretary General, the reporter may choose whom they wish to contact within the Whistleblowing Committee.

Reports concerning employees of FRI must be sent to the employee’s line manager/personnel manager or the managing director.

Contents of the report

It is helpful if the report contains the following information:

Date, time, and place of the incident/observation, if the report concerns one or more specific incidents.
A specific description of what is being reported and any witnesses, and any knowledge of previous cases involving the same person(s).
The name of the reporter, if you wish to be involved in the further handling of the case.

You may also report anonymously, but this may make it impossible for the Whistleblowing Committee to handle the report.

5. Confidentiality, anonymity, and safeguarding the parties

All reports are handled confidentially. This means that information in the case and the reporter’s identity must not be disclosed to more people than strictly necessary. Everyone involved in handling a report has a duty of confidentiality and must ensure that the identities of both the reporter and the person being reported are kept secret from all third parties.
The reporter shall remain anonymous to the person being reported.

Exceptions apply if:
the reporter themselves wishes the person being reported to know their identity
dialogue between the parties is initiated
due to the nature of the report, it is not possible to keep the reporter’s identity hidden from the person being reported in order to proceed with handling the report
the case is reported to the police

Retaliation for whistleblowing must not occur, and those handling a report must ensure that the reporter is protected from retaliation.

A person who is the subject of a report has the right to know that a whistleblowing case is ongoing in which they are involved, and must also be given the opportunity during the process to present their version of events to those handling the report. Information must be handled in accordance with the confidentiality guidelines, see the first paragraph of section 5 of these procedures. Those handling the report must work to safeguard all parties involved in the best possible manner.

In some cases, it may be appropriate to obtain expertise beyond what the committee or regional chapter leader possesses. This shall be done in consultation with the person having submitted the report and in line with the confidentiality guidelines. The identities of those involved will be withheld from persons having been given an advisory role.

All information in a whistleblowing case must be handled and stored with great care. As a general rule, no information shall be stored physically, but only in digital spaces accessible only to those who strictly need access.

6. FRI’s Whistleblowing Committee

FRI has a national Whistleblowing Committee which handles whistleblowing cases and serves in an advisory capacity in cases handled at the regional level.

The Whistleblowing Committee may assess whether there has been a breach of statutes or guidelines and may provide recommendations and advice. Beyond this, the committee has no authority to impose sanctions.

The Whistleblowing Committee consists of the president of the Executive Board and the Secretary General, as well as two external members elected by the National Board. The individuals who at any given time constitute FRI’s Whistleblowing Committee, and their contact information, are publicly available at foreningenfri.no/varsling. A report must always be handled by at least two committee members. In cases of greater seriousness, and always where the reporter requests it, the committee as a whole shall participate in handling the report.

If a report concerns a member of the Whistleblowing Committee, or someone in a close relationship with a member of the committee, that member must not participate in handling the report.

7. Impartiality (conflicts of interest)

The person handling the report must not have any personal interests in the case. Each person must, on their own initiative, assess their own impartiality, and in cases of doubt ask other members of the committee for an objective assessment. Upon request, an objective assessment must be carried out. The parties shall be informed of the outcome of the assessment and the reasoning.

7.1 Receipt of a report

If a report is made to a regional chapter leader, the leader shall immediately inform the Whistleblowing Committee about the case.

If the case is of moderate scope, and there is agreement with the person having submitted the report and the Whistleblowing Committee, the case may be handled locally and the regional board may itself handle the report. The Whistleblowing Committee shall be informed of the conclusion of the case and may otherwise provide advice along the way.

The person having submitted the report shall receive prompt feedback, no later than within one week, confirming that the report has been received and what they can expect from the further process. The case shall be concluded within a reasonable time, and no later than within two months. The reporter is not entitled to detailed information about all aspects of the handling, and for the sake of all parties, sensitive personal data that emerges in the case processing shall be handled confidentially. Only parties to the case have rights in the relevant matter.

Both the reporter and the person being reported shall be assigned a contact person within the Whistleblowing Committee with whom they can maintain dialogue throughout the process. If the case is handled by the regional board, the reporter and the person being reported shall be assigned a corresponding contact person from the board.

7.2 Investigation and assessment

The Whistleblowing Committee shall take all reports seriously and investigate the different aspects of the case. The same applies to the regional board if the case is handled locally. The Whistleblowing Committee shall hear from the person being reported, and where necessary from person(s) who witnessed the incident or other matters that have been reported.
Throughout this phase, those handling the report shall ensure that meeting minutes, communication logs, and other documentation related to the case are obtained and stored in accordance with the data storage procedures, see section 5, fifth paragraph.

7.3 Conclusion and assessment of further measures

Those handling the report shall make an overall assessment of all aspects of the case, and then consider and propose any further measures, consequences, or possible sanctions. Any measures and consequences resulting from a report depend on a concrete and individual assessment. Measures and consequences proposed by a regional board shall be assessed and, where applicable, adopted by the Whistleblowing Committee. Conclusions must not be made by one person alone.

Measures, consequences, and any sanctions shall, as far as possible, be constructive, proportionate to the nature of the case, and safeguard the parties involved.

If it becomes relevant to permanently or temporarily remove a member from a position of trust and/or membership in FRI, this shall be done in accordance with section 18 of the statutes.

If the Whistleblowing Committee considers that the National Board or Executive Board has breached the organization’s statutes, the Whistleblowing Committee shall inform the Control Committee of this.

7.4 In case of breaches of Norwegian law

If the handling of the report reveals that a criminal offence has occurred, FRI shall offer support to the affected party if they wish to report the matter to the police. The Whistleblowing Committee acknowledges that such a process may be burdensome, so it is up to the affected party whether they wish to file a police report. The exception is where a specific criminal offence has occurred in the form of an incident at an event for which FRI was the responsible organizer. In such cases, FRI itself shall report the matter to the police. The general duty to avert under section 196 of the Norwegian Penal Code applies regardless. FRI may, independently of the police’s work, adopt measures in line with the organization’s statutes and guidelines.

8. Appeal

If the report has been handled by a regional board, the reporter or the person being reported may appeal the case to the Whistleblowing Committee. If the report has only been handled by the Whistleblowing Committee, the committee’s handling may be appealed to the Executive Board for a new assessment. If the case concerns the Executive Board, the handling may be appealed to the Control Committee.

9. Updating and follow-up of the whistleblowing procedures

FRI is responsible for ensuring that the organization at all times has updated whistleblowing procedures. The guidelines shall be reviewed annually by FRI’s Executive Board and revised as needed. Final approval is made by FRI’s National Board.

The guidelines shall be well known within the organization, and the Secretary General of FRI has the day-to-day responsibility for implementation across the different parts of the organization. Elected representatives in FRI are obliged to familiarize themselves with the whistleblowing procedures.

If someone withdraws from the Whistleblowing Committee, the committee shall be supplemented at the next National Board meeting.