Anti-Corruption 2026

DENMARK Trends and Developments Contributed by: Christian Monberg, Simon Evers Hjelmborg, Ann Sophie Juul Hird and Linn Dyrgaard Stinus, Accura Advokatpartnerselskab

to properly inform parliament about key aspects of the procurement process, including delivery timelines and the existence of a prior settlement agreement with Elbit. The controversy was further intensified by the fact that Elbit Systems had previously been excluded from investment portfolios by several Danish pension funds due to alleged involvement in human rights vio - lations. Although no direct evidence of bribery has emerged, the case is an example of public decisions made with - out sufficient transparency or democratic safeguards. Moreover, the case may be utilised as an example of the need for Denmark to strengthen its regulatory framework around lobbying and transparency in politi - cal decision-making processes. The political aftermath of the case is still unfolding, likewise it remains unclear whether there is a con - nection between the purchase of weapons from Elbit and the fact that the state simultaneously entered into a settlement in a case brought against the state by Elbit. Over the course of four weeks during the Fall of 2025, the Danish Parliament’s Scrutiny Committee is conducting a series of closed hearings to investigate whether parliament was misled during the procure - ment process. The Mauritius Power Plant case On 3 July 2024, the District Court of Hillerød ruled in a bribery case involving a Danish contractor in con - nection with the construction of a power plant in Mau - ritius. Between 2019 and 2024, the company’s local subsidiary paid at least DKK632,000 (EUR85,000) in bribes to politicians, civil servants, and other deci - sion-makers in Mauritius. The payments were made through intermediaries with the aim of gaining access to confidential information that could improve the company’s chances of winning a public tender worth DKK790 million (EUR106 million). The company itself reported the suspected misconduct to Danish authori - ties in 2019 and co-operated throughout the investi - gation. The court found that the payments constituted bribery and misuse of entrusted power for commercial gain. The company accepted a fine of DKK10 million.

The Defence Dinner case The Eastern High Court of Denmark ruled on a bribery case involving a former procurement officer with the Ministry of Defence Acquisition and Logistics Organi - sation (DALO) on 13 November 2024. The procure - ment officer was convicted of having accepted an undue advantage in the form of an expensive dinner at the Michelin-starred restaurant, Kong Hans Kælder (King Hans Basement) in 2011. The dinner, valued at a minimum of DKK2,500 (EUR335), was offered by an employee of a weapons supplier during negotiations concerning the quality of ammunition delivered to the Danish Army. The court found, based on the price of the dinner, that the benefit was unjustified. The court emphasised that a dinner at a Michelin-starred res - taurant like Kong Hans Kælder significantly exceed - ed what could be considered acceptable. The court found that the officer had acted with intent and that the dinner constituted passive bribery. The procure - ment officer was sentenced to ten days of imprison - ment, suspended for one year. The FES case In a court ruling dated 16 September 2024, sever - al persons (physical and legal) were found guilty of corruption and bribery involving the Danish Defence Estates and Infrastructure Organisation (FES) by the Eastern High Court of Denmark. The case centred around the misuse of public funds and the acceptance of bribes by public officials and their collaborators. A former office manager at FES (the “office manager”) was convicted of gross criminal breach of trust and passive bribery. Between 2014 and 2019, the office manager allowed FES to cover personal expenses, including a kitchen, an electric awning, and house - hold appliances, totalling DKK124,783 (approximately EUR17,000). These actions were carried out in col - laboration with a project manager at FES (the “project manager”). The office manager received a six-month suspended prison sentence with community service due to his good personal circumstances and age. An associate of a kitchen supplier to FES (the “asso - ciate”) was found guilty of active bribery in 2014, involving a kitchen worth DKK82,427 (approximately EUR11,000). Additionally, the associate was convict - ed of aiding the project manager’s criminal breach of

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